PRIVACY POLICY

Update!

Our Privacy Policy was updated on 28 April 2020. 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 Kebbi Air products and services by Nuwa Robotics Corp. and affiliated companies, unless a separate privacy policy is provided for a specific Nuwa product or services.

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 Nuwa Robotics Corp. and its affiliated companies within the Nuwa Group ("Nuwa", "we", "our" or "us") collect, use, disclose, process and protect any information that you give us when you use Nuwa Space software and services. Should we ask you to provide certain information by which you can be identified when using Nuwa Space software 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 Nuwa.

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

By using Nuwa Space software and services, 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. We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, including your local data protection legislation. We are equally committed to ensuring that all our employees and agents uphold these obligations.

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 our Data Protection Officer at privacy@nuwarobotics.com to address your specific concerns. We will be happy to address them directly.

WHAT INFORMATION IS COLLECTED AND HOW WE CAN 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):

• Information you provide to us or upload (including your contact details): we may collect any and all personal information you provide to us, like your name, mobile phone number, email address, delivery address, Nuwa Account details ( e.g.name, birthday), order, invoicing details, materials or data you may sync through Nuwa Cloud or other apps (e.g. photos, contact lists), information in relation to creating an account and participating in the all Nuwa platforms or services, phone numbers you insert into your contacts or to send a message, feedback, and any other information you provide us.
• Information related to device: information related to your device. For example, Serial number, MAC address, software version, Android version, iOS version, and model name.
• Location information (only for specific services/functionalities): various types of information on your location. For example, country code, longitude and latitude information, time zone settings, language settings.
• Information about Bluetooth devices: Information about other devices (sub-devices) that are connected to the network via the device, including the model, DID, name, status, Bluetooth signal strength, and MAC address of Bluetooth devices.
• Network information: we may collect network-related information when your device is connected to a network. This includes IP address, and MAC address of the device.
• Purchase orders information：We may collect purchase orders information you provide to us when you purchase in Nuwa Store, like your name, address, postal code, phone number and invoice type.
• Family information：We may collect family information you provide to us, including name, gender, face recognition. Face recognition will only be performed on your device. We will not store your original face photos, only the feature information processed by special algorithms. If you do not provide face recognition information, such functions will not be available, while other functions will not be affected. We will take strict security measures to ensure the safety of such data. If you want to delete such information, you can contact us at privacy@nuwarobotics.com.
• 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 Nuwa 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 IS 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, Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

• Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.
• Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, information about our events, notices.
• Analyzing and developing statistical information on use of our products and services to better improve our products and services.
• Optimizing the performance of your device.
• Storing and maintaining information about you for our business operations or legal obligations.
• Providing local services without communicating with our servers.

Here are more details on how we use your information (which may include personal information):

• Setting up your Nuwa Account. Personal information collected when creating a Nuwa Account on our web sites or through our mobile devices is used for creating the personal Nuwa Account and profile page for the user.
• Processing your purchase orders. Information relating to e-commerce orders may be used for processing the purchase order and related after-sales services, including customer support and re-delivery. In addition, the order number is used to cross check the order with the delivery partner as well as the actual delivery of the parcel. The receipt details, including name, address, phone number and postal code are for delivery purposes. The email address is used to send parcel tracking information to the user. The list of purchased item(s) is used for printing the invoice and allowing users to see what is in the parcel.
• Allowing you to participate in Nuwa Forum. Personal information in relation to the Nuwa Forum or other Nuwa Internet platforms may be used for profile page display, interaction with other users, participating in the forum.
• Providing Nuwa Cloud and other Nuwa services. Information (phone number, device ID, device operating system, MAC Address, device type, system and performance information and location information including mobile country code) is collected for activating Nuwa services, e.g. Nuwa Cloud, call log sync, SMS sync, for the purposes of user authentication and activation of the services.
• Providing other Nuwa services. Other information collected for each of the Nuwa services may be used for performing the functions of that service, and to facilitate the provision of that service for the benefit of the user, e.g. downloading, updating, registering or performing activities related to Nuwa services.
• Providing messaging functions. When you have conversation with Nuwa products, your chat history will be collected by Nuwa Cloud and stored by Nuwa Space. In addition, chat history is stored for the convenience of re-loading historical chats after a user has re-installed apps, or for synchronisation across devices.
• Face recognition: When you register as a family member, we will get your face feature information by taking your photo. Such information will only be backed up and stored to the server while the user can choose whether to use the previous data when changing the robot or resetting it (inheritance mechanism).
• Voice control. When use voice control and interaction services, we may collect your dialogue notes to provide such services.
• Providing location based services. In the course of using Nuwa services, location information may also be used by us or Third Party Service Providrs to serve you the correct version of the service and provide accurate details about that location for the best possible user experience, e.g. weather details, location access (as part of the Android/iOS platform).
• Improving user experience. Some opt-in features, such as the User Experience Program, allow Nuwa to analyse data about how users use the Nuwa devices and services, so as to improve the user experience, such as sending crash reports.
• Providing Push Service. Device serial number will be used to provide the Nuwa push service to evaluate advertising performance and send notifications from Nuwa about software updates or new product announcements, including information about sales and promotion.
• Collecting user feedback. The feedback you choose to provide is valuable in helping Nuwa make improvements to our services. In order to follow up on the feedback you have chosen to provide, Nuwa may correspond with you using the personal information that you have provided and keep records.
• Sending notices. From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.

DIRECT MARKETING

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

COOKIES AND OTHER TECHNOLOGIES (ONLY WHEN BROWSING https://www.nuwarobotics.com)

• What information is collected and how we can use them: Technologies such as cookies, tags, and scripts are used by Nuwa and our Third Party Service Providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
• Log Files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type.
• Local Storage – HTML5: We use Local Storage Objects (LSOs) such as HTML5 store content and preferences. Various browsers may offer their own management tool for removing HTML5 LSOs.

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 Nuwa will only share your personal information in accordance with your consent. Your consent to Nuwa will engage sub-processors for the processing of your personal information. You should know that when Nuwa shares your personal information with a Third Party Service Provider under any circumstance described in this section, Nuwa will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Nuwa 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

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 Nuwa affiliated companies, 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, and Nuwa’s representatives. Such Third Party Service Providers would be processing your personal information on Nuwa’s behalf or for one or more of the purposes listed above. If you no longer wish to allow us to share this information, please contact us at privacy@nuwarobotics.com

Our policy does not apply to products and services provided by other third parties. all Kebbi Air products and services may include third-party products and services, and links to third-party websites. When you use these products or services, they may also collect your information. Therefore, we strongly recommend that you take the time to read the privacy policy of the third parties, just like reading our policy. We are not responsible for how such third parties use the personal information they collect from you and cannot control their use.

SHARING WITH OTHERS

Nuwa 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, Nuwa 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. Such disclosure may be brought about by the necessity to protect our rights, ensure the safety of you and other people, and comply with the requirements of the local government to facilitate the investigations of illegal activities.

SECURITY SAFEGUARDS

NUWA’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 from your using of Nuwa products and services and on Nuwa websites. We will use all reasonable efforts to safeguard your personal information.

For example, when you send or receive data from your Nuwa device to our servers, we make sure they are encrypted using Secure Sockets Layer ("SSL") and other algorithms.

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.

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 Nuwa Account user on Nuwa websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.
• Nuwa 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 fulfil 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 Nuwa even if the further processing is incompatible with original purposes.

All the personal information on the device will be erased when you reset your device to factory default settings. To implement a hard-reset function, you can perform this function in setting menu of the robot. Beware that reset can’t be undo, so you have to make sure that you don’t need the information any more.

ACCESSING OTHER FEATURES ON YOUR DEVICE

Our applications may need access to certain features on your device such as Wi-Fi network status. 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 privacy@nuwarobotics.com.

YOU HAVE CONTROL OVER YOUR INFORMATION!

CONTROLLING SETTINGS

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

• Log in and out of the Nuwa Account;
• Delete any information stored on Nuwa Cloud through privacy@nuwarobotics.com.

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 privacy@nuwarobotics.com.

ACCESSING, UPDATING, CORRECTING OR ERASING 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.
• We normally provide such services for free but reserve the right to charge a reasonable fee for your data access request.
• 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 or if you believe any information we are holding on you is inappropriate or excessive, please write to or email us as soon as possible at the email address below. Email: privacy@nuwarobotics.com.
• For details relating to the personal information in your Nuwa Account, you may also access and change them at https://account.nuwarobotics.com

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. This may be done by sending e-mail to privacy@nuwarobotics.com. 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 recognise 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 (1) Nuwa’s products and services/ (2) Nuwa Space software 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, 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 Nuwa for this transfer of your personal information

Nuwa may use overseas facilities operated and controlled by Nuwa to process or back up your personal information. Currently, Nuwa has data centers in Tokyo. 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.

MISCELLANEOUS

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 may notify you by email (sent to the e-mail address specified in your account) or post the changes on all the Nuwa websites or through our software, 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. Nuwa 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:

• By using the intelligent voice function, you are agreeing to [Google’s privacy policy: https://policies.google.com/privacy].

CONTACT US

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

Nuwa Robotics Corp. and affiliated companies.

3F., No. 102, Dunhua N. Rd.,

Songshan Dist., Taipei City, 105405

Taiwan (R.O.C)

Email: privacy@nuwarobotics.com

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