Initial Effective Date: 2024/6/24
Last Updated Date: 2025/2/20
UGREEN Home consists of the application and related services provided by Ugreen Group GmbH (hereinafter referred to as "we" or "Ugreen"). We attach great importance to the security of your personal data and privacy protection. This policy aims to explain to you how we collect, use, store, share, and protect your personal data, as well as how you can exercise your rights. If you have any questions about this policy, you can contact us through the contact information at the end of this policy.
Users of UGREEN Home may come from all over the world. If you are a user from the European Economic Area (EEA), the state of California in the United States, or Japan, the special appendices for the respective regions after this policy also apply to you. In case of any conflict between the appendix and the main text, the provisions of the appendix shall prevail.
Before using our products or services, please carefully read and fully understand the contents of this policy, especially the bolded text.
The following are all the personal data collected by UGREEN Home's functions. You can also click on the "Personal Information Collection List" to view it. For functions you do not use, we will not collect your personal data, and your consent to this policy does not involve functions you have not used. We will not use your personal data beyond the purposes disclosed in this policy.
You can register and log in using your email. When registering, you need to provide us with the verification code received by your email.
You can choose to add devices to UGREEN Home through Bluetooth scanning or manual methods. If you choose to add devices through Bluetooth scanning, we need to access the WIFI list and Bluetooth list to facilitate the connection between the device and UGREEN Home. We collect this information based on your consent so that you can add and use devices.
When you bind a device, we will collect your device name, device ID, MAC address, SSID, and Location permission to confirm device information, identify device identity, and ensure device security. We collect this information for the binding of your device; otherwise, the device cannot be bound to UGREEN Home.
You can use existing photos in your phone or take photos to set your personalized avatar, for which we will request access to your phone photos or camera. We collect this information based on your consent, and not providing it will allow you to continue using the default avatar without affecting your use of other functions.
We will collect your custom nickname to showcase your personal style and preferences.
We will collect and display your device name so that you can understand and manage your device information. You can view and modify the device name.
You can select or switch your country/region on the login page. If the two countries/regions you switch between share the same server, your bound devices and data will remain on the original server after switching. If the two countries/regions you switch between do not share the same server, your bound devices and data will remain on the original server before switching, and you will need to reregister your account and bind devices after switching. We will remind you when you switch countries/regions.
During use, we may request system permissions from your phone. You can click on the "System Permission List" to view the permissions requested by each function. We will only request the permission when you touch the corresponding function and will inform you of the purpose of use before or during the request. You can choose whether to authorize it. At the same time, you can click your avatar and choose "Personal Center > Personal Information Protection > System Permission Management" to view the permissions you have opened and click to jump to the phone "Settings" to change the authorization.
When you share your device with others or accept devices shared by others, you will share information with each other. For details, please refer to "How We Collect and Use Your Personal Data - Device Sharing and Reception."
To ensure the stable operation of UGREEN Home and enable you to use and enjoy more services and functions, we embed third-party SDKs in the application. Your personal data will be handled by SDKs as follows:
In addition, we will not share your personal data with third parties (except with your consent).
In addition to the legal bases already explained in "1. How We Collect and Use Your Personal Data," we may also process your personal data in the following cases without obtaining your consent:
We will store your personal data for the shortest period necessary to achieve the purposes stated in this privacy policy. After achieving the purposes stated in this policy, after we terminate the service, after you withdraw your consent to this policy, or after you cancel your account, we will delete your personal data. For specific content, please refer to "Your Rights - Cancel Your Account or Request Deletion of Your Personal Data."
We have set up servers in mainland China, Germany, the United States, and Japan. The personal data collected and generated by us in mainland China will be stored in the People's Republic of China. Personal data collected outside mainland China will be stored on servers closer to your local area. For information on data cross-border transfers, please refer to the following section.
We have multiple servers worldwide, and your personal data will be stored on servers closer to you for your quick access to your account information. Data on each server is not shared, which is why you need to re-register your account when switching countries or regions.
Our operational and maintenance team comes from our Chinese company, LULIAN GROUP LIMITED. To assist you in managing your account, devices, after-sales, and maintenance issues encountered during the use of the app, our Chinese employees may access the personal data as stated in "1. How We Collect and Use Your Personal Data". We have taken a series of measures to protect the security of your personal data, including implementing data protection impact assessments and signing SCCs as required by applicable laws. We also strictly limit the purposes for which your personal data can be used, only for operational and maintenance purposes. We strictly limit access to data by position and restrict the data accessed by each position to the minimum necessary for the responsibilities of that position. Additionally, for specific types of data such as your registered email, we have implemented measures to make it "available but not visible".
If you need to inquire further about the SCCs we have signed, please feel free to contact us via support@ugreen.com.
We attach great importance to the security of your personal data. To ensure the security of your personal data, we have taken technical measures such as encrypted transmission and secure storage. We have implemented a data security management system and ensured that our relevant employees receive personal data protection training.
We fully recognize that there is no flawless system. Therefore, we continuously strive to identify and manage potential risks, take preventive measures to reduce the risks of your personal data being disclosed, lost, tampered with, or accessed without authorization. In the event of a security incident, we will follow clear procedures and response mechanisms for handling, including taking timely remedial measures, notifying regulators and affected users, and taking measures to prevent similar incidents from occurring.
Please understand that despite our reasonable technical and managerial measures and compliance with relevant legal requirements, you should take active measures to ensure the security of personal data, such as setting complex passwords, regularly changing account passwords, etc., and do not disclose account password information to others.
For your personal information, you have the following rights:
We provide the following ways for you to exercise your rights:
You can check your avatar, nickname, and account by following the path of "clicking on the avatar > personal information > clicking on the avatar info box". For inquiries about other personal information, you can contact us via the email address provided at the end of this policy.
If you find that your personal information is incorrect or incomplete, you can contact us via the email address provided at the end of this policy.
Subject to the conditions required by applicable laws and regulations, you have the right to transfer your personal information to a designated third party. You can contact us using the information provided in the "How to Contact Us" section of this policy to exercise your rights.
You can click your avatar and choose "Personal Center > Personal Data Protection > System Permission Management" to jump to the "Settings" page of your phone to change the system permissions you have authorized. You can also click on "clicking on the avatar > Personal Information Protection > Withdraw Consent" to withdraw your consent to this privacy policy. Please be advised that doing so will result in your logout, and we will no longer collect or use your personal information. However, this withdrawal will not retroactively affect any previous processing of your personal information that was based on your prior consent. All devices previously associated with your account will be disassociated from it, and all data stored on the server side for these devices will be permanently deleted and cannot be recovered. If you need to manage devices under this account again, you will need to re-authorize and bind them.
You can cancel your account by clicking your avatar and choosing "Personal Center > Account Security". Before canceling, we will verify your identity. We will delete your personal information within 15 days after you submit the cancellation request. If you log in or use the account again within 15 days, it will be deemed that you have revoked the cancellation request.
If you have other deletion requests, you can contact us using the contact information provided in the "How to Contact Us" section of this policy.
Please note that after canceling your account, withdrawing consent, or exercising the right to deletion, not all of your personal information will be deleted. We will only delete it when the conditions for deletion specified by law are met. Situations in which deletion may not occur include (1) not reaching the minimum statutory retention period; (2) when deletion of personal information is technically difficult (such as when your data is archived in the backup system, but we will stop processing other than storage and take necessary security measures until it is anonymized or deleted).
The application currently does not use automated decision-making technology.
Direct marketing refers to commercial entities sending commercial information directly to you by means such as mail, telephone, or sending brochures. We will not send you direct marketing information without your consent. After receiving direct marketing information, you can also unsubscribe, opt-out, or refuse according to the content prompted by the information.
If you are dissatisfied with our handling of your above requests or our processing activities, you may contact us for negotiation first, and you have the right to complain to the regulatory authority or file a lawsuit in a court with jurisdiction. To obtain complaint channels in different countries or regions, you can contact us using the contact information provided at the end of this policy.
When you exercise these rights with us, to prevent identity theft, we will promptly accept and process your requests after verifying your identity. You can also request us to explain the contents of this policy through this email.
If you, as a close relative of the deceased, request to inquire, copy, correct, or delete personal information of the deceased, depending on the actual situation, you need to provide identity documents, death certificates of the deceased, proof of your relationship with the deceased, and other materials. We will only use this information to verify your identity and process your request, and will not process any other personal information.
We will respond to your request within the time limit stipulated by law. If the information requested by you exceeds a reasonable range, requires excessive technical means (such as developing a new system or fundamentally changing existing practices), may harm the legitimate rights and interests of others, or is very impractical (such as requiring information stored on backup tapes to be extracted), we may refuse to fulfill your request in accordance with legal requirements and explain the reasons.
This application does not offer services to children, whose age is defined in accordance with respective local laws, typically referring to minors under the age of 13 to 16. Should you find that your child has disclosed personal information to us, kindly reach out to us via the email address provided at the conclusion of this document to request for its removal.
We may update this policy from time to time. When the updated policy is released, we will provide a prompt within the application, and you can also view the updated content by clicking your avatar and choosing "Personal Center > Personal Information Protection > View Privacy Policy". If the update is a material change, we will also notify you through the official website, official blog, community forum, email, or push notification. By continuing to use our services, you agree to be bound by the updated policy.
If you have any questions, comments, or suggestions about this policy or our privacy practices, or if you need to exercise your rights related to personal information protection, you can contact us through the following methods:
Email: support@ugreen.com
Address: Mannheimer Str.13, 30880 Laatzen
Ugreen Group GmbH reserves the right to interpret and modify this policy to the extent permitted by law.
If you are located in California, the provisions in this section supplement those in this Policy.
The California Consumer Privacy Act of 2018 and the California Privacy Rights Act (CPRA), as amended, along with their implementing regulations (collectively referred to as the "CCPA"), grant California residents specific rights regarding their personal information. This section details your rights under the CCPA and how to exercise them.
1. Your Personal Information Rights
(1) Right to Know of the Collection, Disclosure, and Sale of Your Personal Information: California residents are entitled to request that a business collecting their personal information disclose the following:You are entitled to submit up to two free, verifiable consumer access or data portability requests to us within a 12-month period.
2. Right to Request the Deletion of Personal Information
California residents are entitled to request businesses delete any personal information they have collected, subject to exceptions as outlined in the CCPA. We will provide a clear basis for any denied requests for deletion.
3. Right to Limit Use of Sensitive Personal Information:
You have the right to limit the use of your sensitive personal information for any purpose, except as provided under Section 7027 (m) of the CCPA.4. Right to Opt-Out of the Sale of Personal Information:
We do not, nor have we in the past 12 months, sold any personal information we have collected.5. Right to Non-Discrimination:
UGREEN will not discriminate against individuals exercising their rights under the CCPA.These rights are not absolute, and in some cases, we may be legally required or permitted not to fulfill your request.
If you are under 18 years of age and have a registered account, you may request that we remove content or information that you have posted on the Site or stored on our servers by submitting a written request as indicated in the "CONTACT INFORMATION" section below and clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.
This section applies only to individuals who access or use our Services while located in the European Economic Area.
The controller for the processing described in this Privacy Policy is Ugreen Group GmbH. You can contact our Data Protection Officer or DATAREP at [support@ugreen.com].
In addition to the rights mentioned in the main text, you also have the right to restriction of processing.
We may process your personal information on the lawfulness without your consent:
processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms. We also may extend the period for which we retain your personal data for public interest, scientific, historical research, or statistical purposes.
We will protect your personal data in accordance with the Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect the personal data concerned in accordance with applicable laws. These steps include implementing the European Commission's Standard Contractual Clauses for the transfer of personal data to our service providers and business partners located in countries that are not considered by the EU to provide an adequate level of data protection.
In addition to the rights in the main text, Ugreen Group GmbH is the controller of your personal information, personal related information, pseudonymized personal information, and anonymized information. You can require us to stop using your personal information in the case of meeting the Japanese laws and regulations, and if your personal information is transferred out of the country, we will obtain your consent in advance (except for the country or other regions such as the European Union and the United Kingdom, etc., which have obtained the recognition).