HomeTouch LH Privacy Policy

Last updated: November 24, 2022

Thank you for your trust and support in HomeTouch LH. We (Land&Houses.) understand the importance of your personal information, so we will take appropriate measures to protect your personal data. This Policy describes how we collect, use, and handle your personal information when you use our websites, software, and service (collectively, "Service").

By using HomeTouch LH service, you consent to the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Terms of Use for the HomeTouch LH Products and Services you use.

Information We Collect

Types of information collected

In order to provide our services to you we will ask you for personal information that is necessary for us to successfully provide those services. If you do not provide us with this personal information, we may not be able to provide our products or services to you.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes. We may collect the following types of information (which may or may not be personal information):

1. Information You Provide

• Account Information: When you are interacting with our products, before we further collect the nickname, country code, language preference, timezone and other personal sensitive data in your account, we will get your consent via your clicking "agree" button through explicit popup messages.
• Feedback: When you submit feedback to get customer support for our service, you will provide us with information related to your use of our service, including your email address, mobile phone number, and your feedback content so we can provide you customer support.

2. Automatically Collected Information

• Device Information: When you install, access, or use our service, we automatically collect device-specific information, such as the MAC address of your devices, IP address, wireless connection information, operating system type, and version, application version number, mobile application list, push notification identifier, log files, and mobile network information.
• Usage and Log Information: Through your usage of HomeTouch LH service, we automatically collect your activity on our website or our service, service-related information, diagnosis, performance information, log files, crash report, website visits, clicks, downloads, and other information generated by using our service.
• Location Information: To ensure the normal function of our service, such as the sunrise/sunset, we will collect information about your real-time geolocation.

• Camera information: The camera information we collect will be used to allow you to scan the QR code to add the devices you purchased, or take videos.

• Access to the album: required for uploading pictures to submit user feedback, changing the user's profile photo/picture, Upload pictures to smart device as a wallpaper , etc.

• Use the microphone: use the microphone for features e.g. two-way calls. To achieve that, we will collect your voice information to identify your voice commands.

• Directly used SDK :Umeng SDKCollected personal data type: device information(IMEI/Mac/android ID/IDFA/OPENUDID/GUID/SIM card  IMSI data)Privacy Policy url:https://www.umeng.com/page/policy
• Software Installment List Info: The type of personal information collected by Bugly SDK: Software Installment List Information, and it will be uploaded to http://android.bugly.qq.com. Since our software is multi-process, we reserve the right to collect your software installment list information in the backend so that we can capture the log of the software crash in the event of your software crash.

3. Information We Collect Automatically

• Mobile Device Information: When you interact with our Services, in order to provide and maintain the common operation of our Services, improve and optimize our Service, and protect your account security as well, we automatically collect mobile device information, such as mobile device model number, IP address, wireless connection information, the type and version of the operating system, application version number, push notification identifier, log files, and mobile network information. Meanwhile, we will collect your software version number. In order to ensure the security of the operating environment or to provide services, we will collect information about the installed mobile applications and other software you use.

• Usage Data: During your interaction with our websites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our websites and Services.

• Log Information: When you use the App, in order to improve your user experience, the system and exception log may be uploaded, including your IP address, preference language setting, operating system version, date or time of access, so that we can facilitate and accurately identify problems and help you solve them in timely manner.

Please note :that one cannot identify a specific individual by using device information or log information alone. However, if these types of non-personal information, combined with other information, may be used to identify a specific individual, such  information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will aggregate or desensitize such information.

3) Smart Devices Related Information:

When you use a Smart device, we will collect some basic and pre-embedded information of the Smart Device and the information generated during your use of the Smart Device.

• Basic Information of Smart Devices: When you connect your Smart Devices with the Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

• Information collected during the process of connecting to a Smart Device: Based on the type of Smart Device you need to connect, the basic information collected includes:

• Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device Mac address;

• After establishing a local connection via Bluetooth, Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device Mac address;

• Smart Devices connected via Bluetooth: device Mac address;
• Smart Devices connected via ZigBee: device Mac address.

• Information Reported by Smart Devices: Depending on the different Smart Devices you select to connect with the Services, we may collect different information reported by your Smart Devices. The following information reported by the Smart Device only applies when you use them:

• When you voluntarily use a smart camera (IPC service) and connect to the HomeTouch LH platform: When you connect a doorbell camera, a door lock, or a smart surveillance camera through HomeTouch LH service to monitor the security of your residence, during the process, the device may capture the images if it recognizes someone or an object is moving around, and then provide you a playback of related surveillance content. At this time, we will automatically encrypt the captured image and save it locally on the device. When you actively choose and successfully purchase cloud storage service, the smart camera will upload the pictures or video files you have taken to the cloud for further storage so that you can review them on the App. We will keep your information based on the cloud storage service you purchase. When you choose to delete the picture in advance in the ORVIBO Home App, you can delete it in the message center and if you need to delete a video on the App, the cloud will respond to delete immediately the video files you stored in the cloud service.

2. Purposes and Legal Basis for Processing Personal Data

• Provide You Services: We process your account data, mobile device information, usage data, location information, and Smart Device related information to provide you with the Services and Services that you have requested. The legal basis for this processing is to perform our contract with you according to our User Agreement.

• Improve Our Services: We process your mobile device information, usage data, location information and Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services, to analyze the efficiency of our operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our User Agreement.
• Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. 
• Data Analysis: In order to analyze the usage of the products we provide and improve your user experience, we will analyze the data you provide us, a) we need to check your problems when you encounter any malfunctions during the usage of the product, under such circumstance, you may not able to opt-out because it is highly relate to your functionalities and quality of using our product and service, and b) analyze data about how you interface with the product or under particular scenarios so that you can better enjoy the convenience brought by our Services.
• Marketing Communication and Personalization: We may process your account data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of the Services.

• Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

• enforce our Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof;
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law;
• detect, prevent or otherwise address security, fraud or technical issues.

If there is any change in the purposes for processing your Personal Data, we will inform such change to you with a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

With whom we share your information?

We do not sell any personal information to third parties.

We do not share your personal information to third parties.

Sharing of information with others

HomeTouch LH may disclose your personal information to others without further consent when required under applicable law.

Information not requiring consent

• We may share anonymized information in aggregate form with third parties (such as advertisers on our website) for commercial purposes. We may share trends in common usage of our services, for example, the number of customers in a particular group who purchase certain products or engage in certain transactions.
• For the avoidance of doubt, HomeTouch LH 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 (to, for example, comply with a subpoena). We may also disclose your information without your consent if we believe in good faith that it must be disclosed in order to protect our rights, your safety, or the safety of others; investigate fraud; or respond to government requests.

Security commitment

HomeTouch LH's security measures

We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure, or other similar risks, we havewe have put in place reasonable physical, electronic, and managerial procedures to protect the information We collect from you during your use of the HomeTouch LH app. We will take all appropriate measures to protect your personal information.

For example, when you access your HomeTouch LH account, you can choose to use our two-step verification program for better security. When you send information to our home server from your HomeTouch LH device or receive information through the same channel, we make sure that it is encrypted using a number of protocols including Secure Sockets Layer (SSL).

All of your personal information is stored on secure servers and protected in controlled facilities. We classify your data based on importance and sensitivity, and we guarantee that your personal information is always protected by the highest level of security. We also guarantee that employees and third-party service providers who provide products and services to you by accessing this information will be held under strict contractual confidentiality obligationsand may be disciplined or terminated if they fail to meet such obligations. Similarly, we have special access control measures for cloud-based data storage. In summary, we regularly review our information collection, storage, and processing practices, including physical security measures taken in order to prevent any unauthorized access and use.

We will take all practicable steps to protect your personal information. You should, however, be aware that the use of the Internet is not entirely secure, and for this reason. Because of this, we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

We will take upon the personal data breach, notifying the breach to relevant supervisory authority or under some circumstances, notifying the personal data breach to the data subjects by complying with applicable laws, including your local data protection legislation.

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 When you log into HomeTouch LH as a HomeTouch LH account user, no matter when, and especially if you are using another person's computer or a public Internet portal, you should always log out at the end of the session.
• HomeTouch LH 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 immediately notify us if any online users access your account without permission or if any other security breaches occur.

Your assistance will help us better protect your personal information.

Retention policy

We retain information we collect about you as long as it is still needed for the purposes we obtained it or as long as it is needed to comply with applicable legal requirements or permissions. 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 HomeTouch LH even if the further processing is incompatible with original purposes.

Accessing other features on your device

Our application may need to access certain features on your device, for example, Wi-Fi network status. This information is necessary for these applications to be able to run on your device and for you to be able to interact with them. You can close the application on your device at any time, or you can contact us at lhdevapp@gmail.com to revoke your consent.

You have control over your personal information

Control settings

HomeTouch LH knows that everyone has different concerns about privacy. Therefore, We have provided some examples of the various ways in which HomeTouch LH allows you torestrict the collection, use, disclosure, and processing of your personal information, in addition to ways in which you can control your privacy settings:

• Turn on or turn off the user experience planning and location access features;
• Log into or log out of your HomeTouch LH account:
• If you previously agreed to let us use your personal information for the purposes described above, you can change your decision at any time by writing us a letter or sending an email to lhdevapp@gmail.com.

Access , update, correct, erase or restrict processing your persona information

• You have the right to request access to and/or to correct any personal information we hold about you. When you update your personal information, you will be asked to verify your identity before your request is processed. Once we have a sufficient amount of information, we will be able to process your request to either access or make corrections to personal information. We will respond to your request within the time period specified by applicable data protection law.
• A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
• 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, please write to or email us as soon as possible at the email address below. Email: lhdevapp@gmail.com.
• If you are a Europe Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.
• If you are a Europe Union user under GDPR, you have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
• If you are a Europe Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• If you are a Europe Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.
• More details about the personal information in your HomeTouch LH Account can be accessed or changed by using your device to log into your account.

Withdrawal of consent

• You can submit a request by sending an email to lhdevapp@gmail.com, in which you can request to withdraw your consent for us to collect, use and/or disclose any of your personal information that we hold or control. We will process your submission within a reasonable amount time, after which, we will abide by your request and no longer collect, use, and/or disclose your personal information.
• Please recognize that your withdrawal of consent may result in some 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 HomeTouch LH products or services.

Transfer of personal information outside of your jurisdiction

To the extent that we need to transfer personal information outside your jurisdiction, whether it is transferred to our affiliates (these may include communications, social media, technology, or cloud services) or to third-party service providers,we shall do so in accordance with the applicable laws. In particular, in order to ensure that all such transfers comply with applicable local data protection law, we will implement appropriate security safeguards. You will have the right to be informed of the appropriate safeguards taken by Us for this transfer of your personal information. For example, if you choose to use other third-party services available for this product or service (such as Amazon Alexa, Google Assistant, etc.), those third parties may be able to read information about you, information about you may also be transferred to a third-party server outside of your jurisdiction, and you agree to this kind of transfer.

HomeTouch LH is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal data to any subsidiary of the HomeTouch LH group worldwide when processing that information for the purposes described in this Privacy Policy. We may also transfer your personal data to our third party service providers, who may be located in a country or area outside the area of the European Economic Area (EEA).

Whenever HomeTouch LH shares personal data originating in the EEA with a third party which may or may not be a HomeTouch LH entity outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.

HomeTouch LH may use overseas facilities operated and controlled by HomeTouch LH to process or back up your personal information. HomeTouch LH currently has data centers in Beijing, the United States, Russia , Singapore, and Germany. These overseas jurisdictions may or may not have data protection laws similar to the data protection laws in your jurisdiction. We may transfer and store your personal information in one of our overseas facilities; however, this does not change our full commitment to protecting your personal information in compliance with this Privacy Policy.

Miscellaneous

Minors

• We believe that it is the responsibility of parents to monitor their children when using our products and services. Our policy, however, does not require us to obtain the personal information of minors or to send any promotional materials to these kinds of people.
• HomeTouch LH will not seek or attempt to seek out any way to obtain personal information from a minor. If parents or guardians have reason to believe that a minor has provided personal information to HomeTouch LH without their prior consent, they should contact us to ensure that such personal information is removed and that subscriptions the minor may have for any applicable HomeTouch LH services are canceled.

Order of priority

If you agree to an applicable user agreement, and if there is any inconsistency between the user agreement and this Privacy Policy, the user agreement will prevail.

Privacy Policy updates

We periodically review our Privacy Policy, and we may update it to reflect changes in our information practices. If we make a substantial change to this Privacy Policy, We will notify you by email (using the email address specified in your account), by releasing a notice in the HomeTouch LH app, or by contacting you via your mobile device. This will allow you to understand what information we collect and how we use it. These kinds of changes to this Privacy Policy will be effective starting on the date specified in the notice or on the website. We recommend that you visit this page regularly for the latest information on our privacy practices. Your continued use of products and of website, cell phone and/or any other device-based services will be deemed as your acceptance of the updated Privacy Policy. If we collect additional personal information from you, or if We wish to use or reveal your personal information for a new purpose, We will once again seek your consent.

Do I have to agree to all terms and conditions of third parties?

Our Privacy Policy does not apply to products and services provided by third parties. HomeTouch LH 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, they may also collect your information. Because of this, we strongly urge you to spend time reading the privacy policies of these third parties, just as you have read ours. We do not take any responsibility for the way in which third parties use the personal information they collect from you, nor do we have any control over how they use it. Our Privacy Policy does not apply to other websites whose links can be accessed through our services.

When you use these extension services for specific products on the HomeTouch LH portal, the terms of the third party and the Privacy Policy of the third party both apply, and you are considered to have agreed to the terms of each of these extensions.

About our systematic approach to manage your personal information

If you are Europe Union user under GDPR, HomeTouch LH will provide systematic approach to manage personal data deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) HomeTouch LH set up a Data Protection Officer (DPO) in charge the data protection, and the contact of DPO is dpo@zhijiacloud.com; (2) procedure like data protection impact assessment (DPIA).

Contact us

If you have any questions or feedback regarding this Privacy Policy, or if you have any questions regarding HomeTouch LH's collection, use, or disclosure of your personal information, please contact our Data Protection Officer at the address listed below and mention that your message is in reference to the "Privacy Policy":

Land&Houses.

Q. House Lumpini Building Fl. 37-38 ,1 South Satorn Rd. Tungmahamek , Sathon , Bangkok 10210

Bangkok 10210

Email: lhdevapp@gmail.com

Thank you for taking the time to familiarize yourself with our Privacy Policy!

What's new to you

We have made several major edits throughout the Privacy Policy as following:

• By complying with GDPR and providing better data privacy protection, we updated the relevant content about users' rights under GDPR, and how we process the personal information for Europe Union users. We also described our data privacy management method additionally.