Updated on August 2021.

QUBA Co., Ltd. (Registered address at Yangcheon Venture town 103-105ho, 201ho, 204-206ho, 267，Sinjeong-ro, Yangcheon-gu, Seoul, Republic of Korea) and QUBA Smart Technology (Shanghai) Co., Ltd. (Registered address at Room 132, 12F, Building 1, 588 Zixing Road, Minhang district, Shanghai, China) and its affiliates (collectively, “QUBA “, “we”, “us”, and “our”) respect your privacy.

Therefore, we have developed a Privacy Policy (hereinafter referred to as “Policy”) that covers how we collect, use, disclose, protect, store and transfer your personal data. Please take a moment to read and understand our Privacy Policy and let us know if you have any questions.

Personal data means any electronic or other information which alone or jointly with other information can be used to identify a natural person or make him/her identifiable. Policy explains how QUBA processes your personal data, but does not cover all processing scenarios as you will be informed in specific processing activity. Therefore, before using a specific product or service, it is recommended that you read the privacy notice or supplementary Policy released by QUBA for that product or service to understand how it processes your personal data.
Policy applies only to QUBA personal and home products, including smart household appliances, smart lock products, mobile services, software, toolkits, websites, and services that display or mention Policy.

Policy describes:
I. How QUBA Collects and Uses Your Personal Data
II. How QUBA Uses Cookies and Similar Technologies
III. How QUBA Shares Your Personal Data
IV. How QUBA Protects Your Personal Data
V. How You Can Manage Your Personal Data
VI. How QUBA Protects Children’s Personal Data
VII. Links to Third-Party Websites, Products, and Services
VIII. International Transfers of Your Personal Data
IX. Updates to Policy
X. How to Contact Us

I. How QUBA Collects and Uses Your Personal Data

A. Personal Data Collected by QUBA
Before using QUBA products or services, you may need to provide personal data. You do not have to provide your personal data to QUBA , but in some cases, the non-provision of certain personal data will cause the inability to provide you with some related products or services.
QUBA will collect and use your personal data for the purposes stated in Policy. Here are some examples of personal data we may collect:

a. Personal data that you provide to QUBA
You need to register a QUBA ID to enjoy certain functions or services. When you register a QUBA ID or log in with a QUBA ID to reach supports from QUBA , download software/documents, or purchase services, we will ask you to provide relevant personal data, such as your name, email address, mobile number, order information, shipping address, and payment mode.
Some QUBA products allow you to communicate and share information with others. When you use a QUBA product to share things with your family and friends, you may need to create a QUBA ID that includes certain information which will be made public, including a nickname and avatar. QUBA may collect information related to those people, such as their names, email addresses, and phone numbers. QUBA will take appropriate and necessary measures to ensure the security of the information that you provide. You must ensure that the people, whose information you provide, have consented to you providing their information to QUBA .
To meet some jurisdictions’ requirements on real-name authentication of accounts, such as Internet payment, QUBA might ask you to provide a proof of identity issued by the government or relevant card information that can identify you.

b. Information that QUBA collects in your use of services
QUBA will collect data about your device and how you and your device exchange information with QUBA products and services. This type of information includes:
(1) Device and application information, such as the device name, device identification code (such as SN), device activation time, hardware model, OS version, application version, software identification code, and device and application settings (such as region, language, time zone, and font size).
(2) Mobile network information, such as the public land mobile network (PLMN) provider ID and Internet Protocol (IP) address.
(3) Log information. When you use QUBA services or view QUBA -provided content, QUBA will automatically collect and log some information, such as the time of access, access count, IP address, and information about incidents (such as errors, crashes, restarts, and upgrades).
(4) Location information. QUBA will collect, use, and process the approximate or precise location of your device when you access some location-based services (for example, when you search, use navigation software, or view the weather of a specific location). Location information can be obtained based on the GPS, WLAN, and service provider network ID. We will ask you to choose the applications for which you want to enable location services. In the device settings menu, you can disable the location permissions of specific services to reject sharing your location information.
(5) Information you store on QUBA servers. For example, the information you upload to the cloud will be stored on QUBA servers for rapid access and sharing between devices.

c. Information from third-party sources
When permitted by law, QUBA will collect information about you from public and commercial sources. QUBA may also obtain certain information from third-party social network services, such as the time when you use a social network account to log in to a QUBA website.

d. Collection and use of non-identifiable data
Non-identifiable data refers to data that cannot be used to identify an individual. Examples of non-identifiable data include statistics on website visits, application downloads, and product sales volume. QUBA will collect statistics information to understand how users use our products and services. By doing so, we can improve our services to better meet your requirements.
We keep your personal data and non-identifiable data separate, and use each independently. Circumstances may arise where QUBA collects, uses, discloses, and transfers non-identifiable data for other purposes at our own discretion.

B. How QUBA Uses Your Personal Data
QUBA may use your personal data for the following purposes:

a. Register and activate QUBA personal and home products that you have purchased.

b. Register a QUBA ID so that you can enjoy a wider range of functions and mobile services.

c. Deliver, activate, or verify the products and services you have requested, or perform changes and provide technical support and after-sales services for the foregoing products and services based on your requirements.

d. Send you OS or application updates and installation notifications.

e. Provide personalized user experience and content.

f. Send you information about products and services you might be interested in, invite you to QUBA promotional activities and market surveys, or send marketing information to you. If you do not want to receive such information, you can opt out at any time.

g. Carry out internal auditing, data analysis, and research; analyses business operation efficiency and measure market shares; and improve QUBA ‘s products and services.

h. Synchronize, share, and store the data you have uploaded or downloaded, as well as the data needed for the upload and download operations.

i. Improve our loss prevention and anti-fraud programs.

j. Process pursuant to laws and regulations, e.g., tax, authority requests.

k. Other purposes within specific services or with your consent.

II. How QUBA Uses Cookies and Similar Technologies

A. Cookie
Cookie is a text file stored by a web server on a computer or mobile device, and the content of a cookie can be retrieved and read only by the server that created the cookie. Cookies are unique to the browser or mobile application you are using. The text in a cookie often consists of identifiers, site names, and some numbers and characters.
Sometimes, QUBA stores cookies on computers or mobile devices for the purpose of improving user experience, including the following scenarios:

a. Technical cookies: Login and verification. When you use a QUBA ID to log in to a website, the “session-based” cookies ensure that your visit to this site functions as smoothly as possible.

b. Personalized cookies: Storage of your preferences and settings. A website can use cookies to save settings, such as the language setting and font size on your computer or mobile device, items in your shopping cart, and other browser preferences.

c. Advertising cookies. QUBA uses cookies to collect information about your online activities and interests and provide you with advertisements that correlate most highly with you.

d. Statistical cookies. With cookies, QUBA can collect information about your use of our websites and other applications, either for a single visit (using a session cookie) or for repeated visits (using a persistent cookie).

e. Social Media Cookies. Social media cookies are linked to services provided by third parties, such as ‘Like’ buttons and ‘Share’ buttons. The third party provides these services in return for recognizing that you have visited our websites.
You can manage or delete cookies at your own preference. For details, visit AboutCookies.org. You can clear all the cookies stored on your computer, and most current web browsers provide the option of blocking cookies. However, blocking cookies will require you to change your user settings every time you visit our website. Find out how to manage cookie settings for your browser here: Internet Explorer > Google Chrome > Mozilla Firefox > Safari > Opera.
If you clear cookies, you will need to change your settings the next time you visit QUBA websites. Note that some QUBA services require the use of cookies. Disabling cookies may affect your use of some or all functions of these services.

B. Web Beacons and Pixel Tags
In addition to cookies, QUBA and some third parties may also use web beacons and pixel tags on websites. Web beacon is usually an electronic graphic image embedded into a website or email to identify your device cookies when you browse the website or email. Pixel tags allow QUBA to send emails in a way that is readable to you and find out whether an email is opened.
QUBA and some third parties use these technologies for various purposes, including analyzing service usage (together with cookies) and providing more satisfactory content and advertisements to you. For example, when you receive an email from QUBA , it may contain a click-through URL which links to a QUBA web page. If you click the link, QUBA will track your visit to help us learn about your preferences for products and services and improve our customer service. You can unsubscribe from the mailing list of QUBA at any time if you do not want to be tracked in this manner.

C. Other Local Storage
QUBA and some third parties may use other local storage technologies, for example, local shared objects (also called “Flash cookies”) and HTML5 local storage, in certain products and services. Similar to cookies, these technologies store information on your device and can record some information about your activities and preferences. However, these technologies may use different media from cookies. Therefore, you may not be able to control them using standard browser tools and settings. For details about how to disable or delete information contained in Flash cookies, click here.

D. Do Not Track
Many web browsers provide a Do Not Track function that can release Do Not Track requests to websites. Currently, major Internet standardization organizations have not established policies to specify how websites should handle these requests. If you enable Do Not Track in your browser, all QUBA websites will respect your selection.

III. How QUBA Shares Your Personal Data
We do not share personal data with other companies, organizations and individuals unless one of the following circumstances applies:

A. Sharing with consent: After obtaining your consent, QUBA will share the information that you have authorized with specified third parties or categories of third parties.

B. Sharing pursuant to laws and regulations: QUBA may share your information as required by laws and regulations, for resolving legal disputes, or as required by administrative or judiciary authorities pursuant to law.

C. Sharing with QUBA affiliates: Your information may be shared within QUBA ‘s affiliates only for explicit, and legitimate purposes, and the sharing is limited only to information required by services. For example, we verify the global uniqueness of accounts before allowing them to be registered.

D. Sharing with business partners: Some products and/or services are provided to you directly by our partners. QUBA also may share your information with them, they may use your information to provide you with products and/or services you request (e.g., products sold by third-party seller through QUBA ‘s e-commerce platform, video content provided by other companies through QUBA ‘s applications), make predictions about your interests and may provide you with advertisements, promotional materials and other materials

E. Sharing with service providers: QUBA also may disclose your information to companies that provide services for or on behalf of us. Examples of these service providers include companies that provide hotline services, send email, or provide technical support on behalf of QUBA . The service providers can use your information only for the purpose of providing services to you on behalf of QUBA .

F. QUBA will share your information when there is a reasonable requirement to do so, for example, to meet request of applicable law, regulation, legal process or enforceable government.
QUBA will ensure that the lawfulness of this sharing and sign stringent non-disclosure agreements (NDAs) and/or data processing clauses with the companies, organizations, and individuals with whom personal data is shared, requiring them to comply with Policy and take appropriate confidentiality and security measures when processing personal data.

IV. How QUBA Protects Your Personal Data
QUBA attaches great importance to the security of your personal data and has adopted standard industry practices to protect your personal data and prevent it from unauthorized access, disclosure, use, modification, damage, or loss. To this end, QUBA takes the following measures:

A. We take reasonable and feasible measures to ensure that the personal data collected is minimal and relevant to what is necessary in relation to the purposes for which they are processed. We retain your personal data for no longer than is necessary for the purposes stated in Policy and privacy notice of specific product or service, unless extending the retention period is required or permitted by law.

B. We use a range of technologies such as cryptographic technologies to ensure the confidentiality of data in transmission. We implement trusted protection mechanisms to protect data and data storage servers from attacks.

C. We deploy access control mechanisms to ensure that only authorized personnel can access your personal data. In addition, we control the number of authorized personnel and implement hierarchical permission management on them based on service requirements and personnel levels.

D. We strictly select business partners and service providers and incorporate personal data protection requirements into commercial contracts, audits, and appraisal activities.

E. We hold security and privacy protection training courses, tests, and publicity activities to raise employees’ personal data protection awareness.
QUBA is committed to protecting your personal data. Nevertheless, no security measure is perfect and no product, service, website, data transfer, computing system, or network connection is absolutely secure.
To cope with possible risks, such as personal data leakage, damage, and loss, QUBA has developed several mechanisms and control measures, clearly defined the rating standards of security incidents and vulnerabilities and corresponding processing procedures, and established a dedicated Security Advisory and Security Notice page. QUBA has established a dedicated emergency response team to implement security planning, loss reduction, analysis, locating, and remediation, and to perform tracking operations with related departments based on security incident handling regulations and requirements.
If any personal data incident occurs, QUBA will notify you, pursuant to relevant legal and regulatory requirements, of the basic information about the security incident and its possible impact, measures that QUBA has taken or will take, suggestions about active defense and risk mitigation, and remedial measures. The notification may take the form of an email, text message, push notification, etc. If it is difficult to notify data subjects one by one, we will take appropriate and effective measures to release a Security Notice. In addition, we will also report the handling status of personal data security incidents as required by supervisory authorities.

V. How You Can Manage Your Personal Data

A. Access, rectification, deletion, data portability, restriction of processing, objection to processing.
Legislation in some countries and regions to which QUBA provides products and services or from where QUBA processes personal data, provides that data subjects the rights request (hereinafter referred to as “requests”) in regards to the accessing, rectifying, deleting or erasure, porting, restricting, and objecting, the processing of related personal data by QUBA retains. In addition, you will have the right to data portability.

a. Requesting modes and channels
Data subjects’ requests must be submitted in accordance with QUBA designated privacy channels. The requests are valid even when the requester does not specify the laws on which the requests are based.
Data subjects’ requests may be initiated through the official website of QUBA . If a data subject initiates a request via a hotline, email, online customer service, service center, or another channel, we will instruct the data subject to officially raise the request through one of the aforementioned channels to facilitate communication and feedback of progress and results. The dedicated request channels for data subjects are intended to protect data subjects’ lawful interests, ensure QUBA ‘s normal operation, and prevent the right to request from being misused or fraudulently used.

b. Validity of requests
Most laws require data subjects to comply with specific requirements when they initiate requests. Policy requires data subjects to:
(1) Submit requests through dedicated request channels provided by QUBA (namely, the official website of QUBA ).
(2) Provide sufficient information for QUBA to verify their identities (to ensure those who initiate the requests are the data subjects themselves or those authorized by them).
(3) Ensure that their requests are specific and feasible.
There are some circumstances, provided by laws and regulations, in which QUBA may not have to comply with the request in full or at all.

B. Consent withdrawal
You can change the authorized personal data collection scope or withdraw your consent without affecting the lawfulness of the processing activities based on the consent and prior to such withdraw.
Your rights can be exercised by deleting information, disabling related functions, or setting privacy options on your QUBA product. QUBA will release the methods for withdrawing consent for specific products and services in the privacy notice or supplementary Policy of those products and services or upon request according to section A above.

C. Deregistering a QUBA ID
You can deregister your account in QUBA ID-related products. After you deregister your account, we will stop providing products and services, and delete your personal data unless otherwise stipulated by law. Your account cannot be restored after deregistration. You need to register a new QUBA ID if you want to use related QUBA products or services again. You can submit a deregistration application and complete the process in setting menu after logging in to your QUBA ID on related devices, applications or official website.

VI. How QUBA Protects Children’s Personal Data

QUBA ‘s personal and home products are intended for adults. However, for the use of QUBA products and services by children, we are fully aware of the importance of taking extra preventive measures to protect privacy and security. QUBA identifies whether data subjects are children based on the age of majority defined by laws of the local countries and regions.
When children’s personal data is collected based on the consent of the holders of parental responsibility, we will only use or disclose the information as permitted by law, explicitly consented to by the holders of parental responsibility, or required for protecting the children. Holders of parental responsibility who need to access, modify, or delete the personal data of their children and people under guardianship can contact us via the channels provided in “IV. How QUBA Protects Your Personal Data.”
If QUBA accidentally collects children’s personal data without obtaining consent from provable holders of parental responsibility, QUBA will delete the information as soon as possible after becoming aware of it.

VII. Links to Third-Party Websites, Products, and Services
QUBA websites, application software, products, and services may contain links to third-party websites, products, and services. QUBA products and services may also use or provide products or services from third parties, for example, third-party apps released on QUBA ID.
All links to third-party websites, products, and services are provided for users’ convenience only. You need to determine your interaction with such links on your own. Before submitting your personal data to third parties, please read and refer to these third parties’ privacy policies.

VIII. International Transfers of Your Personal Data
Your personal data may be stored and processed in countries where we have agencies or service providers, and by using the QUBA page, you consent to the transfer of information to countries outside your country of residence. Data protection rules that differ from your country may be used. In some cases, courts, law enforcement agencies, regulatory agencies, or security agencies in these other countries may have access to your personal data.

IX. Updates to Policy
QUBA reserves the right to update Policy at any time.
Should Policy be revised from time to time, QUBA will release the change notice via various channels, for example, posting the latest version on our official website: https://www.qubaindia.com
“Major changes” in Policy include but are not limited to:

A. Major changes in our service modes, for example, purposes of personal data processing, types of processed personal data, and ways of using personal data
B. Major changes in our ownership structure, organizational structure, etc., for example, ownership changes caused by business adjustment, bankruptcy, or acquisition
C. Changes in the main objects of personal data sharing, transfer, or disclosure
D. Major changes in your rights regarding personal data processing and the ways in which you can enjoy those rights
E. Changes of QUBA departments, contacts, and complaint channels responsible for the security of personal data processing
F. High risks identified in personal data security impact assessment reports

X. How to Contact Us
If you want to exercise your privacy rights, or have any privacy issues for which you need to lodge a privacy complaint with us, or want to consult us regarding general data protection, please email us at info@qubaindia.com
Note: Due to differences in local laws and languages, the local versions of QUBA Privacy Policy may be different from this version. In the case of any conflicts, the English version shall be prevailed.