Privacy Notice

Updated: February 1, 2021

Effective Date: February 1, 2021

Beijing Kangshuo Information Technogy Co.,Ltd (hereinafter referred to as "KANGSHUO") describes the way in which we collect and use your personal information when you access or use our site, APP or other products & services that interact with KANGSHUO on your computers, mobile phones, laptops, consoles, or other devices (hereinafter referred to as "devices"),. KANGSHUO may update this Privacy Notice as necessary.

This Privacy Notice is intended to describe the general privacy policies of KANGSHUO, and our goal is to provide you with more detailed information at times that have the greatest impact on you.

I How we collect information

1. The information you provide to us.

If you consent to data collection when using our service, we will collect and store any information that you provided, including the following:

• contact information such as name, birthday, e-mail address, physical address, mobile phone number, gender, occupation;
• social media information and portraits;
• activity related information and health related data such us height, weight, , health records, physical data (e.g. heart rate, blood pressure, calories consumption, etc.);
• specific location information (e.g. altitude, latitude, longitude, GPS, etc.);
• personal preferences, product reviews;
• credit card & related payment information (if necessary);

2. Information that we will automatically collect.

If you provide your consent, whenever you interact with us or use our products & services, we will automatically collect certain information. For example, when your smart hardware (in the case of a smartwatch) is paired with the Lenovo Smart Watch APP and the Bluetooth connection is complete, it will automatically collect your steps, sleep and heart rate information, then automatically upload to the APP. If you initiate blood pressure, body temperature measurements and motion records from the smartwatch, such data will also be automatically uploaded to the APP.

When you use Lenovo Smart Watch APP, we will obtain information about your software usage. They include but far beyond hardware information, system types, access times. When you download or use the APP created or promoted by KANGSHUO, we will receive your phone number, device identifier and information about your location. In order to achieve the integrity of functions such as call reminders and outdoor sports.

3. The information we collect from third parties.

We will combine the information you provided or collected from mobile phone brand self-operating channels, transactions and communications. Such third parties include Lenovo U Health, Apple Health, Huawei Health, Google Health, Samsung Health, WeRun, QQ Sports and Alipay. This data processing activity will be performed only after you have provided your approval so that you can benefit from collaboration between applications.

II How we share, transfer and disclose your personal information

We won’t share your personal information with any company, organization or individual other than Lenovo Group and subsidiaries, except in the following cases:

• if necessary, after your explicit permission and authorization, we will share your personal information with other parties;
• with our affiliates, including companies of Beijing Kangshuo Information Technogy Co, Ltd. We only share the necessary personal information and are bound by the stated purposes in this Privacy Notice;
• with our suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our services globally, including the provision of technical infrastructure services, analysis, advertising, provision of customer service, payment services, academic research and investigation. For example, we use the Microsoft Cloud Service to store all user data.
• Authorized partners in advertising and analytical services. Without your permission, we will not share your personal identity information (information such as your name or email address, which can contact or identify you) with partners providing advertising and analysis services. We will provide these partners with information about the coverage and effectiveness of advertisements, rather than your personal identity information, or we will aggregate such information to avoid identification.

We always execute strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, and require them to process personal information in accordance with our instructions. Our partners have no right to use shared personal information for any other purpose.

In relation to mergers, acquisitions or liquidation, we ensure that the affected users are notified before any personal information is transferred or subject to other privacy notices.

Additionally, we will disclose your personal information in the following cases:

• legal requirements, legal processes, litigation cases or upon government or law enforcement requests;
• operating and maintaining product security, including preventing or blocking attacks on our computer systems or networks; identifying, preventing or handling fraud; protecting the legitimate rights of us, users or the public from damage, to the extent required or permitted by law; probably disclosing identity-free information publicly.

III How we protect your personal information

We have implemented industry-standard security measures to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss.

• We use encryption and authentication tools to help protect your information. For your personal data, we use a secure server;
• All personal data you provide will be transmitted via SSL technology and encrypted in our database;
• We organize security and privacy training sessions to enhance staff awareness of the importance of protecting personal data;
• we will take all reasonable and feasible measures to ensure that irrelevant personal data won’t be collected;
• we will retain your information only during the validity of your account, or the period of providing you with services and technical support. We will also retain your personal information for such periods as may be necessary to comply with applicable legal obligations, settle disputes, and enforce agreements. If you request to delete your information, we will take action and delete your information in accordance with our policy and applicable law.
• we will regularly update and publicize the relevant contents of security risks and personal information impact assessment reports.

The Internet environment is not 100% secure, but we will do our best to ensure or guarantee the security of any information you sent. If our physical, technical, or administrative protective devices are damaged, resulting in unauthorized access to information, disclosure, tampering, or destruction, or damage to your legitimate rights and interests, we shall be liable accordingly.

In the event of a personal data breach, we will promptly inform you, in accordance with applicable data protection laws.

IV Your rights

You may exercise the following rights by accessing your the App, under your profile, or you can contact us anytime via email at service@kang-shuo.com.

• Access your personal information and data protability.
• Correct your personal information.
• Delete your personal information.
• Change the scope of your authorization.
• Other applicable data protection rights.

In relation to the data deletion right, please note that you can do so if we process your personal information in violation of applicable data protection laws; if we collect and use your personal information without your consent where it is necessary; if we are processing the personal data beyond the retention period described above; and if we no longer provide you with products and services.

Please be aware that each feature requires some basic personal information. You can grant or withdraw your authorization for the collection and use of personal information at any time. When you withdraw your consent, we will no longer process the corresponding personal information. This includes the processing of your personal data for the purposes of marketing communications.

Regarding automated decisions, we may make decisions based on non-manual automatic decision mechanisms, such as information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will provide appropriate remedies, unless otherwise provided for by laws and regulations.

For safety, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request.

We do not charge any fees, but for repeated requests, we may charge a certain cost as appropriate. We may reject requests that are unreasonably duplicated, that require too many technical tools (such as the need to develop new systems or radically change current practices), that pose risks to the privacy of others, or that are highly impractical (such as information stored on backup tapes). We will not be able to respond to your request in the following cases, as required by the law:

• related to national security & defence security;
• related to public safety and vital public interest;
• related to criminal investigation, prosecution and trial, etc;
• the personal information controller has sufficient evidence to show that, responding to the request of the information subject will cause serious damage to the legitimate rights and interests of the individual information subject or other individuals and organizations.

V How we handle children's personal information

Our products, websites and services are mainly for adults. Children are not allowed to create their own accounts without the consent of their parents or guardians. For the collection of a child's personal information with parental consent, we will only use or disclose this information if it is permitted by law, with the explicit consent of the parent or guardian, or the necessity to protect the child. Although local laws and customs define children differently, we treat anyone under the age of 14 as a child. If we find ourselves collecting the child's personal information without the prior consent of a verifiable parent, we will delete the data as soon as possible.

VI How your personal information will be transferred globally

In principle, the personal information we collect and generate in the people's Republic of China will be stored in the people's Republic of China. Since we provide products and services through resources and servers worldwide, this means that, with your authorization, your personal information may be transferred to or accessed from other jurisdictions outside the country / territory in which you use the product or service. Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is adequately and equally protected within the people's Republic of China. For example, we will request your consent to move personal information across borders or implement security measures such as data anonymity prior to cross-border data transfer.

If you are in other country than China, we will comply with all applicable data protection requirements to ensure that your personal data is transferred in a compliant manner.

VII How this Privacy Notice is update

Our Privacy Notice may change which will not reduce your rights under this Privacy Notice without your explicit consent. We will post any changes to Privacy Notice on this page. For major changes, we will also provide more significant notifications (including email notifications of specific changes to privacy policies for certain services).

The major changes referred to in this Privacy Notice include, but are not limited to:

• there have been major changes in our Service Mode. For example, the purpose of handling personal information, the type of personal information processed, the use of personal information;
• major changes have taken place in our ownership structure, organizational structure, etc. For example, business adjustment, bankruptcy mergers and acquisitions caused by changes in owners;
• Significant changes have taken place in your right to participate in personal information processing and in the way you exercise it;
• the responsible department dealing with personal information security, contact methods and complaint channels change;
• personal information impact assessment reports indicate high risk.

We will make available to you an old version of this Privacy Notice for your reference.

VIII How to contact us

If you have any questions, comments or advice on this Privacy Notice, contact us at service@kang-shuo.com.

IX Description of user data collection in non-logged status

This software allows users to use the APP as a visitor without logging in. Users can use all the functions related to the smartwatch, and some software functions normally, such as step counting, sleep, heart rate, blood pressure and other functions under the health data module. The generated data will be associated with your generated visitor account, but not with your personal identity information.

If you uninstall the APP, in an unlogged-in state, the data will be lost. If you need to save your data under your account, log in or register first.

X The use of this software in collecting personal information

We will use your information in the following ways:

1. Enable you to consume related services of the software and smart wearable products.

2. Enhance, customize and personalize your experience and communication of Lenovo Smart Watch APP.

3. Operate, provide, improve and maintain products and services of Lenovo Smart Watch APP, including analysis of user behavior and trends. Send you management and other information about Lenovo Smart Watches.

4. Evaluate and improve the effectiveness of advertising and promotional activities in our services.

5. Perform services of software verification and upgrades.

6. When providing specific services based on users’ specific requirements, information needs to be provided to our affiliates, third parties or other users.

7. Other circumstances that benefit the users and Lenovo Smart Watch APP operators and follow mandatory laws and regulations.

8. Let you participate in surveys about our products and services.

By law or for the purpose of protecting rights:

We may disclose information at the request of government agencies, court orders, legal requirements, or for the purpose of enforcing our policies, protecting the rights, property or safety of us or others. We may share information to prevent illegal use of KANGSHUO related products and services, violation of Terms of Use, or legal defence against third-party litigation. We may also share information with other companies that help us with anti-fraud or investigation.