Privacy

Synaudio™'s promise
This Privacy Policy describes how Synaudio Technology Co., Ltd. and its affiliates (hereinafter referred to as "Synaudio", "we" or "us") collect, use, disclose, process, and protect the information you provide to us through the Synaudio™ app when using our products or services. If we ask you to provide certain information in order to verify your identity when using Synaudio™ products or services, we will use this information in strict accordance with this Privacy Policy and/or our User Terms and Conditions.

This Privacy Policy was developed with full consideration of your needs taken into account. It is important that you fully understand our personal data collection and usage practices as well as full confidence that ultimately, you have control of any personal information provided to Synaudio.

In this Privacy Policy, "personal information" means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information Synaudio has access about that individual. Such personal information may include but not limited to the information you provide to us or upload, device information.

By using Synaudio™ products and services or other acting permitted by the applicable, you have understood that the risk you are deemed to have read, acknowledged and accepted all the provisions stated herein this Privacy Policy, including any changes we make from time to time. In order to comply with applicable laws, including local data protection legislation (e.g. General Data Protection Regulation in Europe Union), we will specifically seek prior explicit consent to the particular processing (e.g. automated individual decision-making) of special categories of personal data. Furthermore, we are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.

If you have questions or concerns regarding our Privacy Policy or practices, please contact us at privacy@Synaudio.link.

Personal information: collection and usage
Synaudio™ collects specific types of information
In order to provide our services to you, we will ask you for personal information that is necessary for us to successfully provide those services. If you do not provide us with this personal information, we may not be able to provide our products or services to you.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of information (which may or may not be personal information):

• Information you provide to us or upload:

We may collect the personal information you provide to us, like your name, email address, Synaudio account information (e.g. your security-related information, name, birthday, gender), or data you may sync with the device you use to access the Synaudio™ portal, information used to create your account or related to your account setup on the Synaudio™ portal, devices you add or information that you send, and feedback.

• Information related to the handheld device terminal:

We may collect information related to the operation of the Synaudio™ handheld device terminal. For example, the version of your operating system, manufacturing information about your device, model name, and network operator. We may also collect information about the device associated with your account. For example, MAC address, DID, network status of the device (IP/network signal), and the version of your firmware.

• Information we designate that is about you:

We may collect and use content such as information related to your Synaudio account. For example, if you use an email address/phone number to register an account, we may collect the email address/phone number information as the login proof. Meanwhile, we will send a verification code to the email address/phone number to verify the authenticity of the register information.

• Location information:

Various types of information on your location (Only for specific services/functionalities). For example, region, country code, city code, district name, longitude and latitude information, time zone settings, language settings.

• Log information:

Information related to your use of certain functions, apps and websites. For example, cookies and other anonymous identifier technologies, IP address, network request information, temporary messaging history, standard system logs, and crash information.

• Other information:

Environmental characteristics value (ECV) (i.e. value generated from Synaudio Account ID, Synaudio & Deity device ID, and location value).

• Account credentials:

Information related to your account credentials. For example, password, password security questions and answers, etc.

We may also collect other types of anonymous information which are not directly or indirectly linked to an individual and which is aggregated, anonymized or de-identified. For example, the device model and system version number of the user's Synaudio & Deity device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you.

• Join User Experience Program：

Our products are integrated with Umeng+SDK. Umeng+SDK needs to collect your device MAC address and unique device identification code (IMEI/ Android ID/IDFA/ OpenUDID /GUID, SIM card IMSI information) to provide statistical analysis services and to calibrate the report data accuracy through geographical location to provide basic anti-cheating capabilities. This helps us improve our products and services. The user may opt to participate in or withdraw from the User Experience Improvement Plan at their own discretion through "Me > Settings > Privacy settings > User Experience Improvement Plan" in the Synaudio™ app. By enabling it, the user chooses to opt-in the Synaudio Link User Experience Improvement Plan; by disabling it, the user chooses to opt-out the User Experience Improvement Plan.

• Third-Party SDK Personal Information Collection Disclosure:

To assist us in improving stability and identifying potential bug issues, we have integrated third-party SDKs into our application.

SDK Name: Mobile Analytics SDK
Purpose of Use: Mobile Analytics and Analysis
Operated by: Umeng Tongxin (Beijing) Technology Co., Ltd.
Types of Personal Information Collected: Device Information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM Card IMSI/ICCID), Location Information, Network Information
Privacy Policy Link: https://www.umeng.com/page/policy
We will not share any personal information with any third parties outside of the scope of mobile analytics functionality, nor will we use this information for any purposes other than mobile analytics.

SDK Name: Application Performance Monitoring SDK
Purpose of Use: Performance Analysis
Operated by: Umeng Tongxin (Beijing) Technology Co., Ltd.
Types of Personal Information Collected: Device Information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM Card IMSI/ICCID), Location Information, Network Information
Privacy Policy Link: https://www.umeng.com/page/policy
We will not share any personal information with any third parties outside of the scope of software issue analysis functionality, nor will we use this information for any purposes other than analyzing software issues.

SDK Name in Use: Realsil SDK
Service Type: Bluetooth Firmware Upgrade
Types of Device Information Obtained: Bluetooth firmware version and device name

We will not share any device information with any other third parties beyond this, and we will not use this information for any purposes other than the functionality of upgrading the device's Bluetooth firmware.

How this personal information can be used
Personal information is collected for providing services and/or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies (which are in the communications, social media, technology and cloud businesses), Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

Synaudio™ may use personal information for certain purposes:
Providing, processing, maintaining, improving, and developing our goods and/or services to you, and services provided through your device or by Synaudio™.

Communication with you about your device, service, or any general queries, such as updates, device firmware/software updates, customer support, related information, and notices.

Conducting marketing related activities, such as providing marketing and promotional materials and updates. For more information on marketing and promotional activities, please refer to the Marketing and sales section below.

Analyzing and developing statistical on the use of our products and services to better improve our products and services.

Storing and maintaining about you for our business operations or legal obligations.

Providing local services without communicating with our servers.

Here are more details on how we use your information (which may include personal information): Setting up your Synaudio Account. Personal information collected when creating a Synaudio Account on our web sites or through our App on mobile devices is used for creating the personal Synaudio account and profile page for the user.

Providing location-based services. When using Synaudio™ and accessing Synaudio™ devices, we may use information about your location to determine the time zone of the device. This will ensure that the device accurately displays the correct time and login service area. It will also optimize user experience by providing services such as advance activation of the corresponding device at a time set by the user. You can turn off this feature at any time by going to device settings or by discontinuing your use of this application.

Accessing devices. The authenticity of devices that are operated through the app must be verified. We, therefore, need to confirm the legal identity of the device by consulting the factory MAC and DID information. We also need to analyze the device's IP and network signal in order to determine the optimal network connection method. This will ensure the stability of the device network.

Display of device status. This allows you to view the status of the device remotely that you can check at any time whether or not the device is running.

Setting up automated tasks. The event information reported by your device (this information comes from the device you have added. The specific information that can be set depends on the scope of your privacy authorization for the device. Every added device will provide the Privacy Policy terms for the provider of that device, which you may then choose to agree with) can be used to create your own, personalized automated tasks.

Verification of user identity. Synaudio™ uses EVC to verify user identities and ensure that hackers or other unverified persons are unable to log in.

Collecting user feedback. The feedback you choose to provide is extremely valuable, as it helps us improve the services provided by Synaudio™. In order to track your feedback, Synaudio™ may use the personal information you provide to contact you and to keep records.

Sending notifications. We may occasionally use your personal information to send important notifications, for example, notifications about the status of device malfunctions; your customized device push notifications (which depend on what additional equipment you have purchased); and changes to our terms, conditions, and policies.

Marketing and sales
We may use your name, email address, or Synaudio account to provide you relating to goods and services of Synaudio companies, and our business partners which offer network, mobile applications and cloud products and services. We will only so use your personal data after we obtain your prior explicit consent and involve a clear affirmative action we have obtained your consent or indication of no objection in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of our proposed use of your personal data for marketing and sales. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each communication. We will not transfer your personal data to our business partners for use by our business partners in marketing and sales.

Sharing of personal information
We do not sell any personal information to third parties.

We may disclose your personal information to third parties (as defined below) in order to provide products or services that you have requested.

We may disclose information to the third-party service providers and affiliates listed at the end of the section. In any of the various situations described at the end of the section, you can rest assured that Synaudio will only share the personal information in accordance with your consent. Your consent to Synaudio will engage sub-processors for the processing of your personal information. Please understand that if in any of the situations described below, Synaudio shares your information with a third-party service provider, Synaudio will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Synaudio will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your jurisdiction.

Third-party service supplier
In order to operate successfully and provide you with the full functionality of our products and services, We may disclose your personal information to other Synaudio affiliated companies (these may include communications, social media, technology, or cloud services) or our third-party service providers (our mailing centers, delivery services providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and promotional service providers, and agents representing Synaudio) affiliated companies and/or other third-parties. Such third-party service providers may process your personal information on Synaudio's behalf or for one or more of the purposes listed above. When using certain mobile applications on our devices, we may share your IP address with third parties in order to provide you with some of the services you requested. If you would no longer wish to allow us to share this information, please contact us by sending an email to privacy@Synaudio.link.

Cooperation partner
Synaudio works with a group of very forward-thinking companies. Together, they form the Synaudio ecosystem. Synaudio may disclose your personal information to Synaudio ecosystem companies in order to provide you with and make improvements to a range of exciting products and services (including software and hardware). Some of these products and services will be under the Synaudio, Deity, Synaudio™ brand, while other products may use their own brand. Synaudio ecosystem companies may share data with Synaudio related to Synaudio, Deity, Synaudio™ brand products and services in order to provide software and hardware services, create better functionality and provide a better user experience. Synaudio will take appropriate organizational and technical measures to ensure the security of personal data during the process of sharing information, including but not limited to encryption of your personal data. If Synaudio is involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any change to the ownership of, use of, or any of the choices you have regarding your personal information by email and/or by posting a notice on our website.

Other
Synaudio may disclose your personal information to others without further consent when required under applicable law.

Information shared without consent
We may share anonymized information in aggregate form with third parties (such as advertisers on our website) for commercial purposes. We may share trends in the common usage of our services, for example, the number of customers in a particular group who purchase certain products or engage in certain transactions.

For the avoidance of doubt, Synaudio may collect, use, or disclose your personal information without your consent if it is and only to the extent it is allowed explicitly under local data protection laws (to, for example, comply with a subpoena). We may also disclose your information without your consent if we believe in good faith that it must be disclosed in order to protect our rights, your safety, or the safety of others; investigate fraud; or respond to government requests.

Data security commitment
Synaudio™'s security measures
We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure, or other similar risks, we have put in place reasonable physical, electronic, and managerial procedures to protect the information We collect from you during your use of the Synaudio™ app. We will take all appropriate measures to protect your personal information.

For example, when you access your Synaudio account, you can choose to use our two-step verification program for better security. When you send information to our home server from your Synaudio™ device or receive information through the same channel, we make sure that it is encrypted using a number of protocols including Secure Sockets Layer (SSL).

All of your personal information is stored on secure servers and protected in controlled facilities. We classify your data based on importance and sensitivity, and we guarantee that your personal information is always protected by the highest level of security. We also guarantee that employees and third-party service providers who provide products and services to you by accessing this information will be held under strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. Similarly, we have special access control measures for cloud-based data storage. In summary, we regularly review our information collection, storage, and processing practices, including physical security measures taken in order to prevent any unauthorized access and use.

We will take all practicable steps to protect your personal information. You should, however, be aware that the use of the Internet is not entirely secure, and for this reason. Because of this, we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

We will take upon the personal data breach, notifying the breach to the relevant supervisory authority or under some circumstances, notifying the personal data breach to the data subjects by complying with applicable laws, including your local data protection legislation.

Your rights
• You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you when you log into Synaudio™ as a Synaudio account user, no matter when, and especially if you are using another person's computer or a public Internet portal, you should always log out at the end of the session.

• Synaudio cannot be held responsible for lapses in security caused by third-party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must immediately notify us if any online users access your account without permission or if any other security breaches occur.

Your assistance will help us better protect your personal information.

Data preservation strategies
We retain the information we collect about you as long as it is still needed for the purposes we obtained it or as long as it is needed to comply with applicable legal requirements or permissions. We shall cease to retain personal information or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by Synaudio even if the further processing is incompatible with original purposes.

Access features on your device
Our application may need to access certain features on your device.

• Wi-Fi network status. If users need to upload or download data to the Cloud, we need to verify the current Wi-Fi network status;

• Camera access. Users could shot a photo via camera and use this photo to personalize their profile picture.

• Bluetooth access. Users could connect the fixtures and control them wirelessly;

• Local file access. Users could upload a photo via camera and use this photo to personalize their profile picture.

This information is necessary for these applications to run on your device and for you to be able to interact with them. You can close the application on your device at any time, or you can contact us at privacy@Synaudio.link to revoke your consent.

You have control over your personal information
Control settings
Synaudio knows that everyone has different concerns about privacy. Therefore, we have provided some examples of the various ways in which Synaudio allows you to restrict the collection, use, disclosure, and processing of your personal information, in addition to ways in which you can control your privacy settings:

• Turn on or turn off location access features.

• Log into or log out of your Synaudio account.

• If you previously agreed to let us use your personal information for the purposes described above, you can change your decision at any time by writing us a letter or sending an email to privacy@Synaudio.link.

Access, update, correct, erase or restrict processing of your personal information
• You have the right to request access to and/or to correct any personal information we hold about you. When you update your personal information, you will be asked to verify your identity before your request is processed. Once we have a sufficient amount of information, we will be able to process your request to either access or make corrections to personal information. We will respond to your request within the time period specified by applicable data protection law.

• A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.

• If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the email address below. Email: privacy@Synaudio.link.

• If you are a European Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.

• If you are a European Union user under GDPR, you have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.

• If you are a European Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

• If you are a European Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

• More details about the personal information in your Synaudio account can be accessed or changed by using your device to log into your account.

Withdrawal of consent
• You can submit a request by sending an email to privacy@Synaudio.link, in which you can request to withdraw your consent for us to collect, use and/or disclose any of your personal information that we hold or control. We will process your submission within a reasonable amount time, after which, we will abide by your request and no longer collect, use, and/or disclose your personal information.

• Please recognize that your withdrawal of consent may result in some legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy Synaudio products or services.

Transfer of personal information outside of your jurisdiction
To the extent that we need to transfer personal information outside your jurisdiction, whether it is transferred to our affiliates (these may include communications, social media, technology, or cloud services) or to third-party service providers, we shall do so in accordance with the applicable laws. In particular, in order to ensure that all such transfers comply with applicable local data protection law, we will implement appropriate security safeguards. You will have the right to be informed of the appropriate safeguards taken by Synaudio for this transfer of your personal information.

Synaudio is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal data to any subsidiary of the Synaudio group worldwide when processing that information for the purposes described in this Privacy Policy. We may also transfer your personal data to our third-party service providers, who may be located in a country or area outside the area of the European Economic Area (EEA).

Whenever Synaudio shares personal data originating in the EEA with a third party which may or may not be a Synaudio entity outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.

Synaudio may use overseas facilities operated and controlled by Synaudio to process or back up your personal information. Synaudio currently has data centers in Shenzhen and the United States. These overseas jurisdictions may or may not have data protection laws similar to the data protection laws in your jurisdiction. You have understood that the risks under applicable data protection laws are different and we may transfer and store your personal information in one of our overseas facilities; however, this does not change our full commitment to protecting your personal information in compliance with this Privacy Policy.

If you choose to use other third-party services available for this product or service (such as Amazon Alexa, Google Assistant, etc.), those third parties may be able to read information about you, information about you may also be transferred to a third-party server outside of your jurisdiction, and you agree to this kind of transfer.

Delete Account
Synaudio™ account is unrecoverable upon successful deletion so please apply for deletion after making sure you've taken everything into consideration. If you have opened automatic renewal services, disable such function before deleting the account.

Upon account deletion, your personal data and information will be cleared or processed anonymously, your rest available days of paid version will be cleared and can be no longer used, and your subscribed information will be cleared, too. The personal data or information in the successfully deleted Synaudio™ account cannot be recovered any longer, even if you log in Synaudio™ with the same account again.

We'll delete your personal information to avoid retrieval and visit or process it anonymously after successful deletion. You've known and acknowledged that, according to relevant laws and regulations or consensus that we have made, we will retain your relevant personal information within the shortest time required for satisfying legal provisions or purpose as mutually agreed by us.

Miscellaneous
Minors
• We believe that it is the responsibility of parents to monitor their children when using our products and services. Our policy, however, does not require us to obtain the personal information of minors or to send any promotional materials to these kinds of people.

• Synaudio will not seek or attempt to seek out any way to obtain personal information from a minor. If parents or guardians have reason to believe that a minor has provided personal information to Synaudio without their prior consent, they should contact us to ensure that such personal information is removed and that subscriptions the minor may have for any applicable Synaudio services are cancelled.

Order of priority
If you agree to an applicable user agreement, and if there is any inconsistency between the user agreement and this Privacy Policy, the user agreement will prevail.

Privacy Policy updates
We periodically review our Privacy Policy, and we may update it to reflect changes in our information practices. If we make a substantial change to this Privacy Policy, we will notify you by email (using the email address specified in your account), by releasing a notice in the Synaudio app, or by contacting you via your mobile device. This will allow you to understand what information we collect and how we use it. These kinds of changes to this Privacy Policy will be effective starting on the date specified in the notice or on the website. We recommend that you visit this page regularly for the latest information on our privacy practices. Your continued use of products and of website, cell phone and/or any other device-based services will be deemed as your acceptance of the updated Privacy Policy. If we collect additional personal information from you, or if we wish to use or reveal your personal information for a new purpose, we will once again seek your consent.

Do I have to agree to all terms and conditions of third parties?
Our Privacy Policy does not apply to products and services provided by third parties. Synaudio products and services may include third-party products and services, as well as links to third-party websites. When you use these products or services, they may also collect your information. Because of this, we strongly urge you to spend time reading the privacy policies of these third parties, just as you have read ours. We do not take any responsibility for the way in which third parties use the personal information they collect from you, nor do we have any control over how they use it. Our Privacy Policy does not apply to other websites whose links can be accessed through our services.

When you use these extension services for specific products on the Synaudio portal, the terms of the third party and the Privacy Policy of the third party both apply and you are considered to have agreed to the terms of each of these extensions.

Social media (features) and gadgets
Our website contains some social media features, including a "Like" button and widgets like "Share" buttons. These features may record your IP address and the pages that you have browsed on our site. They may also set cookies that enable functionality and operation. Social media features and widgets are either hosted by third-parties or hosted directly on our website. Any interaction that you have with these features is subject to the individual company's Privacy Policy.

Contact us
If you have any questions or feedback regarding this Privacy Policy, or if you have any questions regarding Synaudio's collection, use, or disclosure of your personal information, please contact our Data Protection Officer at the address listed below and mention that your message is in reference to the "Privacy Policy":

Synaudio Technology Co., Ltd.

23rd Floor, Zone C, 2330-5, Huitong Third Road, Hengqin New Area, Zhuhai City, Guangdong Province, China.

Email: privacy@synaudio.org

Thank you for taking the time to familiarize yourself with our Privacy Policy!