Our Privacy Policy (the “Privacy Policy”) was updated on September 1, 2024, and becomes effective on September 1, 2024 (the “Effective Date”). Unless otherwise agreed, this Privacy Policy will govern how we manage the personal information you disclose while using Fidesinnova’s products and services (the “Product and Service”) from the Effective Date.

Please take some time to read the Privacy Policy. You may contact us at any time if you have any questions.

1.Our Promises

Protecting users’ personal information and privacy is a high priority for us. We are committed to enhancing transparency in information processing, giving you more control over your information, and ensuring the safety of your data.

We strictly comply with applicable laws and regulations and adopt the following privacy protection principles to provide you with more reliable and safer services:

• Safety and Reliability: We endeavor to prevent the leakage, damage, or loss of information through reasonable security technology and management processes.
• Self-Determined Options: We provide convenient information management options so that you can manage your personal information.
• Reasonable and Necessary Information Collection: We only collect the necessary information to improve the services we offer to you and other users.
• Clarity and Transparency: We use clear and explicit language to describe our Privacy Policy so that you can easily understand how we process information.
• Privacy Protection as Part of Product Design: In developing our products and services, we incorporate privacy protection into the design process, considering factors such as legal requirements and product design.

We fully consider your needs when developing the Privacy Policy. It’s important to us that you understand our practices for collecting and using personal information and that you can control all your personal information disclosed to Fidesinnova.

“Personal Information” refers to data directly or indirectly used to identify an individual through information related to them or in conjunction with other information related to them that Fidesinnova has access to. Personal Information includes, but is not limited to, device information and other data you have provided or uploaded.

Your use of the Product and Service signifies that you have read the latest version of the Privacy Policy and agree to all terms and conditions stated. To ensure compliance with laws, including local data protection laws (such as the European Union’s General Data Protection Regulation (“GDPR”)), we will seek your explicit approval before processing certain types of personal data (such as automated individual decision-making). We will also protect the privacy, confidentiality, and safety of your personal information according to applicable laws (including local data protection laws). Additionally, we will ensure our employees and agents comply with these legal obligations.

We aim to provide the best experience for our users. If you have any questions about our data processing practices, please send an email to the address provided. We will gladly respond to your inquiries and address your concerns.

If you have any questions or doubts about our Privacy Policy or practices, please send an email to us. If our responses do not satisfy you, please contact us using the information provided on our official website.

2.What Information Will Be Collected By Us? How Will We Use the Collected Information?

2.1. Types of Information Collected

We comply with applicable laws when collecting information and do not collect information without a valid reason. We only collect information necessary for providing services to you and only for explicit, clear, and lawful purposes related to the features of our Product. Information will not be processed for purposes or in manners inconsistent with these principles. We may collect the following types of information (whether personal information or not):

• Information You Provide or Upload: We may collect personal information you provide, such as names, mobile phone numbers, email addresses, account information (including safety-related details, names, dates of birth, and gender), materials or data synchronized across devices on the Fidesinnova platform, account configurations, devices added, and feedback provided.
• Log Information: We may automatically collect and store information related to your use of our services as logs.
• Device Information: Includes device model, operating system version, unique device identifier, battery status, signal strength, and IP address.
• Software Information: Includes software version number and browser type.
• Location Information: When using location-related services, we may record geographical details such as region, country codes, city codes, mobile network codes, longitude and latitude, time zone, and language settings.
• Geographical Location Information: May include information from your account or photos shared with others that contain geographical tags.
• Other Information Designated by Us: Information related to your Fidesinnova account and other details.
• Login Information: Includes features used, mobile applications, websites visited, cookies, anonymous identifiers, IP addresses, network requests, temporary message history, and system logs.
• Other Information: Includes environmental character values (such as values generated by Fidesinnova accounts, mobile phone IDs, connected Wi-Fi accounts, and location information).
• Account Certificate: Includes information about your account certificate, such as passwords, security questions, and answers.

We may also collect aggregated, anonymous, or unlabeled information that is not directly or indirectly related to any individual. For instance, we may collect device models and system version numbers of mobile phones using specific services to improve service quality.

3. How Will Personal Information Be Used?

Personal Information is collected to provide Products and/or services to you and to ensure compliance with applicable laws. You hereby consent to our processing of Personal Information and the disclosure of Personal Information to our affiliates (including those in telecommunications, social media, technology, and cloud services) and third-party service providers (defined below) for the purposes stated herein.

3.1.We may use Personal Information for the following purposes:

• Providing, Handling, and Improving Services: To provide, handle, maintain, improve, and develop the Product and/or Service offered to you, and to meet your individual needs.
• Communication: To communicate with you regarding your devices, services, or general inquiries (e.g., updates, device firmware/software upgrades, customer support, and notifications).
• Marketing Activities: To carry out marketing activities, such as sending information and updates for marketing and promotional purposes. For more details on our marketing activities, please refer to the section titled “Direct Marketing” below.
• Statistical Analysis: To analyze and develop statistics about the use of our Product and Service to improve them. For instance, we may record and analyze system breakdowns to optimize our services.
• Storing Information: To store and maintain your information for operational purposes or to fulfill statutory obligations.
• Local Services: To provide local services without the need to communicate with our servers.

3.2. Detailed Practices for Using Your Information (Including Personal Information):

• Account Creation: To create your “Fidesinnova” accounts using the Personal Information collected from our websites or mobile devices.
• Location-Based Services: To use location information for determining time zones, showing the correct time, and enabling certain features based on your choices. You may disable this feature in settings or by stopping use of the related application.
• Device Access: To verify the authenticity of devices and configure network settings via apps. Wi-Fi information and passwords provided will be encrypted and stored locally, not uploaded to servers. You can delete this information at any time. We also use IP and network signal information to select the best connectivity mode.
• Device Status Display: To allow you to check the status of your devices remotely.
• Automated Tasks: To create automation tasks based on incident information reported by your device. Privacy authorization will be required for related devices.
• Push Notifications: To provide push notifications, we may need your account number and IMEI number.
• Identity Verification: To use ECV for verifying users’ identities to prevent unauthorized access.
• Feedback Collection: To collect feedback that helps us improve our services. We may use your Personal Information to contact you for feedback and keep related records.
• Notices: To send emails, short messages, information, or push notifications. You can cancel related subscriptions by following our instructions.
• Service Notices: To send service-related notices (e.g., during system maintenance). You may not be able to cancel these notices if they are not of an advertising nature.

3.3.Direct Marketing

We may use your name, phone number, email address, account number, and IMEI number to send promotional materials about our partners’ products and services (e.g., network, mobile applications, and cloud services). We comply with local data protection laws and will only use your Personal Information with explicit approval. You can unsubscribe from marketing emails using the link provided. After unsubscribing, we will not send your Personal Information to our business partners for direct marketing.

3.4. Disclosure of Your Information

• No Sale of Personal Information: We will not sell your Personal Information to any third party.
• Sharing with Third Parties: We may share your Personal Information with third parties.
• Sharing with Third-Party Partners: We may share your Personal Information with third-party partners (e.g., service providers, contractors, agents, advertising partners) for external processing. For instance, a partner may be a communication service provider or a map service provider. We will ensure they follow our instructions, comply with the Privacy Policy, and implement necessary confidentiality and security measures.
• Purpose of Disclosure: To provide our services to you, achieve the goals stated in the section “How Will Personal Information Be Used,” perform duties and exercise rights under the User Agreement or Privacy Policy, and improve our services.
• Data Protection Measures: We will encrypt and anonymize information shared with third parties and take measures to ensure data safety.
• Business Changes: In the event of a merger, acquisition, or asset transfer, we will inform you and ensure that the new administrator of your Personal Information adheres to the Privacy Policy.
• Big Data Analysis: We may use collected information for big data analysis, such as creating city thermodynamic charts or industry insight reports, provided that such information is anonymized and does not include personally identifiable details.

3.5. Mandatory Legal Requirements

We may disclose your Personal Information without your approval if required by law.

3.6. Disclosure Without Approval

We may disclose summarized, anonymous information to third parties (e.g., advertisers) for commercial purposes or general trends about service use (e.g., the number of customers).

4. Security and Protection

4.1. Information Security

• Security Measures: We have implemented reasonable physical, electronic, and administrative measures to prevent loss, misuse, unauthorized disclosure, or access to information. These measures protect the information collected during your use of the “Fidesinnova” app.
• Data Storage: Your Personal Information will be stored on secure servers within controlled facilities. We classify data based on sensitivity and provide high-level security. Employees and third-party service providers with access to Personal Information are bound by confidentiality obligations.
• Risk Awareness: While we take measures to protect your Personal Information, internet use entails risks. We cannot fully guarantee the security or integrity of online transmissions.
• Data Breach Response: In the event of a data breach, we will activate contingency plans and inform you via push notification or notice.

4.2. Your Role in Protection

You should not disclose your login password or account information to anyone other than authorized individuals. Always log out after using your “Fidesinnova” account, especially on shared or public devices. Notify us immediately of any unauthorized use or security breaches.

4.3. Accessing Device Features

Our applications may access certain features of your devices (e.g., Wi-Fi network status) to operate effectively. You may revoke these permissions at any time by closing the application or contacting us.

4.4. Controlling Your Personal Information

• Control Settings: You can manage your Privacy Settings, such as enabling or disabling user experience programs and location access.
• Account Management: You may contact us to change your approval decisions regarding Personal Information use.
• Accessing and Modifying Information: You may request access to or modification of your Personal Information. We will verify your identity before processing such requests and respond within the timeframe required by data protection laws.
• Accuracy and Updates: If you believe any information we hold is inaccurate or incomplete, please contact us.
• EU Users (GDPR): EU users may request the deletion of Personal Information, limit processing, object to automated decisions, or request data portability. We will handle such requests in accordance with GDPR.
• Account Access: You can log in to your account to access and update detailed information.

4.5. Revoking Approvals

You may request the revocation of approvals for collecting, using, or disclosing Personal Information. We will handle your request promptly, but revoking certain approvals may impact our ability to provide services.

4.6. Moving Personal Information

• Compliance: We will comply with applicable laws when transferring Personal Information outside your jurisdiction and take appropriate security measures.
• International Transfers: We may transfer data to global subsidiaries or third-party service providers outside the EEA, ensuring compliance with data protection standards.
• EU Standards: We will adhere to the EU’s Standard Contractual Clauses or GDPR for transferring data outside the EEA.
• Data Processing and Storage: We may process or store Personal Information in facilities outside your jurisdiction, but we remain committed to protecting your information according to the Privacy Policy.
• Third-Party Services: Your use of third-party services may involve data transfers outside your jurisdiction. Your use indicates consent to such transfers.

4.7. Miscellaneous

We prioritize the protection of minors’ Personal Information. Minors under 18 must obtain parental or guardian approval before using our services. Guardians may contact us regarding the Personal Information of minors under their care.

5. Update of Privacy Policy

We will regularly review and update our Privacy Policy to reflect changes in our practices. Significant changes will be communicated to you by sending emails (to the addresses provided in your account information) or by issuing announcements on our apps or devices. We strive to ensure you are informed about the information we collect and how we use it. The updated Privacy Policy will become effective on the dates specified in the related notices or website rules. We recommend that you regularly review our webpage to stay informed about our latest privacy practices. Your continued use of our Product, website, mobile phone, or services on other devices will be considered acceptance of the updated Privacy Policy. We will seek your approval again before collecting more Personal Information or using or disclosing your Personal Information for new purposes.

6. Do You Have to Accept a Third Party’s Terms and Conditions?

Our Privacy Policy does not apply to products and services provided by third parties. The “Fidesinnova” Product and Services may include links to third-party products, services, or websites. Your information may be collected when you use these third-party products or services. We strongly recommend that you review the privacy policies of such third parties as you would our Privacy Policy. We are not responsible for any third party’s collection or use of your Personal Information and cannot control their use of your Personal Information. Our Privacy Policy does not apply to other websites linked to our Service.

7. Social Media Features and Gadgets

Our website may offer certain social media features, such as the “Share” button. These features may set cookies needed for normal operation and collect your IP address and information about the pages you have browsed on our website. Social media features and gadgets may be managed by third parties or directly on our website. Your interaction with these features is governed by the privacy policy of the company providing them.

8. Single Sign-On

You may use single sign-on services provided by third-party software to log in to our website, depending on your jurisdiction. This service will verify your identity and may ask if you want to share certain Personal Information (such as your name and email address) with us to pre-fill our registration forms. Other social media platforms may allow you to upload information about your activities on this website to your profile and share it with others.

9. About the Ways We Manage Your Personal Information

9.1. If you are an EU user governed by GDPR, we will:

• Manage personal data: We will manage personal data related to our employees, management processes, and information systems through appropriate risk control measures and systematic methods. According to GDPR, we may use the following methods:
• Appoint a Data Protection Officer (DPO): Responsible for data protection.
• Establish a Data Protection Impact Assessment (DPIA): And other processes.

9.2. Contact Us

If you have any suggestions or questions about the Privacy Policy or our collection, use, or disclosure of your Personal Information, please contact our DPO at info@fidesinnova.io.

Thank you for reading our Privacy Policy!