So you have purchased our SmartLife device hardware and are starting to use the SmartLife device software and all its
functionalities! Any information you share with us (e.g. for creating a SmartLife Account) will help us to provide
with services related to SmartLife device and to improve them to make them even better. We explain here our ways of
information that can be used to identify an individual, either from that information alone, or from that information
and other information we have access to about that individual. We collect both personal and non-personal data to
enable and facilitate the best user experience possible.
What information is collected and how do we use it?
Types of Personal Data Collected
- In order to provide our services to you, we will ask you to provide necessary personal data that is required to
provide those services. If you do not provide your personal data, we may not be able to provide you with our
products or services.
Set up and log in of SmartLife Account.Personal data that are collected for creating a
may include your email address or mobile phone number, device related information (e.g. IMEI number) and various
location related information (e.g. location area code, mobile network and country codes).
Purchasing your SmartLife products.When you make purchases through the SmartLife e-commerce
may collect your SmartLife Account ID (or mobile phone number or email addressed used to create your SmartLife
name, phone number, delivery address and order details, etc. SmartLife provides logistics services to deliver
products purchased on the e-commerce website. SmartLife has an after sales system to handle after sales related
matters as well as an after sales centre for walk-in support services for users. When you use these services, we
may also collect the order number, invoice date, list of purchased items and your contact details in order to
process the services.
Activating SmartLife device.When you activate the SmartLife device, we may collect your age,
height, weight and gender. We may also collect other details you provide as part of your profile such as your
birthday, picture and signature.
Sync SmartLife device data.When you synchronise the SmartLife device data, e.g. to SmartLife
device Cloud Service, we may collect data relating to your activities and functionalities of SmartLife device,
such as those obtained from our sensors and features on SmartLife device, your sleeping patterns, movement data
and smart alarm related information.
Sharing your content.When you share content or send information to family and friends, we may
collect personal information of those people, such as their names, email addresses, telephone numbers, and
mailing addresses (if we need to send a product to them). You hereby represent and warrant that you have
obtained necessary consent for use of third parties’ personal data if you choose to provide them to us. When you
share content or invite users to use SmartLife device, please note that other users may see personal data you
Processing the services.In providing the above services, we may also collect data in relation
to your device, including your SmartLife device ID, firmware version, device OS version, model and system, and
visiting IP and time.
How the Personal Data is used
- To provide you with our products and services, processing your orders, performing contractual obligations
between you and us, to ensure the functions and safety of our products, to verify your identity, to prevent and
trace fraudulent or inappropriate usage
- To develop our products and services, together with general and statistical information
- To communicate with you, including providing you with notifications on products and services that are updated or
- To provide marketing and promotional materials to you on our products and services (please note that you may
- To personalise product design and to provide you with services tailored for you, for example, recommending and
displaying information and advertisements regarding products suited to you, and to invite you to participate in
surveys relating to your use of SmartLife device
- To conduct investigations regarding our products and services
- If you participate in our lottery, contest or other promotions, we may use your personal data to manage such
- To provide maintenance services, monitor software licenses, to improve our products or analyse the efficiency of
We use statistical data that does not specifically identify you (non-personal data) to help in our operations and
improve our products and services and provide a better user experience for you. Here are some of the non-personal
data we may collect and how we use them:
- When you create a SmartLife Account, download our software, register in our e-commerce website, participate in
surveys or interact with us in other ways, we may collect your language preferences, postal code, area code
number and time zone in which you use our products and services, and your profession.
- When you opt-in to participate in our User Experience Improvement Program, we may gather statistics relating to
your use of our products functions, on an anonymous basis. This may include information relating to your use of
our official website, products and services. If there is an abnormal shutdown or breakdown, we may collect
information relating to your mobile device to diagnose the problem.
- When you use our services or functions that are based on location information, e.g. carry out a location search,
take advantage of advertising, use weather functions, access information based on maps, etc., we may collect
your geographical information.
- When you use our website, online services, interactive applications, email messages and advertising, we may use
cookies and other technical elements (e.g. pixel labels) to collect and store non-personal data. These enable us
to provide you with a better experience and improve our overall service quality, e.g. in saving your preferred
language settings, sending emails in a readable format, to determine whether the emails have been opened or not,
- When you use the Internet browser in using our products and services, we may collect log information, e.g. IP
address, browser type, language, reference source, operating system, date and time marking and click rate data.
- When you first use and activate your SmartLife device, the device’s unique identification code and approximate
geographical information may be collected.
You have control over your information!
We recognise that privacy concerns differ from person to person. Therefore, we provide examples of ways we make
available for you to choose to restrict the collection, use, disclosure or processing of your personal data and
control your privacy settings, such as controlling the settings under the User Experience Improvement Program,
Location Access functions, and your SmartLife Account.
Access, Updating or Correcting Your Personal Data
- You have the right to request access and/or correction or any other personal data that we hold about you. When
you update your personal data, 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 or correction of your personal
data, we shall process in accordance with the laws of your country. While we try our utmost in acceding to your
requests, unreasonably repetitive or unrealistic requests or those that put others’ privacy at risk may be
- We normally provide such services for free but reserve the right to charge a reasonable fee.
- 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: firstname.lastname@example.org.
- For details relating to the personal data in your SmartLife Account, you may also access and change them at
Withdrawal of Consent
- You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession
or control by submitting a request. This may be done by accessing your SmartLife Account management center at
email@example.com . We will process your request within a reasonable time from when the request was made,
thereafter not collect, use and/or disclose your personal data 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 data, it may mean that you will not be able
to enjoy SmartLife’s products and services.
Who do we share your information with?
personal data on occasion to third parties in order to provide the products or services that you have requested.
Some of these third parties may be located outside your home country.
Disclosure may include the scenarios listed in this section below. In each case described in this section, you can be
assured that SmartLife will only share your personal data in accordance with your consent. You should know that when
shares your personal data with a third party under any circumstance described in this section, SmartLife will ensure
the third party is subject to practices and obligations to comply with the relevant data protection and privacy laws
of your country. SmartLife will contractually ensure compliance by any foreign Third Party Service Providers with
privacy standards that apply in your home jurisdiction.
Disclosure to SmartLife group companies and Third Party Service Providers
- In order to conduct business operations smoothly, the SmartLife entity which collects your personal data may
your personal data from time to time to other SmartLife group companies (in communications, social media,
or cloud business), or our third party service providers which are our mailing houses, delivery service
providers, telecommunications companies, data centres, data storage facilities, and customer service providers,
agents, related corporations, and/or other third parties (together “Third Party Service Providers”). Such Third
Party Service Providers would be processing your personal data on SmartLife’s behalf or for one or more of the
purposes listed above.
- Personal data will only be shared by SmartLife to provide or improve our products or services and will not be
for use for marketing purposes.
Disclosure to Others
SmartLife may disclose your personal data without further consent if required or permitted by law in the following
- cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
- cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety
of the individual or another individual;
- cases in which the disclosure is necessary for the prevention of crime or legal proceedings;
- cases in which the purpose of such disclosure is clearly in the individual’s interests, and if consent cannot be
obtained in a timely way;
- cases in which the disclosure is necessary for any investigation or proceedings;
- cases in which the disclosure is to any officer of a prescribed law enforcement agency upon production of
written authorisation signed by the head or director of that law enforcement agency, or a person of a similar
rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
- cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.
Information Not Requiring Consent
- We may share anonymised information and statistics in aggregate form with third parties for business purposes,
for example with advertisers on our website, or we may tell our business partners the number of customers in
certain demographic groups who purchased certain products or who carried out certain transactions.
- For the avoidance of doubt, in the event that we are permitted by law to collect, use or disclose your personal
data without your consent, such permission granted by the law shall continue to apply.
Information Safety Safeguards
We are committed to ensuring that your personal data is secure. In order to prevent unauthorised 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. We have put in place the following security procedures and technical and
organisational measures to safeguard your personal data:
- Your personal data is stored on secure servers that are protected in controlled facilities.
- All data saved in the back-end is classified into different levels based on the importance and sensitivity of
the data, e.g. whether the data contains personal data.
- In the data centers, clusters that contain sensitive data are grouped together in the network topology, and will
be placed in rooms with additional physical security protection.
- Data exchanged between SmartLife devices and servers are encrypted using Secure Sockets Layer (“SSL”).
- There is an optional two-step verification process when users access their SmartLife Account.
- There is regular review of information collection, storage and processing practices, including physical security
measures, to guard against unauthorized access to systems.
- Access is restricted to SmartLife employees and Third Party Service Providers who need to know that the
in order to process it, and who are subject to strict contractual confidentiality obligations and may be
disciplined or terminated if they fail to meet such obligations.
- There are also access controls for all server clusters used for cloud-based data storage and process.
- Most data used for SmartLife’s products and/or services is stored in a storage system. By using column family
access control mechanism, SmartLife employees are only allowed access to the data column families they are
- Please note also that for the above, SmartLife may use overseas facilities operated and controlled by SmartLife
or back up your personal data. Currently, SmartLife has data centres in Beijing and Singapore. As a result, we
transfer to and store your personal data at our overseas facilities. However, this does not change any of our
Information safety is very important to us. We will take all practicable steps to safeguard your personal data.
Through our protective measures above, especially encrypted storage and transmission, your data is as secure as it
can be. Certain details of encrypted data cannot be accessed by anyone except by you.
include third party’s products or services. When you use such products or services, they may collect your
time to read ours. We are not responsible for and cannot control how third parties use personal data which they
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 data from minors or offer to send any promotional materials
to persons in that category. SmartLife does not seek or intend to seek to receive any personal data from minors.
parent or guardian have reasons to believe that a minor has provided SmartLife with personal data without their
consent, please contact us to ensure that the personal data is removed and unsubscribe them from any of the
applicable SmartLife services.
SmartLife websites, so that you may be aware of the information we collect and how we use it. Such changes to our
Policy shall apply from the time that we post the same on the SmartLife websites. 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 data from you or when we wish to use or
disclose your personal data for new purposes.