Space Assistant Privacy Policy
Last updated: 2024/12/20
Welcome to our Space Assistant product and related services. We take your privacy seriously, and this User Privacy Agreement aims to explain how we collect, use, store, and share your personal information. Please read this agreement carefully before using our product.
Contents
1£® Terms and Definitions
2£® Legal Grounds to Processing of Personal Data
3£® Information We Collect
4£® Purposes of Processing of Personal Data
5£® Ways of Processing of Personal
6£® Retention Terms
7£® How We Share Your Personal Data
8£® Your Rights
9£® Security
10£® Minor¡¯s Privacy
11£® Notification Regarding Updates
12£® Controller and Data Protection Officer
13£® Contact Us
1.Terms and Definitions
Data controller:means the legal entity (alone or jointly with others) determining the purposes and means of the processing of personal data. Space Assistant is the data controller, if not otherwise determined by law.
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; You (user or visitor of the Services) are the data subject.
International transfer: means transmission of personal data to the territory of a foreign state, public authority of a foreign state, foreign individual or foreign legal entity.
2. Legal Grounds to Processing of Personal Data
SPACE ASSISTANT will process your personal data only where there are legal grounds to do so. Those grounds include the following:
(a) Consent: You have provided your consent to the processing of your personal data.
(b) Legal situations: The processing of your personal data is required or authorized by applicable laws, or relates to suspected unlawful activity, serious misconduct, legal proceedings or law enforcement.
(c) Reasonable expectations: The processing of your personal data is necessary for the purposes of our legitimate interests. We believe that our processing of your personal data is within our legitimate interests and within your reasonable expectations in a number of situations, including but not limited to:
¡¤ To help us understand our customers better and provide improved, more relevant services to them;
¡¤ To ensure that our Services run smoothly;
¡¤ To help us keep our systems secure and prevent unauthorized access or cyber-attacks;
¡¤ To anonymize personal data (e.g. for research and statistical purposes) .
3. Information We Collect
(a) Conversation information: We may collect information from you during your try-out our product, including voice information you speak when having a conversation with Smart Voice Panel, and text information after voice recognition (transcription) to understand your needs (commands for controlling related smart appliances) and respond accordingly based on the content.
(b) Other Information: When you use some of the Services and such Services may require specific use of your information, we will specify such information in separate terms, agreements, or privacy policies and will collect, process, use, or transfer such information according thereto and get your consent where appropriate.
We do not generally ask you for sensitive personal data, i.e. personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal records, or trade union or professional association membership, genetic data for the purpose of uniquely identifying a natural person, and data concerning health or data concerning a natural person¡¯s sex life or sexual orientation, or other information that may be considered as sensitive personal data under the applicable laws and regulations. However, you may voluntarily provide sensitive personal data in the use of our services (e.g. by including it in the messages you input though you should try to avoid doing so). If we need to collect or process sensitive personal data (such as facial feature, fingerprint feature, heart rate, step count, etc.) in other circumstances, we will do so with your consent or where we are otherwise required or permitted by law.
4. Purposes of Processing of Personal Data
We will process your personal data to fulfill the following purposes:
(a)Operate our Services: We process collected personal data to interact with you about your device, services, or any of your questions and requests(understand your needs (commands for controlling related smart appliances) and respond accordingly based on the content).
(b)Understand how you use our products: We may use information to understand how you use our products/services.
5. Ways of Processing of Personal Data
We will carry out the following operations on your personal data you actively input through the Smart Panel: collection, systematization, retrieval, use, transfer (provision, access), and deletion (destruction) of personal data.
SPACE ASSISTANT does not take any decisions involving the use of algorithms or profiling that significantly affect you.
We are required to ensure such processing is subject to suitable safeguards, including reasonable steps to ensure personal data is accurate, complete, up-to-date and relevant, and your rights to access and correct personal data about you.
6. Retention Terms
The Smart Panel hardware does not store any your personal data. During the process of using cloud services through the Smart Panel, we process your personal data for as long as is necessary to fulfill the purpose of its processing, that is, all uploaded personal data will be immediately deleted after completing the processing purpose (to achieve voice to text, semantic understanding, and feedback to you), and will not be stored.
7. How We Share Your Personal Data
Personal data may be shared with:
(a) Third Parties. We may provide certain of your personal data to third-party service providers who may process your personal data on behalf of us, or for one or more of the purposes of this Privacy Policy.
These third-party service providers provide voice-to-text service, semantic understanding service, large language model (LLM) technology, and servers (as data processing carrier) for us to use.
When we do, we require those third parties to handle it in accordance with relevant laws and reasonable safeguards. SPACE ASSISTANT does not sell personal information, and personal information will never be shared with third parties for their marketing purposes.
(b) Legal and law enforcement. We are required to disclose your personal data by local judicial or governmental authorities, agencies or as mandated under applicable laws.
8. Your Rights
Being a data subject, you have other rights with respect to your personal data in accordance with relevant laws. You can access your personal data, require its rectification, blocking, or deletion by sending your request to smartspace2024@126.com. We shall at no time however be responsible/ liable for the authenticity/ veracity of the information you provide. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You have the following rights in relation to your personal data:
Right to information: You can send your request to smartspace2024@126.com to contact the controller at any time and request information about processing involving your personal data; request the controller to rectify or erase your data or restrict the processing of your data; or object to such processing.
Right of access: At your request, the controller will inform you whether your data is being processed. If yes, you will be entitled to gain access to your personal data that are processed by the controller, and to information concerning the recipients or categories of recipient to whom the personal data have been or will be disclosed, the proposed period of the processing or the criteria used to determine that period, and the sources of the data.
Right to rectification: You have the right to request rectification of any inaccurate data and completion of any incomplete data.
Right to withdraw consent: You may withdraw consent at any time by sending an email to us. Such withdrawal will not affect the legality and lawfulness of any processing made based on the consent given prior to the withdrawal.
Right to erasure: You can request the erasure of your personal data from the controller if(Unless your relevant personal data is immediately deleted after processing and will not be stored):
a) the personal data are no longer necessary in relation to the purposes for which they were processed;
b) you withdraw your consent and there is no other legal ground for the processing;
c) the conditions for making an objection apply;
d) the data processing is unlawful;
e) the erasure is necessary for compliance with a legal obligation to which the controller is subject;
f) you are a minor under the age of 21.
The controller will erase your data on the basis of such request, except if further processing is necessary
a) to ensure compliance with a relevant legal obligation to which the controller is subject, or
b) for the establishment, exercise or defence of legal claims.
Right to restriction of processing: At your request, the controller will restrict processing, if:
a) you contest the accuracy of the personal data, in that case the restriction will apply for a period while the accuracy of the data can be verified,
b) the processing is unlawful but you oppose the erasure of the personal data and request the restriction of their use instead,
c) the controller no longer requires the data for processing, but you need them for the establishment, exercise or defence of legal claims,
d) you have objected to the processing, in which case the restriction will apply for a period while it is verified whether the legitimate grounds of the controller override yours.
If the processing is subject to restriction in accordance with the above, the relevant personal data may, with the exception of storage, only be processed with your consent, or for the establishment, exercise or defence of legal claims, for the protection of the rights of another person or for reasons of important public interest of the European Union or of a Member State. The controller will inform you before the restriction of processing is lifted.
You and all other persons to whom your data have been transferred will be informed about any rectification, erasure or restriction. The controller will not provide such information if this is impossible or involves a substantial effort. If the controller has made the personal data public and is obliged to erase the personal data, it will, in the light of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform controllers that are processing the personal data about your request that they should erase any links to, or copy or replication of, those personal data.
Right to object: You can object to the processing of your personal data if:
a) it is done on the basis of a legitimate interest; in that case the processing may not be continued, unless there are compelling and legitimate reasons for the processing that override your interests, rights and freedoms, or reasons that are related to the establishment, exercise or defence of legal claims;
b) it is done for, or is related to, direct marketing purposes; in that case the processing may not be continued for such purpose.
Right to data portability: You can request the controller to provide your data to you in a structured, commonly used and machine-readable format, if this is technically feasible, so that you can transmit such data to another controller, or you can request the controller to perform such transmission directly.
Right to lodge a complaint: If you believe that your rights associated with your personal data have been violated, please inform the controller or the data protection officer about your complaint by using any of the contact details stated above.
9. Security
SPACE ASSISTANT takes security measures to protect your information, including but not limited to administrative, technical and physical measures. However, please note that although we have implemented these measures, there is no security measure that can guarantee the absolute safety and security of your information. If you believe that your login credentials have been compromised, please contact us at once.
It is your responsibility to make sure that your personal data is accurate.
Below are some examples of data security measures we undertake:
(a)Ensuring the security of the premises where the information systems used to process personal data are located. Such security shall prevent any uncontrolled access to such premises by persons having no rights to access such premises.
(b)Using technical means to protect the information including but not limited to encryption and anonymization techniques.
(c)Approving the list of persons who are authorized to access the information systems where the personal data are processed.
(d)Appointing a data protection officer.
(e)Identifying threats to the security of personal data while they are being processed in our information systems.
(f)Assessing the effectiveness of measures taken to ensure the security of personal data.
(g)Detecting instances of unauthorized access to personal data and taking appropriate measures to mitigate the effects of such unauthorized access.
(h)Taking all practicable measures to restore personal data which have been modified or destroyed as a result of unauthorized access.
(i)Monitoring measures taken to ensure the security of personal data and the level of protection of personal data information systems.
(j)Establishing rules for access to personal data being processed in our information systems and recording all processing actions performed on personal data contained in our information systems.
10. Minor¡¯s Privacy
The Services are not intended for minors as defined by applicable laws. We do not knowingly collect personal data via our Services from minors. We will only use or disclose minor information if (a) legally permissible; (b) the parent or other legal representative of the minor has provided consent; or (c) there are other legal grounds as per applicable data protection laws. If we accidentally collect a child's personal data without verified prior consent from the child's parents, we will attempt to delete the data as soon as possible. If you believe a minor has provided personal data to us without parental/legal guardian consent, please contact us
11. Notification Regarding Updates
We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you via product so that you can learn about the information we collect and how we use it. Such changes to Privacy Policy will apply from the effective date specified in the notice or website
12. Controller and Data Protection Officer
SPACE ASSISTANT is responsible for the collection and processing of your personal data in connection with the provision of our services.
We have appointed data protection officers to oversee the protection of your personal data. If you have any questions about this Privacy Policy or about data protection at SPACE ASSISTANT in general, you can contact the data protection officer responsible for your country at any time. The contact details of the data protection officer is: smartspace2024@126.com
13. Contact Us
If you have any questions about the way we handle your personal data which have not been answered in this Privacy Policy, you may send your request to smartspace2024@126.com