(Draft)

Our privacy policy was updated on July 1, 2019. We have revised our privacy policy to provide details of how we manage the privacy of personal information you disclose when you use all ZMI Home applications, starting from that date, in addition to the independent privacy policy provided by specific ZMI Home products or services.

Please take some time to familiarize yourself with our privacy practices. If you have any questions, please let us know.

We promise you

This Privacy Policy specifies how ZMI USA Corporation and its affiliated companies (hereinafter referred to as "ZMI" or "We") collect, use, disclose, process and protect the information you provide us when using our products and services; if we require you to provide certain information in order to verify your identity when using our products and services, we will only use this information in strict compliance with this privacy policy and/or our user terms and conditions.

This privacy policy is formulated with full consideration of your needs; it is essential that you have a comprehensive understanding of our personal data collection and use practices and are confident that you can ultimately control the personal information provided to ZMI.

In this privacy policy, "personal information" refers to data that identifies a particular individual by the information itself or by combining other information of the individual that ZMI can access. Such personal information includes your name, address, telephone number, and e-mail address.

By using the ZMI Home app, you have read, approved and accepted all the terms stated in this privacy policy, including any changes we may make at any time. We promise to protect the privacy, confidentiality, and security of your personal information in accordance with applicable laws, including the data protection laws of your location. At the same time, we promise all our employees and agents to fulfill these obligations.

Finally, what we want is to bring the best experience to our users. If you have any questions about the data processing practices outlined in this privacy policy, please contact our Data Protection Officer by sending e-mail to privacy@zmiusa.com so that we can handle your special needs. We will be glad to help you with your privacy concerns.

What information is collected and how to use it?

Categories of information collected

In order to provide you with our services, we will ask you to provide us with the necessary personal information to provide your services. If you do not provide personal information, we may not be able to provide you with our products or services.

We collect the following types of information (whether personal or not):

Information you provide or upload (including your contact information): We may collect any or all personal information you provide us, such as mobile phone number, e-mail address and other information related to the creation of mi account, the feedback and any other information you provide us.

Equipment-related information: Information related to your equipment. For example, MAC address, system version, device and motherboard identification number, device online status, SSID of router, RSSI, BSSID, device name, device manufacturer information and model name.

We specify information relevant to you: We may collect and use information such as mi account.

Location information (only applicable to specific services/functions): all kinds of information related to your location. For example, country code, city code, mobile network code, community identification, latitude and longitude information and language settings.

Login Information: Information related to your use of certain functions, applications, and websites. For example, cookies and other anonymous identifier technologies, IP addresses, temporary message history, and standard system logs.

Other information: Environmental Eigenvalue (ECV) (i.e. information obtained from Mi account, telephone equipment account, Wi-Fi account connected and geographic location)

We may also collect other types of anonymous information that are not associated with individuals. The purpose of collecting such information is to improve the services we offer you. The type and amount of information collected depend on how you use, join, or participate in our products and/or services.

How will this personal information be used?

The purpose of collecting personal information is to provide you with products and/or services and to ensure that we comply with applicable laws. You hereby agree that we process personal information for the purposes of this Privacy Policy and disclose personal information to our affiliates (which involve communications, social media, technology and cloud services) and third-party service providers (as defined below).

We may use your personal information for the following purposes:

Provide, process, maintain, improve, develop our products, and/or provide your services, including after-sales service and customer support, as well as services through equipment or website.

Exchange with you regarding your equipment, services or any general queries (such as updates, customer consultation support, information about our activities, notifications, etc.).

Analysis and development of statistics related to the use of our products and services to better improve our applications.

Store and maintain information related to you for use in our business operations or in fulfilling legal obligations

More details on how we use your information (which may contain personal information) are provided below. -

Create your mi account. Personal information collected when creating mi account through websites or mobile devices is used to create users ‘personal mi account and information pages.

Providing service of mi cloud. Collect information (device-related information, including device number, device operating system, MAC address, device category) to find devices, and to use for user authentication and service activation.

Provide location-based services. We may use location information to provide you with device access services. You can access device settings at any time or stop using this application to turn this off.

Authentication of user identity. We use ECV values to authenticate users and ensure that hackers or unauthorized personnel cannot log in.

Who do we share your information with?

We will not sell any personal information to third parties.

Sometimes we may disclose your personal information to a third party (see below for definition) in order to provide the product or service you require.

We may make a disclosure to third-party service providers and associated companies listed below in this section. In the various cases described in this section, you can rest assured that ZMI will only share your personal information according to your authorization. You should understand that in any case described below, when ZMI shares your personal information with third-party service providers, ZMI will abide by applicable local data protection laws by stipulating third-party practices and obligations under the contract. ZMI will contract to ensure that third-party service providers comply with the privacy standards applicable to them in your jurisdiction.

Sharing information with third-party service providers

In order to successfully engage in business and provide you with the full functionality of the application, we may from time to time contact other affiliated companies (which involve communications, social media, technology or cloud business) or our third-party service providers (our mail store, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising). Promotion service providers, agents representing ZMI (collectively referred to as "third-party service providers") disclose your personal information. Such third-party service providers may process your personal information on behalf of ZMI or on behalf of one or more of the above-mentioned projects. If you no longer want to allow us to share this information, please email us at privacy@zmiusa.com.

Share information with others

ZMI may disclose your personal information without further consent when applicable to legal requirements.

Information that does not require consent

We may share anonymous information with third parties (e.g. advertisers on our website) in a summary form for commercial purposes; we may share with them general trends in the use of our services, such as the number of customers in a particular group of people who purchase certain products or engage in certain transactions.

To avoid doubt, ZMI may collect, use, or disclose your personal information without your consent within the circumstances and scope explicitly permitted by the local data protection law (e.g., in order to comply with subpoenas), and when we may sincerely believe that in order to protect our rights, protect your safety or the safety of others, investigate fraudulent acts or respond to government requests When disclosure is necessary, disclose your information without your consent.

Safety guarantee

Safety Measures of ZMI

We promise to ensure your personal information security. In order to prevent unauthorized access, disclosure or other similar risks, we have implemented reasonable physical, electronic and management procedures to protect the information we collect from your products and applications. We will take all reasonable measures to protect your personal information.

All your personal information is stored on secure servers and protected in controlled facilities. We categorize your data according to its importance and sensitivity and ensure that your personal information has the highest level of security. We guarantee that access to this information will help employees and third-party service providers who provide applications to you have strict contractual confidentiality obligations, which will be subject to disciplinary action or termination of cooperation if they fail to fulfill these obligations. In summary, we regularly review information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.

We will take all feasible measures to protect your personal information. However, you should realize that the use of the Internet is not always safe, so we cannot guarantee the security or integrity of any personal information when it is transmitted through the Internet in two directions.

What can you do?

You can play a role in protecting the security of your personal information by not disclosing your login password or account information to anyone (unless this person is duly authorized by you).

ZMI is not responsible for security omissions caused by third parties accessing your personal information due to your failure to maintain the privacy of personal information. Notwithstanding the above provisions, you must notify us immediately of any unauthorized use of your account by any other user on the Internet or any other security vulnerabilities.

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

Reservation policy

If it is necessary to achieve the purpose of collecting information or to comply with applicable legal requirements or permission, we will always retain personal information. As long as we can reasonably infer that retaining personal information cannot achieve the purpose of collecting personal information, and no longer need to retain information for legal, dispute resolution, enforcement of our agreements or other business purposes, we will no longer retain personal information, or will eliminate the way to associate personal information with specific individuals.

Access other functions on your device

Our application may access certain functions on your device, such as Wi-Fi network status, and other functions. This information is used to allow these applications to run on your device and allow you to interact with them. At any time, you can revoke the license by closing the application at the device level or contacting us through privacy@zmiusa.com

You can control your information!

Control settings

ZMI admits that everyone has different concerns about privacy. Therefore, we provide some examples to illustrate the various ways ZMI provides for you to choose to restrict the collection, use, disclosure or processing of your personal information, and control your privacy settings:

Open or close location access function;

Log in or out of Mi account;

Open or close other services and functions that handle sensitive or personal information.

If you previously agreed to use your personal information for the above purposes, you can contact us at any time to change your decision by writing or sending an email to privacy@zmiusa.com.

Access, update or correct your personal information

You have the right to request access to and/or correction of any personal information we hold pertaining to you. When you update your personal information, you will be asked to verify your identity before we process your request. Once we have sufficient information to process your request for access to or correction of your personal information, we will respond to your request within the time required by the Data Protection Act.

We usually provide these services free of charge but reserve the right to charge a reasonable fee for your data access request.

If you wish to request access to our personal data or if you think any information we hold about you is incorrect or incomplete, please contact us at privacy@zmiusa.com as soon as possible.

More details related to personal information in your mi account can be accessed and changed through http://account.mi.com or through your device login account.

Revoke consent

By submitting a request, you can revoke your consent to collect, use, and/or disclose your personal information that we control or control. This can be done by unbinding the device. We will process your request within a reasonable time after you make the request, and will no longer collect, use and/or disclose your personal information according to your request.

Please note that your revocation of consent may have some legal consequences. According to the extent to which you withdraw your consent to let us process your personal information, this may mean that you cannot enjoy ZMI products and services.

Transfer personal information outside your jurisdiction

If we need to transfer personal information outside your jurisdiction, whether to our affiliated companies (which involve communications, social media, technology and cloud services) or third-party service providers, we will do so in accordance with applicable law. In particular, we ensure that all such transfers meet the requirements of applicable local data protection laws by implementing appropriate security measures.

Currently, ZMI has data centers in the United States, Singapore, Germany, China, Russia, and India. These overseas jurisdictions may or may not have data protection laws similar to those of your jurisdiction. We may transfer and store your personal information to our overseas facilities. However, this will not change all our commitments to abide by this privacy policy to protect your personal information.

Other provisions

Juveniles

We believe that it is the parents' responsibility to supervise the use of our products and services by their children. However, our policy does not require access to personal information of minors or any promotional information to such groups.

ZMI will not seek or attempt to receive any personal information from minors. If parents or guardians have reason to believe that minors have submitted personal information to ZMI without their prior consent, please contact us to ensure that such personal information is deleted and that minors are guaranteed to cancel their subscription to any applicable ZMI Service.

Priority order

If you agree to the applicable user agreement and there is an inconsistency between such user agreement and this privacy policy, such user agreement shall prevail.

Update of Privacy Policy

We will review our privacy policy regularly and may update our privacy policy to reflect changes in our information practices. If we make major changes to this privacy policy, we will notify you by e-mail (to your account's designated email address) or by publishing it on all ZMI websites or via mobile devices, so that you can understand what information we collect and how we use it. Such privacy policy changes will apply from the effective date specified by the notice or website. We recommend that you consult this website regularly for the latest information on our privacy practices. Your continued use of products and services on websites, mobile phones, and/or any other device will be considered as an acceptance of updated privacy policies. As we collect more personal information from you or we hope to use or disclose your personal information for new purposes, we will seek your consent again.

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

Our privacy policy does not apply to products and services provided by third parties. ZMI products and services may include third-party products and services, as well as links to third-party websites. When you use these products or services, you may also collect your information. Therefore, we strongly recommend that you take the time to read the third party's privacy policy, just like reading our policy. We are not responsible for how third-parties use the personal information they collect from you, nor can we control its use. Our privacy policy does not apply to other websites linked through our services.

When you use these specific products, the following third-party terms and privacy policies apply:

When creating and using a Mi account, you will agree to the terms of service and privacy policy of Mi account (http://www.miui.com/res/doc/privacy/en.html).

When using Amazon Alexa service, you will agree to Amazon's terms of service and privacy policy (https://na.account.amazon.com/ap/lwa/agreement?agreementName=privacyNotice&language=en_US&).

How to contact us

If you have any questions, comments or suggestions about this privacy policy, please contact us at

ZMI USA Corporation
120 San Lucar Ct
Sunnyvale, CA 94086
E-mail: privacy@zmiusa.com

Thank you for taking the time to review our privacy policy!