Privacy Agreement

Introduction

We value your trust and acknowledge the importance of protecting your personal information. We will collect your personal information as required by laws and regulations within the reasonable and necessary scope. By using reasonable and effective information security technologies and management processes, we protect your information against disclosure, damage, or loss. Therefore, the iBUILDING service provider ("we" or "us") formulates this Privacy Agreement (hereinafter referred to as this "Agreement") and reminds you that:

This Agreement is applicable to all products and services provided to you by us in the form of websites, clients, mini programs, and new forms that emerge with the development of technology. The iBUILDING platform referred to in this Agreement refers to the iEasyEnergy app operated by Shanghai KONG Intelligent Building Co., Ltd. and its affiliates.

If we and our affiliates use iBUILDING products or services (for example, logging in with an iBUILDING account), but there are no independent privacy policies/agreements, these policies/agreements also apply to these products or services. If we and our affiliates have formulated separate privacy policies/agreements for the products or services provided to you, such separate privacy policies/agreements apply to the corresponding products or services. If the separate privacy policies/agreements of a platform are incomplete, please refer to the corresponding agreements applicable to other related platform privacy policies/agreements.

Before using iBUILDING products or services, please be sure to read carefully and understand this Agreement thoroughly, especially the articles that are written using bold or underlined font, and agree to accept the content of the agreement If you have any questions about this Agreement, please contact us at the contact information published in Article 11 of this Agreement.

If you are a minor under the age of 18, please read this Agreement with your legal guardian and pay special attention to the terms of use for minors.

This Agreement mainly explains to you that:

1    Our Role

2    What Information We Collect

3    What We Use Your Information for

4    When We Share Your Information

5    Public Disclosure

6    How We Store Your Information

7    How We Protect Your Information

8    Your Rights

9    Account Logout of Personal Information Subject

10 How We Protect Minors' Information

11 How to Contact Us

12 Update of Clauses

1    Our Role

We are the controller of your data. It means that we have the right to decide how to process your personal information and what we use your information for. We know that you care about how we use and share your data. At the same time, we appreciate your trust and will proceed cautiously and rationally.

2    What Information We Collect

We collect your information on the principle of legality, reasonableness and necessity. To provide a specific service, we will inform you of the information to be collected and why we collect it. According to the service you select, we may collect one or more types of the following information in the scenarios as follows:

2.1   To register an account, you need to provide your mobile phone number (optional), email address and password. If you do not provide relevant information, iBUILDING cannot create an account or provide services for you.

2.2   After your account is registered, you can optionally fill in your personal information, including your name, personal profile (optional), etc., in the personal information column of the webpage or App, or select "Join the company" to display your "Company" information.

2.3   To log in to your account, you need to enter the registered account/mobile phone number/email.

2.4   To better understand the operation of the iBUILDING platform, we may collect information related to your usage frequency, crash data, overall usage, and performance data. We will not associate the information stored in the analysis software with any of your personal information. After you successfully carry out the equipment distribution process or connect your device to the gateway through 4G, the IoT device in your project will automatically upload the device operation and fault data. In order to enable the networking of applications and intelligent devices, it is necessary to obtain the list of system WiFi network hotspots, apply for the corresponding mobile phone location permissions according to Android and Apple system permissions, and mainly obtain the WLAN name and WLAN password. Please rest assured that this information is for local use only and will not be uploaded to the cloud server. To facilitate subsequent device binding, iBUILDING will encrypt and save the WiFi password locally, which is used to automatically fill in the password during networking with the next device, so as to facilitate rapid device networking. On the iBUILDING home page and networking page, we will automatically scan the WiFi list around you intermittently according to the mobile phone version, so as to more rapidly find the devices around you.

2.5   During your use of our products and services, in order to identify the abnormal status of your account or device, understand or optimize the product and service adaptability, and provide application version upgrade or firmware version upgrade services, we will collect your usage information and store it as network log information, including information about the device hardware model, IESI, IDFA, IMEI, IMSI, MEID, SSID, OAID, GAID, ICCID, Android ID, storage permission, location information permission or other unique device identifiers, MAC address, IP address, operating system version, software installation list information, running process information, registration date and settings of the device used to access the service. To provide better intelligent experience services, we will collect the relevant usage of your IoT devices, including device model, device operation status, device usage frequency, power consumption, ambient temperature, and ambient humidity.

2.6   When you copy an SMS verification code, share or receive the shared password information, your clipboard function may be called to read or write relevant information. When reading the SMS verification code, it is automatically filled in to log in using the mobile phone number and verification code. When sharing or receiving the shared iBUILDING platform password information, it is used to write the password information into the clipboard, or monitor the passwords shared by other applications of the device. The clipboard information will only be processed on your device. We will not store your clipboard information for any other purpose.

2.7   When you turn on the device or iBUILDING location function and use our location-based weather service and environmental management service to obtain the local temperature to intelligently adjust the working mode of devices, query after-sales outlets and the repair/installation address, and add devices to discover the list of nearby WiFi or Bluetooth devices, we will collect your location information so that you can obtain relevant services without manually entering your geographic coordinates. We will use IP addresses, GPS and other sensor technologies that can provide relevant information (providing information about nearby devices, WLAN access points and base stations) to determine location. You can disable the location function through system authorization to stop our collection of your geographical location information. After this function is disabled, you cannot use the relevant functions or achieve the intended effect of the relevant services. Note: We collect your current location information for the purpose of providing you with environmental services and fast device networking, rather than tracking your whereabouts.

The table below lists the permissions and purposes we need:

Device Permission

Operating System

Corresponding Business Function and Purpose of Calling Permissions

Inquiry User or not

Whether User Can Disable the Permission

Storage

Android

Read cache information, and track, troubleshoot, diagnose, and count problems in services;

Store cache information to extended storage.

Yes

Yes

Location information

Android/
IOS

Obtain your location information to provide you with services, including maintenance address location, nearby address recommendation and search location services when submitting a maintenance order due to device fault.

Yes

Yes

Device information

Android/
IOS

Build a unique identifier of user identity to complete security risk control, problem diagnosis, synchronization of device information (such as hardware model, IMEI or other unique identifiers, MAC address, and IP address) and other functions for you.

Yes

Yes

2.8   Note: Separate device information and service log information are information that cannot be used to identify a specific natural person. If we combine this information with other information to identify the identity of a specific natural person, or use it with other personal information, such non-personal information will be considered personal information during the combined use. We will anonymize and de-identify such information unless we obtain your authorization or otherwise specified by laws and regulations.

2.9   In addition, in order to achieve online feedback on the use of the iBUILDING platform and devices, we need to collect the content of problem feedback and relevant screenshots from you. We collect such information to better analyze, locate, and solve the problems, and follow up the service closed-loop management. If you do not provide such information, we may not be able to effectively locate and solve the problems.

2.10 To improve the security of your use of iBUILDING services, protect your or other users' or the public's personal and property security from infringement, better prevent security risks such as phishing, fraud, network vulnerabilities, computer viruses, network attacks, and network intrusion, and more accurately identify violations of laws and regulations or iBUILDING-related agreements and rules, we may use or integrate your account information, device interaction information, network log information, and the shared information with your authorization or according to law, so as to comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis and disposal measures according to law.

2.11 If the information you provide contains personal information of other users, you need to ensure that you have obtained legal authorization before providing such personal information to us. If we use the information for purposes other than those specified herein or use the information collected for a specific purpose for other purposes, or we take the initiative to obtain your personal information from a third party, we will obtain your consent in advance.

2.12 Exceptions to authorization and consent: You fully understand and agree that your authorized consent is not required for us to collect, use, share, transfer, and disclose your personal information under the following circumstances, and that we may not respond to your request for information change/modification, deletion, cancellation, withdrawal of consent or demand:

2.12.1   When it involves national security and national defense security;

2.12.2   When it involves public security, public health and major public interests;

2.12.3   When it involves judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of legal judgment;

2.12.4   When it is to protect the life, property or other major legal rights of you or other individuals in a situation where it is difficult to obtain your consent;

2.12.5   When it is disclosed to the public by yourself;

2.12.6   When it is sourced from legally and publicly disclosed information, such as legal news reports or information disclosed by the government;

2.12.7   When it is required by relevant agreements or other written documents signed or performed by you;

2.12.8   When it is necessary for maintaining the safe and stable operation of the products and/or services provided, such as identifying and resolving failures of products and/or services;

2.12.9   When it is necessary for delivering legitimate news reports;

2.12.10    When it is necessary for academic research institutions to collect statistics or conduct academic research in the public interest, provided that any personal information contained in the results of such academic research or descriptions thereof has been de-identified;

2.12.11    Other circumstances as stipulated by laws and regulations.

3    What We Use Your Information for

3.1   We will update your personal data in a timely manner; store or destroy it in a safe manner; minimize the collection and retention of data necessary for us to provide services for you; protect your personal information from disclosure, abuse, unauthorized access and disclosure; and take appropriate technical measures to protect your personal information.

3.2   We collect your information for the following purposes:

3.2.1  Provide you with services (registration, installation, repair, etc.) according to the contract we signed with you.

3.2.2  Provide other services required by you according to the requirements stated when we collect information.

3.2.3  Maintain the integrity and security of the data technology system for storing and processing your personal information.

3.2.4  Detect and investigate information leakage, illegal activities and fraud.

3.2.5  Contact you to solve the problems.

3.2.6  Other purposes you permit.

3.3   Third-party SDK

3.3.1  Our product is developed based on DCloud uni app (5+ App/Wap2App). During application operation, we need to collect your unique device identification code (IMEI/android ID/DEVICE_ID/IDFA, SIM card IMSI information, and OAID) to provide statistical analysis services. In addition, we improve performance and user experience through application startup data and exception error log analysis to provide users with better services. For details, please visit DCloud User Service Agreement at https://ask.dcloud.net.cn/protocol.html.

3.3.2  Alibaba weexSDK: (com. taobao) SDK

3.3.2.1 Purpose: default integration of the uni-app basic module, used to render the nvue page engine of the uni-app.

3.3.2.2 Possible personal information type: stored personal files.

3.3.2.3 Called device permissions: read and write external memory.

3.3.2.4 Official website: http://doc.weex.io/zh.

3.3.3  Fresco picture library

3.3.3.1 Purpose: default integration of the uni-app basic module, used to load pictures on the nvue page.

3.3.3.2 Possible personal information type: stored personal files.

3.3.3.3 Called device permissions: read and write external memory.

3.3.4  Amap: (com.amap.api, com.loc, com.autonavi) SDK

3.3.4.1 Purpose: Addresses are displayed on the map, providing the functions such as location search and nearby address.

3.3.4.2 Possible personal information type: IMEI, OpenID, and location.

3.3.4.3 Called device permissions: Obtain network status, access to WiFi status, location information, rough location, and precise positioning, and read mobile phone status and identity.

3.3.4.4 Link to privacy policy: https://lbs.amap.com/agreement/compliance.

3.4   Note: The above methods cover the main ways we use your information. We may, from time to time, provide users with more diversified services by updating website pages, app versions, mini program versions or device firmware. If we intend to use your information for other purposes not specified in this Agreement, or use the information collected for a specific purpose for other purposes, we will obtain your consent again in the form of agreement signing, pop-up prompt, website announcement, and update of this Agreement, etc.

4    When We Share Your Information

We will not share your personal information with companies, organizations, and individuals other than us, except for the following circumstances:

4.1   Sharing under legal circumstances: We may share your personal information with others according to the provisions of laws and regulations, the needs of litigation dispute settlement, or the requirements of administrative and judicial authorities according to law.

4.2   Sharing with your express consent: We will share your personal information with other parties after obtaining your express consent.

4.3   Sharing with affiliates: To improve our ability to provide you with products and services, identify account exceptions, and protect the personal and property security of other users or the public from infringement, we may share your personal information with our affiliates and/or their designated service providers. We will only share necessary personal information for the purposes stated herein. If we share your personal sensitive information or our associated company changes the use and processing purpose of your personal information, we will ask for your authorization and consent again.

4.4   We will not transfer your personal information to any other companies, organizations and individuals, except in the following circumstances:

4.4.1  Transfer with your express consent: We will transfer your personal information to other parties after obtaining your express consent.

4.4.2  In the event of our merger, internal and external business restructuring, acquisition or bankruptcy liquidation, or other situations involving merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new companies or organizations holding your personal information to continue to be bound by this Agreement. Otherwise, we will require the companies, organizations or individuals to re-obtain your authorization and consent.

 

5    Public Disclosure

We will only publicly disclose your personal information in the following circumstances:

5.1   After we obtain your consent.

5.2   Disclosure according to law: We may publicly disclose your personal information under the mandatory requirements of laws, legal procedures, lawsuits or government authorities.

6    How We Store Your Information

According to law, the personal information collected and generated by us outside the People's Republic of China will be stored in servers in Frankfurt, Germany and North America. We will not transfer or store your personal data across borders to the territory of the People's Republic of China, but our development department and related professional personnel is located in China, so The personnel will remotely access the systems.

Unless otherwise specified by law, iBUILDING will store your information for the following period:

6.1   During your use of iBUILDING products or services, we will continue to store information for you, unless you actively delete or cancel your iBUILDING account.

6.2   We will regularly back up the collected information according to iBUILDING's data backup strategy.

6.3   After you delete information or cancel your iBUILDING account, iBUILDING will stop using your personal information and delete your personal information within 15 working days, except for information that must be stored in accordance with laws and regulations.

6.4   Your personal information will become usable circulation data after it is anonymized and desensitized. iBUILDING can store and use such data without obtaining your consent.

6.5   In case our products or services are stopped, we will notify you in the form of push notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period of time.

7    How We Protect Your Information

7.1   We have taken reasonable and feasible security measures in line with industry standards to protect your personal information from unauthorized access, public disclosure, use, modification, damage or loss. For example, data exchange between your browser and server is protected by SSL Protocol through encryption; We will provide HTTPS protocol security browsing mode for iBUILDING websites; We will use encryption technologies to improve the security of your personal information; We will use trusted protection mechanisms to prevent your personal information from malicious attacks; We will deploy access control mechanisms to ensure that only authorized personnel can access your personal information; and We will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

7.2   The Internet is not a safe environment. When using iBUILDING products or services, we strongly recommend that you do not use communication methods other than those recommended by iBUILDING to send your information. You may establish contact and share with others through our services. When you create communication, transaction or sharing through our services, you can choose the object of communication, transaction or sharing as the third party who can see your transaction content, contact information, exchange information or sharing content and other relevant information.

7.3   In the event of an unfortunate security incident related to personal information, we will inform you of, in accordance with the requirements of laws and regulations, the basic situation and possible impact of the security incident, the handling measures we have taken or will take, the suggestions regarding independent prevention and risk reduction, and the remedial measures for you. We will inform you of the information about the incident by mail, letter, telephone, and push notification. If it is difficult to inform the personal information subject one by one, we will take a reasonable and effective way to publish an announcement. Meanwhile, we will report the disposal of the incident according to the requirements of the regulatory authorities.

7.4   You fully understand and agree that we have the right to review whether the identity information provided by the user for registration is true and valid, and take reasonable technical and management measures to ensure the security and effectiveness of the user account. You are obliged to keep your account number and password properly and use them correctly and securely. If any party fails to fulfill the above obligations, resulting in loss of account and password, theft of account and other circumstances, and damaging the civil rights of users and others, it shall bear the legal liability arising therefrom.

7.5   If you find that others falsely use or embezzle your iBUILDING account and password, or use them without your legal authorization, you should immediately notify us as required. In addition, you should provide your valid personal identity information consistent with your registered identity information when you notify us. After receiving your valid request and verifying your identity, we will take corresponding measures according to your request or specific circumstances (including but not limited to suspending the login and use of the account, unbinding and deleting the smart devices bound to the account). Any loss to you or other users caused by taking corresponding measures according to your request shall be borne by you. If you do not provide valid identity information or the valid personal identity information provided by you is inconsistent with the registered identity information, we have the right to refuse your request, and the loss caused thereby shall be borne by you.

8    Your Rights

You have the right to manage your information, including:

8.1   Access your personal information:

8.1.1  Account information: If you want to access or edit the personal information in your account, change your password, etc., you can access or edit through settings after logging in to your account.

8.1.2  Other personal information (such as after-sales service, installation and repair service): You can access the personal information generated during your use of our products or services on the corresponding service page.

8.2   Modify your personal information

You have the right to ask us to make modifications or supplements when you find that we have made mistakes in processing your personal information. You can make modifications or supplements by visiting the personal information setting page or contacting us directly.

8.3   Delete your personal information

In the following situations, you can request iBUILDING customer service to delete your personal information:

8.3.1  If our handling of personal information violates laws and regulations.

8.3.2  If we collect and use your personal information without your explicit consent.

8.3.3  If our handling of personal information seriously violates our agreement with you.

8.3.4  If you no longer use our products or services, or you voluntarily cancel your iBUILDING account.

8.3.5  If we will permanently cease to provide you with products or services.

8.3.6  If we share your personal information with or transfer it to others without your explicit consent, you have the right to request us and the third party to delete it.

8.3.7  If we violate the agreement with you and publicly disclose your personal information, you have the right to ask us to immediately stop the public disclosure and issue a notice requiring the relevant recipient to delete the corresponding information.

If we decide to respond to your request for deletion, we will stop providing you with products or services and delete your personal information according to the requirements of applicable laws.

8.4   Copy of personal information

If you need a copy of your personal information, you can contact us through the contact information in Article 11.

8.5   Right to withdraw consent

8.5.1  In case we need to obtain your consent to process data, you have the right to withdraw the consent at any time by logging out of the IBUILDING account via the path of "My - Settings - Account and Security - Logout of Account".

8.5.2  If you want to change your authorization scope, you can modify your personal permission settings through your mobile phone via the path of "My - Settings - Privacy Security Settings - Privacy Settings".

8.5.3  When you withdraw your consent or authorization, we will not be able to continue to provide you with the services corresponding to the withdrawal of your consent or authorization, and will no longer process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the previous personal information processing based on your consent or authorization.

9    How We Protect Minors' Information

9.1   Our products and services are mainly intended for adults. For personal information collected from minors with the consent of their legal guardians, we will not use or publicly disclose the legally collected personal information of minors unless permitted by law, expressly agreed by the legal guardian or necessary to protect minors.

9.2   If we find that we have collected the personal information of minors without the prior consent of the legal guardian, we will try to delete the relevant data as soon as possible. If a legal guardian has reason to believe that the minor has submitted personal information to iBUILDING without his/her prior consent, please contact us to delete such personal information and ensure that the minor cancels the subscription of any applicable iBUILDING services.

10 How to Contact Us

10.1 If you have any questions, opinions or suggestions about this Agreement, or you want to exercise any rights, or you have any requirements to discuss with us, please contact our department dealing with personal information protection matters through the following ways:

10.1.1   iBUILDING service provider: Shanghai KONG Intelligent Building Co., Ltd.

10.1.2   Email: Support@hvacssp.com

10.2 To ensure security, you may need to provide a written request or prove your identity in other ways. Generally, we will reply to you within 15 days. If you are unsatisfied with our reply, especially when our handling of personal information has damaged your legitimate rights and interests, you may make a complaint or report to the regulatory authorities such as network information, telecommunications, public security and market supervision departments.

10.3  If you remain unsatisfied with our reply, especially when you believe that our  handling of personal information has damaged your legitimate rights and interests, you may file a lawsuit in the court with jurisdiction where the defendant is domiciled.

11 Update of Clauses

11.1 To provide you with better services and user experience, this Agreement will change in due course according to business adjustments and changes in laws, regulations or policies. If you continue to use any of our services or visit our relevant websites after the adjustment or change of the privacy policy, it is deemed that you have fully read, understood and accepted the revised privacy agreement and are bound by it.

11.2 This Agreement shall be updated at least once every 12 months, and this update shall be made on March 30th, 2024.

iBUILDING

Formulated on March 30th, 2024

Effective on March 30th, 2024