This Privacy Policy (hereinafter referred to as "Policy") is applicable to the products and/or services of smart device control and management services provided to you by Shenzhen Intellirocks Tech Co., Ltd. and Govee Moments Trading Limited (hereinafter collectively referred to as "we/us/our") and also explains how your personal information is collected, used, shared and processed when you access Govee Home or use other services provided by Govee Home operators, including any written or electronic communications and purchases performed (collectively referred to as "services"), as well as the rights and choices you have associated with that information.

The company responsible for selling products and providing services through Govee Home (and therefore the payment collection entity) is Govee Moments Trading Limited,19H Maxgrand Plaza, No.3 Tai Yau Street, San Po Kong, Kowloon Hong Kong SAR.Therefore, the terms "we/us/our", "Intellirocks" and "Govee" refer to different entities, where "we/us/our" refers to Shenzhen Intellirocks Tech Co., Ltd. and Govee Moments Trading Limited, while "Intellirocks" refers to Shenzhen Intellirocks Tech Co., Ltd. and "Govee" refers to Govee Moments Trading Limited.

Please read this Policy carefully and make sure that you understand our rules for processing your personal information before accessing Govee Home or using our products or services. If you have any doubts, comments or suggestions during reading, please contact us at support@govee.com. If you disagree with any part of the User Agreement or this Policy, please stop accessing or using our services. By continuously accessing Govee Home or using our services, you accept our User Agreement and Privacy Policy.

Introduction

Welcome to Govee Home! When you use our products and/or services, we may collect and use information about you. We attach great importance to the protection of users' privacy and personal information. we also know very well the importance of personal information to you and we will spare no efforts to keep your personal information safe and reliable. We therefore pledge:

I) We will be transparent about the different types of information that we collect and how we use it.

II) Except at your request or for the provision of Govee Home services, we will seek your permission before sharing your personal information with third parties and will only do so when we are confident that they will provide you with additional services that are favored.

III) We will use state-of-the-art data security tools to secure your data security and protect Govee Home products from unauthorized access.

Through this Policy, we intend to explain to you how we collect, use, save, share and transfer such information when you use our products and/or services and the methods we provide you to access, update, delete and protect such information. This Privacy Policy will help you understand the following:

1. How do we collect and use your personal information?
2. Device permission call
3. Sharing of information
4. Security and storage of information
5. Your rights as data subject
6. Cookies and similar tracking technologies
7. Other matters to be prompted involving the interests of users and disclaimers
8. Policy update
9. Contact us

1. How do we collect and use your personal information?

Personal information refers to various information recorded electronically or otherwise, which can be used to identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information, excluding information that has been anonymized.

The definition of personal information (which may be used interchangeably with the term "personal data" herein) depends on your place of residence. Pursuant to this Privacy Policy, only the definitions applicable in your country of residence apply to you.

In accordance with the principles of legitimacy, legality and necessity, we will only collect and use your personal information voluntarily provided by you during or arising from your use of products and/or services, as well as your relevant personal information obtained from third parties for the following purposes set forth herein. If we intend to use your personal information for other purposes not set forth herein or use information collected for specific purposes for other purposes, we will inform you in a reasonable manner and seek your consent again before use.

1.1 To provide you with the following core functional services

(1) Account registration, login and authentication

In order to use the Govee Home services and manage smart devices, we need to collect the following information about you: your Govee Home account username, E-mail, login password, nickname and avatar. Among the information collected, your Govee Home account username, E-mail and passwords are sensitive personal information and the purpose of collecting such information is to log into the Govee Home account server to authenticate the user identity and obtain the permission of the Govee Home App to access the server.

We will use your personal information as follows: the Govee Home account username and login password authentication information you entered will be encrypted and transmitted to the Govee Home account server for login authentication, which will not be stored locally by the App and on the server.

If you do not provide such information or are not logged into your Govee Home account, you will not be able to use certain Govee Home services. After logging into the Govee Home account, the Govee Home App will automatically obtain the nickname and avatar of the account and display them on the App page.

(2) Smart device management services

In order to realize the functions of smart device binding, controlling and managing devices, we need to collect the following information about you: device name, model, version, device identifier, MAC address, device running status, custom attributes, parameters setting, business events and device control and usage records. The purpose of collecting such information is to bind smart devices, control and manage them, set device attributes and parameters, view device working status and historical records, conduct statistics, review and research on devices and service operation status, and improve the quality and service of smart devices. The above information will be encrypted and saved to the server, and the Govee Home App will query the data from the server upon your authorization and display the same on the device page.

In order to discover smart devices with wifi and connect them to the WLAN network, the Govee Home App needs access to mobile phone location permission, acquire the WLAN list and the WLAN network identifier and WLAN password that you enter. Among other things, WLAN passwords are personal sensitive information and the purpose of collecting such information is to discover smart devices around you and connect them to the WLAN network. The above information is only used locally and will not be uploaded to the server.

If you do not provide such information, you will not be able to use the device discovery, binding, control and management functions of the Govee Home App.

(3) Display and search of goods/services information

In order to display goods or services to you, we will collect your device information (including the device name, device model, MAC address and IMEI, device identifier, software and hardware feature information such as mobile application list, operating system and application versions, language setting, resolution, service provider network ID (PLMN), device location-related information (including your authorized GPS location information, WLAN access point, Bluetooth and base station sensor information) and browser type to sort the appropriate goods or services to fit your device interface.

Failure to provide such information may reduce your experience with the Govee Home app.

In order to provide you with services such as search history, browsing records, favorite goods, shopping cart or order goods or services display, we will collect your browsing information, search records, favorite records, follow records, addition to shopping cart and order information.

(4) Order fulfillment or processing

When you settle the items in your shopping cart at Govee Home, Govee Home will generate an order for the goods you purchased. In order to complete the delivery, return, refund, sales tax determination and payment operations of the corresponding goods/services, we need to collect the following information about you:

I) Your identity and contact information, such as name, telephone number and delivery address, as well as financial information or payment account information for delivery, return, refund, sales tax determination and payment operations;

II) Transaction details in our services, such as return and refund details, gift card numbers and order history, to perform basic functions, including processing your payment and return requests, as well as keeping you informed of order status and transportation logistics;

III) IP address level location data, to customize your experience based on the appropriately displayed local website, language or user experience;

IV) Invoice header, taxpayer identification number and email address for receiving the invoice, if you need an invoice.

If you don't provide such information, you won't be able to use the goods purchase function of Govee Home.

(5) Problem feedback and quick exchange

To enable feedback on Govee Home service problems, we need to collect the following information about you: log information of apps and devices, contact information and problem description of your feedback, your communication history with us, your account information and order information, problem pictures and videos. Among other things, the log information of apps and devices will include device status, information perceived by sensor devices, device operation records, device identifiers, etc., where the purpose of collecting such information is to analyze and locate the cause of problems; the purpose of collecting your contact information is to exchange and deliver products quickly and provide after-sales service for you quickly. You are expected to supplement other necessary information, such as the warranty starting and ending period of purchased goods, the courier company for returning and exchanging goods, the courier number, the return address and the delivery time.

We will use your personal information as follows: only for the positioning and solution of feedback problem or for quick exchange, not for displaying personal information, and not for pushing commercial advertisements.

If you do not provide such information, it will not be possible to effectively locate the problems you feedback, and you will not be able to solve the problem and enjoy the quick exchange service.

1.2 To provide you with the following add-on services

Services that provide add-ons for implementing the Govee Home App, including: Savvy User Business Operations, Community, Savvy User Points. We need to collect the following information about you: device identifier, user identifier, device type, model and manufacturer, mobile device operating system and model.

If you win a prize, participate in a trial or redeem a physical item, you need to enter your name, address, email and other information to complete the goods delivery and your data will be saved in the Govee Home server.

In order to deliver physical goods to you, we need to provide your contact information to third party logistics providers. Third-party logistics providers are subject to contractual and technical requirements to protect personal data and prohibit any use of personal data for any purpose other than logistics services or those required by law.

If you do not provide such information, you will not be able to use the add-ons of Govee Home normally.

1.3 Service guarantee and optimization

To support continuous improvement, research, development and testing of new services and functions, and to perform troubleshooting activities, we collect additional information in the following ways:

We use Flurry Analytics (www.flurry.com), a third-party data analysis service, to collect information, such as the functions used by users, the results of operations, the time, frequency and duration of users' online activities, crash logs, etc. The analysis service generally does not identify individual users.

We collect information through questionnaires, voting and other activities, such as users' preference for the appearance of a device, their preference for functions and device installation locations. Participation in questionnaires and voting is voluntary. Questionnaires, voting and other activities generally do not identify individual users.

2. Device permission call

Location permission: In order to enable the networking between the Govee Home App and smart devices, we need to obtain the WLAN list and Bluetooth device list of the system. According to the Android system permission application principle, it is required to obtain your location permission to read the WLAN list and Bluetooth device list; In order to enable the real-time broadcast information receiving function of some devices (such as H5055), it is required to obtain your location permission to read the broadcast data and parse out the data collected by sensors.

Camera permission: in order to enable in Govee Home the functions of using camera color selection, intelligent color selection, problem feedback, quick exchange, posting in the community, participating in activities, etc., you need to choose to turn on this permission for taking pictures, taking videos and other functions.

Mic permission: In order to enable in Govee Home the Mic mode function provided for some devices (such as H6001, H7001, etc.) and the call function and the voice recording function in video shooting for problem feedback, quick exchange, posting in the community and participating activities in some devices such as H7205, H7212, etc., you need to choose to turn on this permission.

Storage permission: In order to enable in Govee Home the functions of using camera color selection, intelligent color selection, problem feedback, quick exchange, posting in the community, participating in activities, etc., you need to choose to turn on this permission for reading files stored on the device.

Background location permission: Govee Home will only request the background location permission when there is a Meat Thermometer device in your device list. With your consent, Govee Home will be able to obtain temperature alert information and alert you in time to the temperature of your meat.

In addition to the above permissions, it is required to turn on Bluetooth when using a device with Bluetooth, otherwise it will be unable to connect to the device. You can turn off Bluetooth through the system "Settings."

You can manage these permissions by accessing the system “Settings”.

3 Sharing of information

We may share your personal information with the following types of third-party service providers. We strive to ensure that our third-party service providers will only use your data for the purposes for which they are provided in compliance with our written instructions and control such use to the extent necessary.

3.1 Data sharing for management capacities of single devices provided by you to third-party service platforms

When you bind a Govee Home account on a third-party service platform (Alexa, Google Home) and authorize the third-party service platform to manage smart devices, we need to provide the platform with the following information about you: device identifier, device hardware information, device running status, custom attributes, setting parameters, business events and device controls. Personal information provided to third-party service platform is governed by its privacy policy, where reference is made to the privacy policy of the third-party service platform; besides, before using the function, you are required to acknowledge that you have read and agreed to the user agreement and related privacy policies of the third-party eco-service platform. Your refusal to provide such information will prevent you from using the above third-party services properly, but will not affect your use of other functions of Govee Home.

3.2 Data sharing within a Govee Home-based organization

Govee is part of a corporate organization with multiple legal entities, business processes, management structures, and technical systems. We may share your personal information with our associated group companies and, in some cases, with other affiliates of our corporate group for purposes of business maintenance and personalization continuity. We will ensure that your data is only used for the purposes for which the data are provided to them and control such use to the extent necessary.

3.3 Data sharing for order payment

After you place an order, you can choose the payment services provided by third-party payment institutions that cooperate with Govee Home (including payment channels such as UnionPay and NUCC, hereinafter referred to as "payment institutions"). We need to share your order number and transaction amount information and other personal information on Govee Home with these payment institutions and online trading anti-fraud service providers we are collaborating with to complete the ordering and payment functions. When you use the payment function, the payment institutions and online trading anti-fraud service providers we are collaborating with will collect or verify your bank card (including savings card and credit card) and other necessary payment and verification-related personal information through their pages, so as to confirm your payment instructions and complete the payments, in which case the appropriate privacy policy of each payment institution and online trading anti-fraud service providers shall apply specifically. Your refusal to provide such information will prevent you from completing the order payment, but will not affect your use of other functions of Govee Home.

3.4 Data sharing for product Logistics

After you place an order and complete the payment, or choose to obtain trial products and prizes, Govee Home, its affiliated parties and the third-party warehousing/logistics/distribution companies cooperating with Govee Home (hereinafter referred to as "distribution companies") will complete the delivery of the order for you. You acknowledge and agree that Govee Home, its affiliated parties and the third-party warehousing/logistics/distribution companies cooperating with Govee Home will use your order information in the above links to ensure the safe delivery of the goods you ordered. Your refusal to provide such information will prevent you from receiving the product successfully, but will not affect your use of other functions of Govee Home.

3.5 Data sharing for IT systems and software services

Govee Home may share your personal data with IT systems and software providers cooperating with Govee Home due to reasons such as using Web hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, and E-mail service provision or system maintenance services. Your refusal to provide such information will hinder the normal functionality of Govee Home.

3.6 Data sharing for legal reasons

We may share personal data as required to: (I) comply with applicable laws or responding to, investigate or participate in effective legal proceedings and lawsuits, including those of law enforcement or government agencies; (II) execute or investigate potential violations of its terms of service or policies; (III) detect, prevent or investigate potential fraud, abuse or security concerns, including threats to the public; (IV) fulfill our commitments to corporate and social responsibility; (V) protect our rights and property and those of our clients; (VI) resolve disputes and perform agreements.

3.7 Data sharing for corporate transactions

In case of merger, divestiture, reorganization, restructuring, dissolution or sale or transfer of certain assets, we may disclose personal information (including account information, wallet balance or points information) or all of our assets to buyers, potential buyers, subsidiaries or other successors of the company, whether as a going concern or as part of bankruptcy, liquidation or similar proceedings, the personal information we hold about the users of our services is a transferred asset. You acknowledge and agree to our right to transfer or assign your personal information.

3.8 Data sharing based on your consent

We may disclose your personal information for any purpose with your consent.

4 Security and storage of information

Govee Home cares about the security of your information and adopts physical, administrative, and technical protections to help maintain the integrity and security of all the information we collect and the information we share with service providers. The Internet is not an absolutely secure environment. We strongly recommend that you adopt secure methods and use complex passwords to help us to ensure the security of your account. We also strongly recommend you not to share your password with others, nor to use passwords on our services that you use on other websites or apps, as doing so would increase the likelihood that you become a victim to hacker attack or other malicious network behavior. If you believe that the security of your account or personal data has been compromised, please contact us immediately.

When you access or use our services, your personal data may be processed or transmitted outside your country/region of residence. The data protection laws of such countries or jurisdictions may be different or less protective than the laws of the jurisdiction of your residence in some respects. If you do not wish to have your information transferred for processing or maintenance outside your country or jurisdiction of residence, you should immediately stop accessing or using the services. If you need more details about these transmissions and the protections we use to facilitate such transmissions, please contact us immediately.

In addition, we can't 100% guarantee the security of our system as no security system is impermeable. In case of personal information security incident unfortunately, we will, as required by laws and regulations, inform you of: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions for you to prevent and reduce risks independently, and the remedial measures available to you. We will inform you of the incident by email, SMS, push notification, etc. When it is difficult to inform the subjects of personal information on an individual basis, we will issue an announcement in a reasonable and effective manner. In addition, we will report the disposal of personal information security incidents as required by the regulatory authorities.

5 Your rights as data subject

In accordance with applicable laws, you are entitled to certain rights in relation to personal data, including the right to request for access, correction, modification, deletion, transfer of personal data to other service providers and the right to refuse to have the data used for specific purposes. To make it easier for you to exercise such rights while using the Govee Home App, we provide you with corresponding operation settings in product design and you can refer to the following guidelines for operation.

5.1 Access personal information

You can view the running status and history of the device at any time on the main page of the smart device you have bound, and view the device information on the "Settings" page of the device, including the device name, MAC address, device model and other information;

You can view your personal information at any time by going to "My account" and then clicking on the account avatar and redirecting to "Personal information" page.

5.2 Delete personal information

You can at any time access the "Settings" page of the smart device, delete the smart device you have bound through the "Delete Device" button and clear the device information stored locally by the Govee Home App and on the server;

You can at any time uninstall the Govee Home App, apply for account cancellation or clear the Govee Home App data, to clear the data stored locally by the Govee Home App. In addition, except as otherwise provided by law, relevant personal information shall be deleted or anonymized.

5.3 Update personal information

You can at any time set the device operation parameters and change the device information on the main page of the smart device you have bound and the "Settings" page of the device;

You can go to "My account," click on the account avatar and redirect to the "Personal information" page to change your personal information at any time.

6. Cookies and similar tracking technologies

6.1 Cookies

Cookies are small text files sent to or accessed from your web browser or computer hard drive. Cookies generally contain the domain name (Internet location) from which the cookies originated, the cookie's "life cycle" (i.e., expiration time) and a unique number or similar identifier that is randomly generated. The cookies may also contain information about the device, such as user settings, browsing history, and activities while using the service.

If you clear the cookies, you will be required to change your settings the next time you visit our website. Please note that some of our services require cookies. Disabling cookies may affect your use of some or all functions of these services.

Our service uses the following cookies:

● Strictly necessary cookies, which are necessary for service operation. For example, without them, you will not be able to use your account.

● Analysis/performance cookies, which allow us to identify and count the number of accessors, understand how accessors browse the services and how to improve the services.

● Functional cookies, which we use to identify you when you return to the services.

6.2 Other local storage

We and some third parties may use other local storage technologies, such as local shared objects (also known as "Flash cookies") and HTML5 local storage, in some products and services. Like cookies, these technologies store information on your devices and can record some information about your activities and preferences. However, these technologies may use a different media than those used for cookies. Therefore, you may not be able to control them using standard browser tools and settings.

6.3 Do Not Track

Except as required by law, we do not undertake to comply with the "Do Not Track" signal in your browser, as compliance therewith would prevent most of the tracking and disclosures as described herein.

7. Other matters to be prompted involving the interests of users and disclaimers

Without your prior consent, we have never and will never share, disclose, sell, lease or otherwise provide your personal data to other companies for the promotion of their products or services, except for the sharing of personal information that you authorize us to do so under this Policy, and we have never and will not "sell" your customer information.

7.1 Links to third party websites

Our Apps or websites may contain links redirecting to third-party websites, and this Policy does not apply to these third-party websites. If you click on the links to these websites, please note that these websites have their own privacy policies, and we have no responsibility or obligation for their policies. Before submitting any information to these websites, please check their respective privacy policies. In addition, our websites may include social media functions such as Facebook, Twitter and Pinterest buttons (such as "Like," "Tweet" or "Pin"). These social media sites will automatically record information about your browsing behaviors every time you visit any site with a social media button, whether you click the button or not. Your interactions with these functions are governed by the privacy policy of the company that provides them, not by ours. Please check your privacy settings separately on social media sites.

7.2 Children’s privacy

Our services are not intended for children under the age of 16 or minors (as defined by applicable national laws), nor do we knowingly collect or maintain children's personal information. If you are a minor, please do not attempt to fill out our form or send us any personal information about you. If any minor provides us with children's personal information without the consent of his/her parent or guardian, the parent or guardian shall contact us immediately at support@govee.com to delete the relevant personal information of the minor and cancel the subscription.

If we discover that any minor has provided us with personal information, we will take immediate measures to remove such information from our files. As further described in our User Agreement, please do not upload or display photos of others, especially those of minors.

7.3 Your privacy rights in California

Pursuant to Section 1798.83 of the California Civil Code, California residents are entitled to request from us annually, free of charge, a copy of list of third parties to whom we have disclosed the personally identifiable information (as defined in the Code) of such California residents in the previous year, as well as the categories of personally identifiable information disclosed to such third parties. If you are a California resident and you wish to make such a request, you may contact us at support@govee.com.

7.4 Specific information subject to European data protection

If you are located in EEA, Switzerland or the UK, your rights with respect to our processing of your personal data as a controller include, in particular:

Right to access and/or port: you have the right to access the personal information that we retain about you and, in some cases, may request that such information be made available to you so that you can provide or "port" it to other providers;

Right to delete: under certain circumstances, you have the right to delete the personal data that we retain about you (e.g. such data is no longer necessary for the purpose for which it was originally collected);

Right to object to processing: under certain circumstances, you have the right to demand us to stop processing your personal data and/or stop sending marketing communications to you;

Right to correct: you have the right to demand us to correct any inaccurate or incomplete personal data;

Right to restrict processing: under certain circumstances, you have the right to request us to restrict the processing of your personal data (e.g., you believe that the personal data we retain about you are inaccurate or illegal).

In order to exercise your rights, or in case of any other doubts about our use of your personal data, please send the request to the contact information specified in the "Contact us" section of this Privacy Statement. Please note that we may require you to provide us with additional information in order to confirm your identity and ensure that you have access to relevant personal data.

You also have the right to file a complaint to the data protection agency. For more information, please contact your local data protection agency.

7.5 Third-party transmission of personal data

If any third party is involved during our performance of the contract, they will only receive such personal data to the extent of transmission required by the corresponding services.

If we outsource certain parts of data processing (hereinafter referred to as "order processing"), we will contractually require our order processors to use personal data only in accordance with the data protection law, and guarantee the protection of the rights of the data subjects.

8. Policy update

Govee Home reserves the right to update this Statement in due course. When any change is made to the Statement, we will keep you notified of the changed statement through a pop-up window. We will collect, use and store your personal information according to the updated statement only after obtaining your consent to do so.

We may update this Privacy Policy from time to time. If such change will result in material impairment of your rights under this Privacy Policy, we will prompt you in a prominent position on the page before the change takes effect. In case of any change in the privacy protection guidelines for specific products and services regarding the processing purpose, processing method and types of personal information, your consent will be obtained again.

You have the right to refuse to agree to the update of this Privacy Policy, but you also acknowledge and understand that if you refuse us to collect and process your personal information as necessary to realize the updated services or functions, we may not be able to provide you with the updated services or functions, or achieve the effect of updating the services.

9. Contact us

If you have any doubts or comments about this Policy or our User Agreement, please contact us at support@govee.com.

We will reply as soon as possible upon receipt of your request. Besides, if you think that our processing behavior violates your legitimate rights and interests of privacy and personal information, you have the right to complain and report to the corresponding regulatory authorities.

Last revision date

This Policy was last revised on [21/07/2022] and entered into force thereafter.