Privacy Policy

Our Privacy Policy was updated on 25 Mar. 2019. We have revamped the Privacy Policy front and back so that from this date onwards, this Privacy Policy can provide privacy details on how we manage your personal information for all imuto products and services, unless a separate privacy policy is provided for a specific imuto product or service.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

Our commitment to you

This Privacy Policy sets out how IMUTO LIMITED. and its affiliated companies within the imuto Group (“imuto”, “we”, “our” or “us”) collect, use, disclose, process and protect any information that you give us when you use our products and services located at www.imuto.com. Should we ask you to provide certain information by which you can be identified when using imuto products and services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information provided to imuto.

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 imuto has access about that individual. Such personal information may include but not limit to the information you provide to us or upload, the information specific to you that may be assigned by us, your financial information, social information, device or sim-related information, location information, log information.

By using imuto products and services or other acting permitted by the applicable laws, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may 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 use our products and services in the European Economic Area (EEA), imuto Singapore Pte. Ltd. will act as the data controller and be responsible for the processing of the data. Contact details of imuto Singapore Pte. Ltd. can be found in the "Contact Us" section.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact support@imuto.com to address your specific concerns. We will be happy to address them directly.

If you have questions or concerns regarding our Privacy Policy or practices, please contact us at support@imuto.com

What information is collected and how can we use it?

Types of information collected

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.

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):

· Financial information: information related to completing purchases. For example, bank account number, account holder name, credit card number etc.

· Social information: information related to your social activities. For example, current employer, current job title, education background, professional training background etc.

· Device or SIM-related information: information related to your device. For example, IMEI number, IMSI number, MAC address, Serial number, imuto version and type, Android version, Android ID, screen display information, device keypad information, device manufacturer details and model name, network operator, connection type, hardware usage information such as battery usage, device temperature.

· Application information: information related to your software usage. For example, application list, application status record (e.g. downloading, installing, updating, deleting), application ID information, SDK version, system update settings etc.

· Location information (only for specific services/functionalities): various types of information on your location. For example, region, country code, city code, mobile network code, mobile country code, cell identity, 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 addresses, network request information, temporary message history, standard system logs, crash information.

We may also collect other types of 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 imuto mobile phone device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you.

How the 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.

 

With whom we share your information

We do not sell any personal information to third parties.

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

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that imuto will only share your personal information in accordance with your consent. Your consent to imuto will engage sub-processors for the processing of your personal information. You should know that when imuto shares your personal information with a Third Party Service Provider under any circumstance described in this section, imuto will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. imuto will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

Sharing with our group and third party service providers

From time to time, in order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other imuto affiliated companies (in communications, social media, technology or cloud businesses), or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers, agents acting on behalf of imuto, [related corporations, and/or other third parties] (together “Third Party Service Providers”). Such Third Party Service Providers would be processing your personal information on imuto’s behalf or for one or more of the purposes listed above. We may share your IP address with third parties when using certain mobile applications on our device in order to provide you with some of the services you requested. If you no longer wish to allow us to share this information, please contact us at support@imuto.com.

Sharing with our group’s companies

Imuto may disclose your personal data so as to provide you with and improve the exciting products and services (both hardware and software). Some of these products and services will still be under the imuto brand, while others may use their own brand. The companies may also share data with imuto from time to time in relation to products and services under the imuto brand and other brands owned by imuto to provide hardware and software services, and to create better functions and user experience. imuto will take appropriate organizational and technical measures to ensure the security of personal data during the process of sharing of information, including but not limited to the encryption of your personal data. If imuto is involved in a merger, acquisition or asset sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our website, of any changes in ownership, uses of your personal information, and choices you may have regarding your personal information.

Sharing with others

Imuto may disclose your personal information without further consent when required under applicable law.

Information not requiring consent

· We may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

· For the avoidance of doubt, imuto 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.

Security safeguards

imuto’s security measures

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 on your mobile device and on imuto websites. We will use all reasonable efforts to safeguard your personal information.

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.

We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason 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 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.

What you can do

· 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. Whenever you log in as a imuto Account user on imuto websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.

· Imuto 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 notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.

· Your assistance will help us protect the privacy of your personal information.

Retention policy

Personal information will be held for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws. 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 imuto even if the further processing is incompatible with original purposes.

Accessing other features on your device

Our applications may need access to certain features on your device such as enabling emails to contacts, SMS storage and Wi-Fi network status, as well as other features. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us at support@imuto.com.

You have control over your personal information

Controlling settings

imuto recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways imuto makes available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

· Toggle on/off for the User Experience Program and Location Access functions;

· Toggle on/off for the Mi Cloud sync functions; and

· Delete any information stored on Mi Cloud through www.imuto.com

· Toggle on/off for other services and functionalities which deal with sensitive or personal information.

You may obtain more details in relation to your device’s security status in the imuto Security Center as well.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or emailing us at support@imuto.com.

Access, update, correct, erase or restrict processing your personal information

· You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

· 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 requests 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: support@imuto.com

· If you are Europe 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 Europe 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 Europe 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 Europe 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.

Withdrawal of consent

· You may withdraw your consent for the collection, use and/or disclosure of your personal information in our possession or control by submitting a request. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.

· Please recognize that your withdrawal of consent could result in certain 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 imuto’s products and services.

Transfer of personal information outside of your jurisdiction

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, 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 imuto for this transfer of your personal information.

imuto is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal data to any subsidiary of the imuto 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).

Imuto may use overseas facilities operated and controlled by imuto to process or back up your personal information. Currently, imuto has data centers in Beijing, United States, Germany, Russia and Singapore. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. You have understood that the risks under applicable data protection laws are different and 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.

Miscellaneous

Minors

· We consider it the responsibility of parents to monitor their children’s use of our products and services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.

· Imuto does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided imuto with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable imuto services.

 

 

Order of precedence

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

Updates to the privacy policy

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the imuto websites or through our mobile devices, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

Do I have to agree to any third party terms and conditions?

Our Privacy Policy does not apply to products and services offered by a third party. imuto products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

Here are third party terms and privacy policies that apply when you use these specific products:

Social media (features) and widgets

Our websites include social media features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these Features are governed by the privacy policy of the company providing it.

Single sign-on

Depending on your jurisdiction, you may be able to log in to our website using sign-on services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this website to your profile page to share with others within your network.

About our systematic approach to manage your personal information

If you are Europe Union user under GDPR, imuto will provide systematic approach to manage personal data deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) imuto set up a Data Protection Officer (DPO) in charge the data protection, and the contact of DPO is dpo@imuto.com; (2) procedure like data protection impact assessment (DPIA).

What’s new to you

We have made several major edits throughout the “Privacy Policy” as follows:

· We updated the types of personal information that we collected and the purposes of collecting such information. For example, we collected hardware usage information to conduct statistical analysis and optimize the performance of your devices.

· By complying with GDPR and providing better data privacy protection, we updated the relevant content about users’ rights under GDPR, and how we process the personal information for our Europe Union users. We also described our data privacy management method additionally.

· We updated the relevant content of third parties’ products and services which may be involved during the use of our products and services.