1. Information We Collect
We collect the following types of information when providing our products and services:
1.1. Information You Provide to Us
1.1.1. Account Registration Information
When you register an account, we collect: Email address, Phone number, Username, Password. You represent and warrant that all information provided is accurate, complete, and current. During use, we may also collect: Nickname, Country code, Language preference, Time zone.
When you choose to authorize login with a third-party account, we will obtain the shared account information (default system avatar, nickname) from the third party and bind it with your account for quick login. In accordance with our agreements with third parties and the provisions on sharing personal information in the privacy policies published by third parties, we will use your personal information on the premise of compliance with relevant laws and regulations.
1.1.2. User Feedback
When you submit feedback, we collect: Email address, Phone number, Feedback content, Images or videos, Diagnostic logs. This information is used to resolve application and device issues.
1.1.3. Location-Based Additional Services
When you enable the location function of your mobile device through system authorization and use services provided based on location, we collect and use your location information to enable you to use the App for network configuration with intelligent devices.
Reason for requiring location permission in "Add Device" (Android system only): When entering the Add Device page, Bluetooth scanning is performed based on the function of searching for nearby devices. At this time, we need this permission to perform Bluetooth communication, and since location information needs to be collected during Bluetooth scanning, you are required to enable Bluetooth and apply for location to add a device; otherwise, the "Device Addition" function will not be available.
Additional scenarios:
- When you use our specific products or services (Weather Service / Home Management), we collect your real-time precise or imprecise geolocation information with your consent.
- When you use the geofencing function and generate location changes by creating scenes, we will apply to collect background location permission for the purpose of obtaining location to fulfill the automation capabilities you wish to achieve.
You may disable location services in the system settings of your mobile device to stop our collection of your location information.
1.1.4. Camera-Based Additional Services
You can pair the camera with intelligent devices by enabling the camera permission, so as to use the camera to scan QR codes, record videos, etc.
Please note that even if you have agreed to enable the camera permission, We only access the camera when you actively use it.
1.1.5. Additional Services Based on Album Access and Image/Video Uploads (Photo Library / Video Library)
After enabling the album permission, you can use this function to upload photos/pictures/videos to realize functions such as changing avatars and providing photo evidence to report device usage problems. When you use photos and other functions, we will not identify such information; We do not analyze images unless needed for troubleshooting.
1.1.6. Other Services Related to Microphone-Based Services
After enabling the microphone permission, you can use the microphone to send voice messages, such as shooting videos, waking up the voice assistant, etc. To realize these functions, we collect your voice information to identify your instructions. Please note that even if you have agreed to enable the microphone permission, we will only collect when actively used.
1.1.7. Additional Services Based on Storage Permission
We apply to you for this permission to ensure the stable operation of the client. After you enable our permission to read/write to your device storage, we will read or write necessary information such as pictures and files from/to your device storage space to provide you with the function of publishing information or recording information locally.
1.1.8. Additional Functions Based on Message Notification Permission
We apply to you for this permission to push notifications related to products or services to you.
1.1.9. Additional Services Based on Bluetooth Technology
You can use Bluetooth functions after enabling the Bluetooth permission, including device control, status retrieval, device discovery and device network configuration. In these functions, we communicate with terminal devices via Bluetooth. Please note that even if you have agreed to enable the Bluetooth permission, we will only use Bluetooth for communication in the following scenarios: Displaying device status on the home page and device panel; performing device control on the home page and device panel; and discovering devices and configuring device networks on the Home page and Add Device page.
1.1.10. Additional Functions Based on Permission to Bind to Notification Listener Service (Android system only)
We apply to you for this permission to synchronize App messages to your mobile intelligent device for display by monitoring App notification bar messages after the intelligent device is connected to the App.
You understand and agree that the above additional services require you to enable access permissions for your location information (geographic location), camera, album (photo library), microphone (voice), and internal/external storage on your device to realize the collection and use of information involved in these permissions. You can view the status of the above permissions item by item in your device settings and decide to enable or disable these permissions at your own discretion.
Please note that your enabling of any permission constitutes your authorization for us to collect and use relevant personal information to provide you with the corresponding service. Once you disable any permission, it means you have revoked the authorization, and we will no longer collect and use relevant personal information based on the corresponding permission, nor can we provide you with the service corresponding to that permission. However, your decision to disable a permission will not affect the information collection and use conducted based on your prior authorization.
1.2. Information We Automatically Collect
1.2.1. Mobile Device Information
When you interact with our products, to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize your service experience, and protect the security of your account, we automatically collect mobile device information, mobile device model, login IP address, wireless connection information, device identifier, mobile device location, Bluetooth data, operating system type and version, application version number, application usage data, push notification identifier, log files and mobile network information, etc.
At the same time, we collect your software version number. To ensure the security of the operating environment or as required to provide services, we collect the application installation list of the application program.
1.2.2. Usage Information
During your interaction with our website and services, we automatically collect usage information related to your access, clicks, downloads, sending/receiving messages and other uses of our website and services.
1.2.3. Log Information
When you use our application, system and exception logs are uploaded for analysis to enhance your user experience, including your IP address, language usage habits, operating system version, access date or time, device ID, APP version, etc., so that we can accurately identify problems and help you solve problems during service use.
1.3. Intelligent Devices Information
When you use intelligent devices, we collect inherent information of the intelligent devices themselves and information generated during your use of the intelligent devices.
1.3.1. Basic Information of Intelligent Devices
When you use intelligent devices connected to our products or services, we collect basic information about the intelligent devices, including the name of the intelligent device, device ID, online status, activation time, firmware version and upgrade information.
1.3.2. Information Collected During the Connection of Intelligent Devices
When using the Siterwell Link APP and services, to facilitate device identification/activation/control, conduct data statistics and analysis, and ensure the security and quality of network access and service operation, we receive and record device-related information you use based on your specific operations when using the product and the type of intelligent device you need to connect, such as Wi-Fi information, device ID, device Mac address, and device Bluetooth Mac address.
1.3.3. Information Collected During the Use of Intelligent Devices
For example, temperature, humidity, and device operation data (such as thermostat running time data and temperature set points of HVAC equipment, etc.); some products also collect other types of data such as motion sensors (i.e., "occupancy sensing"). Through machine learning technology, we analyze and process environmental sensor data, HVAC operation information and usage data, as well as occupancy sensing data, combining on-device and remote processing, to strive to minimize energy consumption when you are at home or away.
2. Purposes and Legal Bases for Processing Personal Information
2.1. Subject to compliance with applicable laws, we may use the collected personal data for the following purposes:
2.1.1. Create and manage your account information, mobile device information, usage information, location information and intelligent device-related information to provide the products and services you request;
2.1.2. Process your mobile device information, usage information, location information and intelligent device-related information to ensure the functionality and security of our products, develop and improve our products and services, analyze and improve our operational efficiency, and prevent and track fraud or improper use;
2.1.3. Process and fulfill claims and orders related to our products and services, and feedback the order status to you at any time;
2.1.4. Personalize your product and service experience;
2.1.5. Allow you to stream, save and share content through our services;
2.1.6. Identify and verify your identity so that you can access certain content or use certain of our services;
2.1.7. Enhance and maintain the security of our products and services and prevent abuse;
2.1.8. Communicate with you (including providing you with offers and other information about our products and services) and provide customer support;
2.1.9. Conduct analysis (including energy consumption, market and consumer research, trend analysis and financial analysis, etc.);
2.1.10. Operate, evaluate, develop, manage and improve our business (including operating, managing, analyzing and improving our products and services; developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing and collection activities and other internal functions);
2.1.11. Prevent, identify and stop fraudulent and other criminal activities, claims and other liabilities;
2.1.12. Comply with and implement applicable legal requirements, relevant industry standards and policies, including this Privacy Statement and our Terms of Service.
2.2. Legal Bases for Processing
We process your personal information only when required by law to disclose information, or when we deem it necessary or appropriate to do so:
2.2.1. Comply with applicable laws and regulations, legal procedures or requests from public institutions and government authorities;
2.2.2. Perform our Terms of Use and other agreements, policies or standards, including investigating any potential unauthorized use;
2.2.3. Protect the rights, privacy, security or property of us and/or other users including you; and seek available detection, prevention, remediation measures or limit the damages we may need to provide or resolve security, fraud or technical issues.
3. Information Sharing
Except as otherwise provided in this Privacy Statement, we do not sell or otherwise share your personal information. We may share your personal information with the following parties:
3.1.1. Our affiliated companies and subsidiaries;
3.1.2. Service providers who provide services on our behalf, such as marketing, customer service, order fulfillment, and data analysis and storage.
We do not authorize service providers to use or disclose your personal information except as necessary to provide services on our behalf or to comply with legal requirements.
We may also share personal information with our business partners:
3.1.3. Business partners with whom we jointly provide products and services;
3.1.4. When you connect to third-party products or services through the Siterwell Link App;
3.1.5. For payment processing and fraud prevention.
We may also disclose your personal information in the following circumstances:
3.1.6. Required to do so by law or legal process (such as a court order or subpoena);
3.1.7. To establish, exercise or defend our legal rights;
3.1.8. When we deem disclosure necessary or appropriate to prevent physical or other harm or economic loss;
3.1.9. In connection with the investigation of suspected or actual illegal activities;
3.1.10. Or with your consent.
We reserve the right to transfer any personal information we hold about you in the event of a sale or transfer of all or part of our business or assets (including merger, acquisition, joint venture, restructuring, divestiture, dissolution or liquidation).
4. Information Transfer
Siterwell Link App operates globally, so the personal information we collect in accordance with this Policy may be transmitted, stored and processed between different countries or regions. The laws and regulations applicable in the countries or regions where we operate may differ from those applicable in your country/region of residence, but we will strictly comply with the laws, regulations and requirements related to personal information protection. Therefore, under the framework of personal information protection, we may transfer personal information to the countries or regions where we operate to facilitate our operations. Regardless of where your information is stored, our privacy and security practices are designed to provide global protection for your personal information.
If you wish to learn more about our information storage and security measures, you may contact us directly through the contact information at the bottom of this Policy.
5. Consent to Electronic Communications
After registering the Siterwell Link App and creating an account, we may send you HVAC/Smoke/CO alerts and reminders, software update notifications, energy-saving suggestions, news about Siterwell-related products and services, customer feedback or surveys, and product information of our affiliated companies from time to time via the email or other communication methods used during registration.
You may refuse to receive alerts and reminders sent by email through the application settings of the Siterwell Link App, or opt out of receiving email communications by contacting us through the methods provided in the "Contact Information" section below.
6. Your Privacy Rights
Under applicable law, you may have the following rights in respect of the processing of your relevant personal data:
6.1.1. Request access to the personal information we process about you;
6.1.2. Request us to correct inaccurate or incomplete personal information about you;
6.1.3. Request the deletion of your personal information;
6.1.4. Request the temporary or permanent restriction of our processing of some or all of your personal information;
6.1.5. Request the transmission of personal information to yourself or a third party when we process your information based on your consent or a contract signed with you, and when we process your information automatically.
If you decide to send us a request by email, please state which information you wish to change, for example, whether you wish to have your personal information deleted from our database, or what restrictions you wish to place on our use of your personal information.
Please note that for security reasons, We may verify your identity before processing requests.
7. Information Security Protection Measures
We adopt administrative, technical and physical security measures to protect personal information from accidental, illegal or unauthorized destruction, loss, alteration, access, disclosure or use.
In the event of a security incident affecting the security of your personal information, we will notify you within 72 hours via the email address, phone number you have reserved, or push notification through the message center.
8. Data Retention
We will retain your information for no longer than the reasonable period necessary to provide you with services, comply with legal obligations, resolve disputes and enforce agreements. The criteria we use to determine the retention period include:
- The duration of our ongoing relationship with the customer
- Our legal obligations
- The necessity of retaining information to support our legal position (e.g., for applicable statute of limitations, litigation or regulatory investigations)
Personal information collected through security cameras or other products with camera functions:
When you enable the recording function of the intelligent device, we will record, store and process video and/or audio recordings from the intelligent device in accordance with your configuration of the intelligent device's camera and related settings. This may include intercepting part of the recording data and providing it to you (as part of a notification), or analyzing the data to identify motion or other events. We process and store personal information from your intelligent device to send you alerts in the event of an incident. We will retain video and audio recordings from your camera for a period matching the time from the date of the first recording. Within the corresponding period, you may choose to delete or download such recordings from your account timeline.
Note: Privacy laws in your state may impose specific obligations on you and your use of security cameras or other products with camera functions. You (and not Siterwell) are solely responsible for ensuring that your use of such products complies with all applicable laws. For example, even in private or indoor premises, you may be required to post notices (such as signs) informing visitors that audio and video recording is in progress. Please note that recording or sharing videos or audio containing others may involve the privacy rights of others. You should take appropriate measures to respe
9. Children's Privacy
This App is not intended for individuals under 18, and we will not collect personal information of such persons with knowledge.
If we discover that we have collected or received personal information of a child, we will delete such information.
If you believe that we may hold information of any person under the age of 18, please Contact us at : sales@china-siter.com
10. Energy Star Data Policy
In order to participate in the Energy Star smart thermostat program and help you optimize energy efficiency, we collect and process data related to your HVAC device performance.
- Data Collection for Energy Optimization: When you opt-in to Energy Star features, we collect operational data from your connected intelligent Devices, including temperature setpoints, heating/cooling run times, humidity levels, and occupancy status. This data is used solely to provide energy usage insights, optimize HVAC algorithms for energy savings, and fulfill certification requirements.
- Data Storage: We store energy-related performance data securely in our cloud infrastructure. We adhere to the principle of data minimization, retaining only the information necessary to provide energy optimization services or comply with legal requirements. When energy performance data is no longer required for these purposes, it will be deleted or anonymized.
- Data Sharing: We do not sell your personal energy usage data to third parties. We may share de-identified or aggregated energy performance data with authorized certification bodies or utility partners only when strictly necessary to manage energy programs you have voluntarily enrolled in or to maintain Energy Star compliance.
- User Control: Your participation in energy optimization programs is voluntary. You may opt-out of these features at any time through the Siterwell Link App settings, which will stop the collection and sharing of data for energy optimization purposes.
11. Other Third-Party Services and Functions
Our products or services may allow you to link to third-party products or services to provide specific functions or experiences. For example, you may be able to link your Intelligent devices or account to applications or services not provided by Siterwell.
Such third-party services and functions may operate independently of us. The details of the information they may collect about you are subject to the privacy statements of such third parties, and we strongly recommend that you review those statements. We are not responsible for the information practices of such third parties.
When you use services provided by third parties, we will share the corresponding information only after ensuring that the third party has obtained your authorized consent and in other circumstances that comply with the provisions of relevant laws and regulations. You can learn about what personal information third parties will collect about you and how such information will be processed through the relevant information listed in this list. We will also impose strict restrictions on third parties' acquisition of personal information to protect the security of your personal information.
You can click on the
List of Third-Party Information Sharing and SDK Services
; to view the details of third-party information sharing.
12. Statement on Policy Changes
This Privacy Statement may be updated from time to time to reflect changes in our personal information processing practices. We recommend that you check our services frequently for the latest changes. For changes to the Privacy Statement, we will indicate the last updated date at the top of the statement.
13. Contact Information
If you have any questions about this Policy and our privacy practices, please contact us through the following methods:
14. Supplementary Notice for Consumers in Specific U.S. States
This section of the Policy applies to consumers residing in U.S. states that have enacted comprehensive consumer data privacy laws.
14.1. Collection of Personal Information
In the section "Information We Collect and Methods of Collection" of this Policy, we have specified the types of personal information we have collected from consumers in the past 12 months prior to the last updated date of this Policy, including the following:
14.1.1. Identifiers – Such as email address, password, unique mobile device identifier, intelligent device ID, Internet Protocol (IP) address, location area code, mobile network and country code, home-related information or other similar identifiers;
14.1.2. Personal information as described in Section 1798.80(e) of the California Consumer Records Act – That is, any information that can identify, relate to, describe a specific individual or be associated with a specific individual, including but not limited to the above identifiers;
14.1.3. Commercial Information – Such as your purchase history, and information that may be included in your help requests, customer service communications, product ratings or reviews, and any feedback;
14.1.4. Internet/Network Information – Information about Internet or other electronic network activities, including but not limited to information about your interaction with this Application;
14.1.5. Geolocation Data – Geolocation data obtained through Internet Protocol (IP) address, location area code, country code and mobile network;
14.1.6. Audio, Visual and Similar Information – Including images, photos, audio and video recordings to enable us to provide the services of this Application;
14.1.7. Preferences – Inferences drawn from any information set forth in this Policy to create a profile reflecting your preferences based on your interaction with this Application;
14.1.8. Sensitive Personal Information – Such as account login information, as further described in the relevant categories above.
We collect such personal information when you use this Application. For more information, please refer to the section "Information We Collect" above.
14.2. Disclosure of Personal Information
During the twelve (12) months preceding the most recent update of this Policy, in accordance with the California Consumer Privacy Act (CCPA), we have not disclosed any personal information (including personal information of individuals under the age of 16, to the extent we have actual knowledge) to any business or third party in exchange for monetary or other valuable consideration (i.e., "sold" personal information), nor have we disclosed personal information for purposes of cross-context behavioral advertising (i.e., "shared" personal information).
In the past twelve (12) months, we may have disclosed personal information to our service providers for business purposes. The information we disclose for business purposes may include some or all of the above categories. For information about the categories of recipients to whom we have disclosed information and the purposes of disclosure, please refer to the section "Information Sharing" above.
14.3. Use of Personal Information
We use the personal information collected about consumers for the purposes disclosed in this Policy. For more information, please refer to the section "Purposes and Legal Bases for Processing Personal Information" above.
The business purposes for which we may use personal information about consumers include:
14.3.1. Audit-related activities – Including counting the number of ad impressions to unique visitors, verifying the location and quality of ad impressions, and auditing compliance with applicable laws and other applicable standards;
14.3.2. Helping to ensure security and integrity – To the extent that the use of consumers' personal information is reasonably necessary and proportionate for such purposes;
14.3.3. Debugging – To identify and fix errors in our systems;
14.3.4. Short-term, temporary use – Including displaying non-personalized advertisements during the consumer's current interaction with us;
14.3.5. Providing services on our behalf – Including account maintenance or services, customer service provision, transaction processing or fulfillment, identity verification, payment processing and other services;
14.3.6. Conducting internal research related to technological development and demonstration;
14.3.7. Conducting activities designed to verify, enhance and maintain the quality or security of the services or devices we may own, control or provide.
We may also use the collected information for other operational purposes of ourselves or our service providers, purposes we notify you of separately, purposes disclosed in other parts of this Policy, or purposes compatible with the context in which the personal information is collected.
We do not use personal information for profiling to assist in making decisions that have legal or similarly significant effects on consumers. Nor do we use sensitive personal information for any purposes other than those reasonably necessary to provide the services of this Application; detect, investigate and prevent claims, security incidents and fraud; protect or maintain our legal rights; and comply with applicable laws.
14.4. Your Privacy Rights
If you are a resident of a U.S. state that has enacted a comprehensive consumer data privacy law, subject to the exclusions, limitations and requirements of applicable law, you have the following rights in respect of your personal information. You may exercise such rights free of charge, unless permitted otherwise by applicable law. Such rights are as follows:
14.4.1. Right to Deletion – You have the right to request us to delete the personal information we have collected about you. Please note that if the service you request requires the use of your personal information, we may not be able to provide the service if you choose to delete such personal information.
14.4.2. Right to Access – You have the right to know whether we are processing personal information about you, and the content of the personal information we have collected about you, including:
- The categories of personal information we have collected about you
- The categories of sources from which personal information is collected
- The business or commercial purposes for which we collect, sell or share personal information
- The categories of third parties to whom we disclose personal information
- The specific content of the information we have collected about you
14.4.3. Right to Correction – You have the right to request us to correct inaccurate personal information we hold about you.
14.4.4. Right to Appeal – If we refuse to process your request to exercise the above privacy rights in accordance with the above provisions, you may appeal our decision to us. The response to your request for rights will inform you of any appeal rights you may have and how to exercise them.
14.5. How to Exercise Rights
You may request to exercise such rights through the following methods:
- Email: sales@china-siter.com
- Visit: Global Smart Home Security Solutions Provider-Siterwell to submit a request
- Phone: +86 574 83011392
As required or permitted by applicable law, please note that we may take steps to verify your identity before granting you access to information or taking action in response to your request. We may require you to provide your name, address and any other necessary information to respond to the above types of requests and verify your identity. To the extent permitted by applicable law, we may limit our response to your exercise of the above rights. We will not discriminate against you for exercising your above rights.
14.6. Agent Authorization
You may designate an authorized agent to exercise any of the above rights on your behalf. You may make such designation by providing the agent with a written authorization document. We will require the agent to provide proof of such written authorization document. To the extent permitted by law, even if you choose to make a request through an agent, we may still require you to verify your identity in person. Your agent may contact us on your behalf through the methods described in the section "Requests to Exercise Rights" above to submit a request.
By downloading, installing, registering, or using an account (the "Account"), you acknowledge that you have read, understood, and agreed to this Policy. If you do not agree, you should stop using the application.