Privacy Policy

Updated date: July 10th, 2024

Effective date: July 10th, 2024

Aqara LLC and its affiliated companies (including but not limited to Lumi United Technology Co., Ltd., Shenzhen Aqara Software Service Co.,Ltd., hereinafter referred to as “Aqara Store”,“Aqara”,“we”,“us” or “our”), are committed to protecting and preserving your privacy.

This Privacy Policy explains how we collect, use, and disclose your information through our websites, mobile applications, customer support and other services (collectively referred to as “Services”), and applies to all Services except for those that are specifically covered by a separate Privacy Policy. The separate Privacy Policy will supersede this Privacy Policy and anything that is not specifically covered in that Privacy Policy shall be subject to the terms of this Privacy Policy.

By using our Services, you agree to the terms of this Privacy Policy, and you consent to the use of the information that you provide to us as set forth in this Privacy Policy. We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will let you know of such changes by posting a notice on our website. Your continued use of the website will be considered your agreement that your information may be used per the new policy. If you do not agree with the changes, then you should stop using the website, and you should let us know that you do not want your information used per the changes.

In this Privacy Policy, "personal data" means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

WHAT INFORMATION IS COLLECTED BY US AND HOW DO WE USE IT

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.In operating our website, we may collect a variety of information, including:

Information We Collect

Aqara Account Information.

Your Aqara account and related account details, including your country of residency, contact telephone number, email address, username, passwords, social media account and third-party avatar. If you are an installer, we additionally collect your name, company name and address.

Device Information.

Details of your visits to our website or use of our mobile applications and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, the date and time you accessed or left the website and which pages you viewed, Wi-Fi List Information, Mac address, CPU information, memory information, SD card information and operating system version. Some parts of our website use cookies and other technologies to collect this information about your general internet usage. See section below “How We Use Cookies” to learn more. We may also collect data in relation to your IoT devices, including device serial number, location of the device, device log, usage history and device status.

Contact Information.

We may need your contact information such as your name, email address, shipping address and telephone number when you place an order or contact us for customer service.

Photo and Video.

We may need to upload your personal photos and videos when dealing with certain issues and modifying personal information.

Location information.

We may need your location information for installing, activating and managing your Aqara devices, Bluetooth connection, region,country code,city code,mobile network code,mobile country code,time zone setting, and obtain your latitude, longitude and altitude information for data analysis to provide better marketing promotion services.We do not use or collect your precise geographic location unless your separate consent is sought.

Other Information You Provide to Us.

Details such as the time, topic and content of your communications with Aqara.

You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to requests you may have.

How We Collect Your Information

Here are the ways that we collect your information:

Directly Collected from You

We may collect the following personal information that you provide to us directly, including your name, birthday, contact telephone number, email address, shipping address, passwords, social media account, location of your devices, your location information, your photos and videos.

Automatically Collected

We may collect your devices’ information automatically within the necessary scope, including location information of the device, Wi-Fi List Information, Mac address, CPU information, memory information, SD card information and operating system version. See section below, “How We Use Cookies” for more information.

From the Third-Party Sources

We collect and use information obtained from Facebook, Google, and other social media accounts you use to login to the Services (“Third-Party Accounts”), such as your name, your username, avatar, social media account and other details you may have on your Third-Party Account profile. We do not have access to your Third-Party Account passwords.

You can also choose to change the scope of consent or withdraw your authorization at any time. After the authorization is withdrawn, we will no longer collect personal information related to these permissions, however, we will not be able to continue to provide you with corresponding Services.

Please note that your decision to withdraw consent or authorization will not affect our previous collection and use of personal information based on your authorization. When we want to use the information collected prior to your withdrawal of your consent or authorization for purposes not specified in this Privacy Policy, we will ask for your prior consent, as required by applicable law(s).

By giving a telephone number\Email to Aqara, you agree that a representative of Aqara can contact you at the number\Email you provide, potentially using automated technology (including texts/SMS messaging) or a pre-recorded message. Your consent is not an obligation to receive any of our products and/or services.

How We Use Your Information

Aqara uses personal data to power our Services, process your transactions, communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent or as otherwise permitted or required by law.

Aqara may use your personal data for the following reasons:

Performance of a contract: Much of our processing of personal data is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal data on this basis to allow you to use our Services
Consent: Where required by law, and in some other cases, we handle personal data on the basis of your implied or express consent.
Legitimate interests: In many cases, we handle personal data on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. These legitimate interests include, but not limited to, operating our business and services; providing security for our websites, products, software, or applications; marketing; receiving payments; preventing fraud; and knowing the customer to whom we are providing services.
Legal compliance: We need to use and disclose personal data in certain ways to comply with our legal obligations (such as our obligation to share data with tax authorities), as required or permitted by law.

Aqara may use your personal data for the following purposes:

Provide Our Services

We use your information to fulfil our agreements with you and provide you with our Services. We process your personal data as necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract, including but not limited to:

Account registration and management;
Processing orders and payments, as well as enabling shipping and delivery services for goods;
On-site installation and maintenance services for home energy storage products;
Sending emails, text messages, push notifications and in-app messages to market or advertise Aqara products, services, promotions, sweepstakes and events;
Answering requests for customer or technical support; and
Communicating with you about your account, activities on our Services, and policy changes.

Administrative Purposes

We use your information for various administrative purposes, including but not limited to:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions and other compliance activities;
Sharing information with third parties as needed to provide the Services;
Enforcing our agreements and policies;
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Services and users is among the assets transferred.
Complying with our legal obligations.

Other Purposes

Consent.

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent, as required by law.

Automated Decision-Making.

We may engage in automated decision-making, including profiling. Aqara’s processing of your personal information will not result in a decision based solely on automated processing that significantly affects you unless such a decision is necessary as part of a contract we have with you, we have your consent, or we are permitted by law to engage in such automated decision-making. If you have questions about our automated decision making, you may contact us as set forth in “Contact Us” below.

De-identified and Aggregated Information.

We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

Legal Obligations.

We may process your personal information to comply with our legal obligation in certain circumstances including but not limited to:

To law enforcement authorities, government or public agencies or officials, regulators, and/or any other person or entity with appropriate legal authority or justification for receipt of such information, if required or permitted to do so by law or legal process;

When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity;

When the information is required for the prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, or for the enforcement of civil law claims.

How We Store Your Information

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, information technology, and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by Aqara for this transfer of your personal information

Aqara may use overseas facilities operated and controlled by Aqara to process or back up your personal information. Currently, Aqara has data centers in China, United States, Singapore, Korea, Russia and Germany. If you are Europe Union user under GDPR, your personal information will be stored in the German server. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. We may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as permitted or required by law.

Marketing Emails and Alerts

You may opt-out of receiving marketing communications from Aqara at any time by clicking the “unsubscribe” link at the bottom of an email or following other specific instructions in the marketing communication. Once you opt out, you will no longer benotified of Aqara products, services, promotions and events until you subscribe again. You may still see Aqara ads on other platforms, but such ads are not displayed on the basis of your personal information collected by Aqara.

How We Disclose, Share and Transfer Your Information

Sharing of Your Information

We may share your personal data in the following cases:

Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
Fulfilling legal obligations: We may share your personal information externally in accordance with laws and regulations or the mandatory requirements of government authorities.
Disclosures to Protect Us or Others: We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; protect your, our, or other individuals rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
Disclosure in the Event of Merger, Sale, or Other Asset Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Sharing with our affiliates: Where permitted by law, we may share your information with our affiliates in order to provide you with Aqara Services. We will only share necessary personal information and subject to the purposes stated in this Privacy Policy. If the affiliated company wants to change the purpose of processing personal information, it will ask for your authorization again, as required by applicable law.
Sharing with authorized partners: Some of our Services will be provided by authorized partners only for the purposes stated in this policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and only share personal information necessary to provide services. Our partners are not authorized to use the shared personal information for any other purpose. Usually, our partners are:

Third-party service providers: Provide us with payment facilitation, package shipping, application development, electronic message processing and other services. Some of your personal information may be collected directly by third-party service providers and is subject to their privacy policies.
Advertising providers: We partner with third-party advertisers to assist us in business marketing, which includes using cookies and other technologies to deliver personalized advertising on third-party websites.

Transfer of Your Information

We may transfer your personal information to another company, organization or individual where we obtain your express consent, as required by law, or as otherwise permitted or required by law, or when a merger, acquisition or bankruptcy liquidation is involved, and if the transfer of personal information is involved, we will require a new holder of your companies and organizations with personal information continue to be bound by this Privacy Policy, otherwise we will require the company and organization to seek your authorization and consent again, as required by applicable law.

International Data Transfers.

We may transfer to, process, and store the data we collect about you in countries other than the country in which the data was originally collected, including the China, United States, Singapore, Russia and Germany or other destinations. Those countries may not have the same data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in the Privacy Policy and comply with applicable legal requirements providing adequate protection for the international data transfer, including the Standard Contractual Clauses (“SCC”) approved by the European Union Commission.

Your Rights Related to Your Personal Data

If you are a resident of certain states and/or jurisdictions, you may have certain rights under applicable data privacy regulations including the rights to:

Request access to your personal data

You may have the right to obtain a copy of the personal data we hold about you and certain information relating to our processing of your personal data.

Request correction of your personal data

You may have the right to have your personal data corrected if it is inaccurate or incomplete. You can update your personal data at any time by logging into your account and updating your details directly, or by emailing us at privacy@Lumiunited.com.

Request to delete your personal data

You may request that Aqara delete your personal data. Note, however, that we may not always be able to comply with your deletion request for specific legal reasons of which you will be notified of, if applicable, at the time of your request.

Request restriction on certain processing of your personal data

You may request to restrict the processing of your personal data in certain scenarios.. Where the processing is restricted, we are allowed to retain sufficient information about you to ensure that the restriction is respected in the future.

Request the transfer of your personal data

You may request a digital copy of your personal data or request the transfer of your personal data to another company. Please note though that this right only applies to automated data which you initially provided consent for us to use or where we used the data to perform a contract with you.

Object to processing of your personal data for targeted advertising

You may opt-out of our processing of your personal data for purposes of targeted advertising.

Withdraw your consent

You may withdraw your prior consent for the use of your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the services. Please note any use or disclosure of your personal data prior to your revocation of consent will not be subject to such withdrawal.

Request human intervention for automated decision-making and profiling/opt-out of use of your data for automated decision-making and profiling

You may request human intervention where we are carrying out automated decision-making or profiling when processing your personal data. This form of processing is permitted where it is necessary as part of our contract with you, provided that appropriate safeguards are in place, or your consent has been obtained, as required by law. You may also opt-out of such automated decision-making and profiling by notifying us at the email address below under “Contact Us.”

We will try to respond to all legitimate, validated requests within one month or as otherwise required by law. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may need to request specific information from you to help us confirm your identity in accordance with applicable law. This is a security measure to protect against personal data being disclosed to an unauthorized person.

Right to lodge a complaint

If you have any concerns or complaints regarding the way in which we process your data, please email us directly at privacy@Lumiunited.com. You also have the right to make a complaint to the data protection regulator in the United States (in accordance with the laws that apply to you as a resident of a particular state) or European Union data protection authorities or any other competent authority. Please do contact us first if possible so that we can assist you in the most efficient manner.

If you wish to exercise any of these rights, please email us at privacy@Lumiunited.com.

How We Use Cookies

Cookies are small text files that are sent to or accessed from your web browser or your device’s hard drive. Cookies typically contain the name of the domain (internet location) from which the cookies originated, the “lifetime” of the cookies (i.e., when it expires) and a randomly generated unique number or similar identifier. Cookies also may contain information about your device, such as user settings, browsing history, and activities conducted while using the Services.

Our Services use the following cookies:

Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to use your Account. These cookies cannot be turned off.

Analytical/performance cookies, which allow Aqara to recognize and count the number of visitors, learn how visitors navigate the Services, and improve the Services.

Functionality cookies, which Aqara uses to recognize you when you return to the Services.

Additionally, our website also works with third-party products or services (“Service Providers”) to offer and present our Services to you. These Service Providers may include Google, Facebook, etc. and other Service Providers who help us track and analyze our website user activity, measure the effectiveness of our advertising and fundraising efforts, and support the optimization of our digital campaigns.

Our Service Providers may get more information about your activity on our website, including pages you visit, access times, visit duration, how you arrived at our websites and your IP address. An IP address is a number that identifies a device connected to the internet. For most devices, the IP address changes on at least a weekly basis. Our Service Providers may also get device identifiers and specific information about the browser you use. In some cases, this information may be unique to you.

Additionally, our website uses pixels which are HTML code snippets that are loaded when a user visits a website or opens an email. It is useful for tracking user behavior and activity. With a tracking pixel, advertisers can get data for online marketing, web analysis or email marketing. If such data is analyzed in a particular way, the data collected through these pixels can be used for other purposes as well, for example retargeting/behavioral advertising.

If you’d like to disable these tracking pixels, there are a number of ways in which you can prevent your data from being collected by tracking pixels:

Set browser and email settings to be as restrictive as possible such that external graphics are only supported after permission, and HTML emails are not supported. Appropriate firewall settings can also do this.
Some browser extensions can be used to make tracking pixels visible (e.g. PixelBlock, uBlock Origin, HTTPS Everywhere, etc.).
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational webpage here https://thenai.org/about-online-advertising/how-does-it-work/.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Most internet browsers accept cookies by default, but you can change your browser preferences to block or restrict cookies if you do not want your web browsing activity tracked. Please note that some cookies are necessary for our website to run and, as such, cannot be declined. However, such cookies do not collect any personal information. If you choose, you may use the Digital Advertising Alliance (DAA) WebChoices Tool to globally opt out of third-party tracking via website cookies.

There are also a variety of other tools publicly available to manage cookies and similar technologies that collect information related to your use of our website. To learn more about cookies and modifying your browser settings related to these cookies you can review guidance from the FTC.

We are not responsible for the effectiveness or compliance of third-party opt-out mechanisms or programs. Please note that if you remove your cookies or upgrade your browser after having opted out, you will need to opt out again. Your opt out is specific to the browser you are using and the device you use to access the website. Therefore, if you use multiple browsers or devices you will need to opt out on each browser or device. You can access the information on our website without enabling cookies in your browser, but disabling cookies may result in a diminished ability to take advantage of the services and related informational content on our website.

Security of Your Information

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic, and managerial procedures to safeguard and secure the information we collect from your use of Aqara products and services and on Aqara Storewebsites. We will use all reasonable efforts to safeguard your personal information.

For example, when you access your Aqara Account, you can choose to use authorization code verification process for better security. When you send or receive data from your Aqara device to our servers, we make sure they are encrypted using Secure Sockets Layer ("SSL") and other algorithms.

We ensure that the personal data, which we store on the local server, will not be directly transmitted back to mainland China without data desensitization to protect the security of the user's personal data.

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level.

We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations, and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage, and processing practices, including physical security measures, to guard against any unauthorized access and use.

By using our products and services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the site or through the product or service and/or by sending an e-mail to you. You may have a legal right to receive this notice in writing.

To secure your information, we have put in place commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect through our Services. Nonetheless, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically via our Services, and transmission of such data is therefore entirely at your own risk.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services.

Children’s Information, Users Only of Age of Majority

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Aqara’s Services are not designed for children and we do not knowingly collect any personal information from children under the age of 16 in the European Union, or under age 14 in the United States (or other age as required by local law). If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

By using our Site, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age. Parents or legal guardians of children under 18 cannot agree to these terms on their behalf.

If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.

California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) was amended by the California Privacy Rights Act of 2020 (“CPRA”) (collectively “the CCPA”) which took effect on January 1, 2023. As required by laws, covered businesses are required to comply with all express statutory requirements including those CCPA regulations currently in effect. Please note that any terms defined in the CCPA shall have the same meaning in this Section.

This section of our Privacy Policy only applies to our processing of personal information that is subject to the CCPA. The CCPA provides California residents with the right to know what categories of personal information Aqara collects and whether Aqara disclosed that personal information for a business purpose (e.g., to a service provider). See below for additional details:

Category of Personal Information Collected by Aqara	Category of Third-Party Information is Disclosed to for a Business Purpose
Identifiers.	Service providers Advertising networks Government entities
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Internet or other electronic network activity	Service providers Advertising networks Government entities
Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Service providers Advertising networks Advertising networks
A name, signature, physical characteristics or description, address, telephone number, education, employment, employment history, bank account number or other financial information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
Geolocation data	Service providers Advertising networks Government entities
Physical location or movements.

If you are a resident of California, you have the following rights under the CCPA:

to know what categories of personal information we have collected and used, including how the personal information was collected;
to know what categories of personal information are being sold or disclosed and if it is being sold or disclosed to third parties and a list of categories of information that are sold; or, if applicable: to know that your personal information has not been sold;
to opt out of the sale of your personal information;
to access your personal information, including the right to download or transfer personal information collected;
to ask that your personal information be corrected.
to ask that we limit our use of your sensitive personal information.
to ask that your personal information be deleted;
to ask that we not use your personal information for cross-context behavioral advertising;
to equal service and equal price for goods or services even if you exercise your rights under the CCPA.

We will not discriminate against you for exercising any of your CCPA rights. Unless allowed by the CCPA, we will not

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at privacy@Lumiunited.com.

For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and supply your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response.

If you are a California resident, you may request to opt-out of the sale of, or sharing of for cross-context behavioral advertising.

Additionally, if you reside in California and have provided personal information to us, you may request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes under California’s Shine the Light law. Such requests must be submitted to us at privacy@Lumiunited.com.

Privacy Policies of Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

European Union Residents

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
the right to request access to, or copies of, your Relevant Personal Data, together with additional information, such as information regarding the nature, Processing and disclosure of those Relevant Personal Data;
the right to request rectification of any inaccuracies or incompleteness in your Relevant Personal Data;
the right to request, on legitimate grounds:

erasure of your Relevant Personal Data without undue delay; or
restriction of Processing of your Relevant Personal Data (limiting the purposes for which we Process your Personal Data);;

the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
the right to request the deletion or removal of your Relevant Personal Data where there is no other legal basis for us to keep using it. Please note that we may not be able to immediately remove the information from the backup system due to applicable laws and regulations or technological limitations. If this is the case, we will isolate your Relevant Personal Data from further processing until the backup can be deleted or be anonymized / deidentified .
where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases).

Under the GDPR , you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

Right of access

As a data subject, you have a right to obtain access and information under the conditions provided in Article 15 of the GDPR.

This means in particular that you have the right to obtain confirmation from us as to whether we are processing your personal data. If so, you also have the right to obtain access to the personal data and the information listed in Article 15 paragraph 1 of the GDPR. This includes information regarding the purposes of the processing, the categories of personal data that are being processed and the recipients or categories of recipients to whom the personal data have been or will be disclosed (Article 15 paragraph 1 points (a), (b) and (c) of the GDPR).

You can find the full extent of your right to access and information in Article 15 of the GDPR, which can be accessed using the following link:

http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

Note: You can access your account information and some device-related information yourself in the App. For any further access requests, please contact us at

privacy@lumiunited.com.

Right to rectification

As a data subject, you have the right to rectification under the conditions provided in Article 16 of the GDPR.

This means in particular that you have the right to receive from us without undue delay the rectification of inaccuracies in your personal data and completion of incomplete personal data.

You can find the full extent of your right to rectification in Article 16 of the GDPR, which can be accessed using the following link:

http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

Note: You can correct your account information and some device-related information yourself in the App. When you update some of your personal data, you will be asked to verify your identity before we proceed with your request, so that we can ensure the security of your Aqara Home Account and device. For any further correction requests, please contact us at privacy@lumiunited.com.

Right to erasure (“right to be forgotten”)

As a data subject, you have a right to erasure (“right to be forgotten”) under the conditions provided in Article 17 of the GDPR.

This means that you have the right to obtain from us the erasure of your personal data and we are obliged to erase your personal data without undue delay when one of the reasons listed in Article 17 paragraph 1 of the GDPR applies. This can be the case, for example, if personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed (Article 17 paragraph 1 point (a) of the GDPR).

If we have made the personal data public and are obliged to erase it, we are also obliged, taking account of available technology and the cost of implementation, to take reasonable steps, including technical measures, to inform controllers which are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of those personal data (Article 17 paragraph 2 of the GDPR).

The right to erasure (“right to be forgotten”) does not apply if the processing is necessary for one of the reasons listed in Article 17 paragraph 3 of the GDPR. This can be the case, for example, if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims (Article 17 paragraph 3 points (b) and (e) of the GDPR).

You can find the full extent of your right to erasure (“right to be forgotten”) in Article 17 of the GDPR, which can be accessed using the following link:

http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

Right to restriction of processing

As a data subject, you have a right to restriction of processing under the conditions provided in Article 18 of the GDPR.

This means that you have the right to obtain from us the restriction of processing if one of the conditions provided in Article 18 paragraph 1 of the GDPR applies. This can be the case, for example, if you contest the accuracy of the personal data. In such a case, the restriction of processing lasts for a period that enables us to verify the accuracy of the personal data (Article 18 paragraph 1 point (a) of the GDPR).

Restriction means that stored personal data are marked with the goal of restricting their future processing (Article 4 paragraph 3 of the GDPR).

You can find the full extent of your right to restriction of processing in Article 18 of the GDPR, which can be accessed using the following link:

http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

Right to data portability

As a data subject, you have a right to data portability under the conditions provided in Article 20 of the GDPR.

This means that you generally have the right to receive your personal data with which you have provided us in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance from us if the processing is based on consent pursuant to Article 6 paragraph 1 point (a) or Article 9 paragraph 2 point (a) of the GDPR or on a contract pursuant to Article 6 paragraph 1 point (b) of the GDPR and the processing is carried out by automated means (Article 20 paragraph 1 of the GDPR).

You can find information as to whether an instance of processing is based on consent pursuant to Article 6 paragraph 1 point (a) or Article 9 paragraph 2 point (a) of the GDPR or on a contract pursuant to Article 6 paragraph 1 point (b) of the GDPR in the information regarding the legal basis of processing in Section “HOW THE PERSONAL DATA IS USED” of this Privacy Policy.

In exercising your right to data portability, you also generally have the right to have your personal data transmitted directly from us to another controller if technically feasible (Article 20 paragraph 2 of the GDPR).

You can find the full extent of your right to data portability in Article 20 of the GDPR, which can be accessed using the following link:

http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

Right to object

As a data subject, you have a right to object under the conditions provided in Article 21 of the GDPR.

At the latest in our first communication with you, we expressly inform you of your right, as a data subject, to object.

More detailed information on this is given below:

Right to object on grounds relating to the particular situation of the data subject

As a data subject, you have the right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on Article 6 paragraph 1 point (e) or (f), including profiling based on those provisions.

You can find information as to whether an instance of processing is based on Article 6 paragraph 1 point (e) or (f) of the GDPR in the information regarding the legal basis of processing in Section “HOW THE PERSONAL DATA IS USED” of this Privacy Policy.

In the event of an objection relating to your particular situation, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Right to object to direct marketing

Where your personal data are processed for direct marketing purposes, you have the right to object at any time to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing.

You can find information as to whether and to what extent personal data are processed for direct marketing purposes in the information regarding the legal basis of processing in Section “HOW THE PERSONAL DATA IS USED” of this Privacy Policy.

If you object to processing for direct marketing purposes, we no longer process your personal data for these purposes.

You can find the full extent of your right to objection in Article 21 of the GDPR, which can be accessed using the following link:

http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

Right to withdraw consent

Where an instance of processing is based on consent pursuant to Article 6 paragraph 1 point (a) or Article 9 paragraph 2 point (a) of the GDPR, as a data subject, you have the right, pursuant to Article 7 paragraph 3 of the GDPR, to withdraw your consent at any time. The withdrawal of your consent does not affect the legitimacy of the processing that occurred based on your consent until the withdrawal. We inform you of this before you grant your consent.

You can find information as to whether an instance of processing is based on Article 6 paragraph 1 point (a) or Article 9 paragraph 2 point (a) of the GDPR in the information regarding the legal basis of processing in Section “HOW THE PERSONAL DATA IS USED” of this Privacy Policy.

Right to lodge a complaint with a supervisory authority

As a data subject, you have a right to lodge a complaint with a supervisory authority under the conditions provided in Article 77 of the GDPR, which can be accessed using the following link: http://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679.

You may find the contact details of your local supervisory authority in EU member states on the website of the European Data Protection Board:

https://edpb.europa.eu/about-edpb/board/members_en

You may exert your above-mentioned rights by contacting us at privacy@Lumiunited.com, and we will respond to your request within timeframe set out under your applicable data protection laws.

As applicable, for personal information of individuals that Aqara receives from the European Union, Aqara will handle such personal information in accordance with the European Union data protection laws. For personal information transferred from the European Union, Aqara utilizes the European Commission’s standard contractual clauses commonly known as “model clauses.” These model clauses are contract templates developed by the European Commission as a mechanism for contracting parties to legalize the cross-border transfer of personal data from Europe.

Please note that the model clauses will apply to the extent there is not another legal basis in place to validate the transfer of personal data from the European Union to the U.S.

Similarly, Aqara will comply with the United Kingdom’s Data Protection Act, as applicable.

Changes to Our Privacy Policy

We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

If at any time you find either this Agreement or the Privacy Policy unacceptable, you must immediately cease accessing the App and Websites. Unless Aqara obtains your express consent, any revised Privacy Policy will apply only to information collected by Aqara after the revised Privacy Policy takes effect, and not to information collected under any earlier versions of the Privacy Policy.

Contact Us

If you have any comments or questions about this Privacy Policy, or any questions relating to Aqara's collection, use or disclosure of your personal information, please contact us at the address below referencing "Privacy Policy":

US Office

Aqara LLC

Suite 218, 33 West 60th Street, Singapore, New York 10023

CN Office

Lumi United Technology Co., Ltd

Room 801-804, Building 1, Chongwen Park, Nanshan iPark, No. 3370, Liuxian Avenue, Fuguang Community, Taoyuan Residential District, Nanshan District, Shenzhen，China

Email: contact@aqara.com

If you are not satisfied with the reply received, you may bring a lawsuit in the court of competent jurisdiction where Aqara is located for resolution.

Thank you for taking the time to understand our Privacy Policy!

Country

Privacy Policy

WHAT INFORMATION IS COLLECTED BY US AND HOW DO WE USE IT

US Office

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