Alfred International Inc. (“we”, “us”, “our” or “Alfred”) is committed to protecting the users of its websites, mobile applications, products, and services (each a “Alfred Service” and collectively the “Alfred Services”). When you access, browse, or use the Alfred Services, information will be collected, transferred, processed, stored, and disclosed in accordance with this privacy policy (“Policy”). This Policy governs the information collection and disclosure practices for the Alfred Services. By accessing, browsing, or using the Alfred Services, including registering an account with our Alfred Services, you expressly consent to the collection, transfer, use, processing, and storage of your information (including personal information), as described in this Policy. IF YOU DO NOT AGREE WITH THIS POLICY OR THE INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES DESCRIBED IN THIS POLICY, DO NOT USE THE ALFRED SERVICES OR REGISTER AN ACCOUNT.

 

1. INFORMATION COLLECTION PRACTICES

 

1.1. General. When you visit Alfred websites and use Alfred mobile applications without registering, you can browse without submitting personal information about yourself. If you register for an account within or to access a Alfred Services, we will collect some personally identifiable information from you, including your username, email address, and hashed version of the password you select. When you interact with the Alfred Services, we also receive and store certain additional types of information which, in general, do not directly identify you. For example, we automatically receive and record information on our server logs from your browser or device including your IP address, browser type and language, referring/exit pages and URLs, device type, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time. This Section of the Policy outlines the various ways that information is collected from the Alfred Services. Please fully review this Policy before you use the Alfred Services or submit information to us.

 

1.2. Information that You Provide.

 

(a) Registration and Login. Certain Alfred Services require you to register for an account and/or log in using credentials. You can register for an account from our account registration system or a third-party site or service such as Facebook (“Account”). When you register for an Account you may be asked to provide some personally identifiable information, such as your email address, phone number, lock SN code and a username and password that you select. When you are asked to create an Account using your credentials from a third-party site or service, you will be asked for your username, password, and other information to verify that you have an account with the third-party site or service. When you provide credentials for a third-party site or service, we may use those credentials to obtain information about you from that third party. See Section 1.4 (Information from Other Sources) and 3.4 (Social Sites) for more information. When you register an Account and log in to a Alfred Services you must provide your current, complete, and accurate information. It is your responsibility to keep your information up to date. We are not responsible for any problems, interruptions in access, or liability that may arise if you do not give us complete and accurate information or if you fail to update your information so that it is current.

 

(b) Product Set Up. In order to use certain products such as our lock products, we may record information relating to the setup, general performance, and operation of our Service, your application and lock (and of other of our locks in your home or business or that you otherwise may access), including device status, logs of those who lock/unlock the device and Service, the guests that you invite, and those people who may invite you as a guest, to use the device and application. We may store this data along with your personally identifying information other information about your use of our Service. We use this information to allow you (and us) to operate and monitor your device and our Service.

If you enable the Auto-Unlock feature, the application will track your location using GPS in order to determine when your application nears Alfred devices that you have permission to access (e.g. when you are near home). This information will only be stored on your device, and not on our servers. This information will tell your mobile device to start listening for your lock more often (increasing the polling). This improves the Alfred device’s performance and saves your mobile device’s battery life.

 

(c) Correspondence. If you send us personal correspondence, such as emails or letters, about your use of the Alfred Services, we may save the information in a profile specific to you.

 

(d) Information You Provide to Others. You may choose to share information with third-parties such as social networking Sites like Facebook and WeChat (“Social Sites”) by “sharing” bluetooth key. See Section 3.4 (Social Sites) for more information.

 

1.3. Automatically Collected Information. We will collect some information about you and any product or device you use to access or use the Alfred Services automatically using a variety of technologies. In general, automatically collected information about the use of Alfred Services does not directly identify you and the information may include your diagnostic log information, IP address, browser type and language, referring/exit pages and URLs, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, the actions performed in the Alfred App, the info(OS type/version, network, etc.) of the phone which the Alfred App was installed, and the date and time. We collect this information for the purposes described in this Policy, including to better understand our customer base and to improve the quality of our Alfred Services. We do NOT collect information not related to the use of the Alfred services.

 

(a) Mobile Data. When you use certain features of the Service, in particular our mobile applications, we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Service or specific features of the platform). If you access the Service through a mobile device and you do not want your mobile device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your mobile device. See your mobile device manufacturer’s instructions for further details. Of course, if you do this, Service functionality (such as the Auto-Unlock feature described immediately above) may not work.

 

(b) Guest Access. As part of our Services, you may give others (“guests”) permission levels to access your Alfred device – e.g. to unlock and lock your door (and possibly even to pass this access along to others). Needless to say, you must be careful of the guests that you invite and the access that you give them. YOU ARE RESPONSIBLE FOR ALL USES OF YOUR ACCOUNT, SO BE CAREFUL TO SECURE THIS INFORMATION AND ONLY GIVE ACCESS TO PEOPLE YOU TRUST.

Additionally, certain portions of your personally identifying information, device and Service information may be shared with the people that you invite, such as your name and lock location, and the status of the lock (e.g. locked or unlocked).  We may also collect personally identifying information (as required to use the Service as set forth in this Privacy Policy) about the guests that you invite in order to allow them to have access to your Alfred device and Service. All such information (including their Service usage information) is subject to, and will be used and disclosed as set forth in, this Privacy Policy.ALL GUESTS EXPRESSLY CONSENT TO SUCH USE AND DISCLOSURE AS A USER OF THE SERVICE. IF YOU ARE A GUEST AND DO NOT CONSENT TO SUCH USE, YOU SHOULD STOP USING THE SERVICE. GUESTS SHOULD BE AWARE THAT THE PERSON(S) PROVIDING ACCESS TO A SPECIFIC DEVICE MAY BE ABLE TO SEE INFORMATION ABOUT THE GUEST’S USAGE OF THE DEVICE AND OUR SERVICE AND MAY REVOKE OR LIMIT ACCESS RIGHTS IN THEIR DISCRETION WITHOUT NOTICE. GUESTS SHOULD ALSO BE AWARE THAT THEIR PERSONALLY IDENTIFYING INFORMATION AND USAGE INFORMATION MAY BE SHARED WITH THIRD-PARTY SERVICE PROVIDERS AS SET FORTH IN THIS PRIVACY POLICY, INCLUDING THOSE SERVICE PROVIDERS SELECTED BY THE PERSON(S) THAT INVITED YOU TO USE THEIR LOCK (SEE “YOUR THIRD PARTY SERVICE PROVIDERS” BELOW).

If you send us a request (for example via a support email or via one of our feedback mechanisms), we may use your information to contact you and provide support or a response. We also reserve the right to publish your request in order to help us clarify or respond to your request or to help us support other users.

 

(c) Cookies. A cookie is a small text file that is stored on a user’s computer or mobile device. We and our third-party analytics provider use cookies to record information about your activities on the Alfred Services to “remember” you when you return to the Alfred Services. Some cookies remain on your computer or device until you delete them. Others, like session ID cookies, expire when you close your browser. You may set your browser setting to attempt to reject cookies and you may still use the Alfred Services. See the section “Do-Not-Track-Settings” below for more information on how the Alfred Services may respond to your browser settings. We do not control the use of cookies by third parties. See Section 4 (THIRD-PARTY PROVIDERS) for more information and review the privacy policies of all third-party providers for more information on third-party cookies.

 

1.4. Information from Other Sources. With your permission, we may obtain both personal and non-personal information about you from business partners, Social Sites, and other third parties and add it to our account information or other information we have collected. We also collect information from Social Sites when you register or log in to use our Alfred Services by using your Social Site log-in and password. For example, our Site allows you to create an account and log in using your Facebook account credentials and, in addition to allowing you to log in to the Site and share videos with Facebook, we also use your authorization to obtain the following information from Facebook: Facebook username, first name, last name, and profile picture. The information we collect may depend on the privacy settings you have with the Social Site, so please consult the Social Site’s privacy and data practices.

 

2. USE OF INFORMATION

 

2.1. General. We may use your personally identifiable information (including tracking information) to manage your Account. We may also use it to operate, maintain, and improve the Alfred Services (including providing you a more personal experience); communicate with you; provide you information about products and Alfred Services (including products and services of third parties); market; research purposes; resolve disputes; collect fees owed; detect and protect against errors, fraud, and criminal activity; assist law enforcement; enforce this Policy and any the terms related to our Alfred Services; and any other purpose described in this Policy or that we describe to you at the time of collection.

 

2.2. Email Communications. We may use your personally identifiable information to send you emails or other communications related to your Account or the Alfred Services, or in response to your inquiries or requests. You may not opt-out of receiving service-related messages that are not promotional. We may also send you marketing emails, surveys, or newsletters to notify you about products or services that may be of interest to you. If you would like to stop receiving marketing emails from us, please click on the unsubscribe link at the bottom of any marketing email you receive. You can opt out of marketing email in this way but you will continue to receive service related emails as they are a fundamental part of the services.

 

2.3. Non-identifying Information. We may use non-identifying information for any lawful purpose, including analyzing trends, research, Alfred Services administration, tracking users’ movements around the Alfred Services, and to improve our business and the Alfred Services.

 

2.4. Retaining Your Information. In general, we will retain your information as long as legally required or allowed. If you cancel your Account or your Account is otherwise terminated, we may but are not obligated to, delete information we have collected or obtained from third parties and we may continue to use and disclose it in accordance with this Policy. But you can delete your account information manually, and it will be purged from our system.

 

2.5. 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 Alfred 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, Google, 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.

Alfred is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal data to any affiliates of the Alfred 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 Alfred shares personal data originating in the EEA with a third party which may or may not be a Alfred 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.

Alfred may use overseas facilities operated and controlled by Alfred App to process or back up your personal information. Alfred currently has data centers in the United States. These overseas jurisdictions may or may not have data protection laws similar to the data protection laws in your jurisdiction. You have understood that the risks under applicable data protection laws are different and 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.

For example, if you choose to use other third-party services available for this product or service (such as Amazon, Google, 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.

 

3. INFORMATION SHARING

 

3.1. General. We will not sell or rent any of your personal information to third parties for marketing purposes. However, we may disclose your information to any affiliated entity or organization and to agents and service providers. We may also share non-identifying information with third parties for any lawful purpose, including analyzing trends, research, Alfred Services administration, tracking users’ movements around the Alfred Services, and to improve our business, products, and the Alfred Services. Use of information by affiliated entities and organizations will be subject to this Policy or an agreement that is at least as restrictive as this Policy. For information on the use of information by agents and service providers see Section 4 (THIRD-PARTY PROVIDERS).

 

3.2. Legal Requirements. In some cases, we may disclose your personally identifiable information as required by law; if we believe that disclosure is needed to protect our rights; to government regulators; to law enforcement authorities; in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Alfred Services; and to respond to a physical threat to you or another person.

 

3.3. Insolvency and Business Transitions. If we ever file for bankruptcy or engage in a business transition such as a merger with another company or if purchase, sell, or reorganize all or a part of the Alfred Services or our business or assets, we may disclose your personal information, including to prospective or actual purchasers in connection with one of these transactions.

 

3.4. Social Sites. In addition to using Facebook credentials to set up an Account, certain Alfred Services may permit you to choose to share information and videos taken with our lock products with Social Sites. When you choose to share with a Social Site, we may share that video or information as well as additional personal information about you with the Social Site. Information shared with a Social Site is subject to that Social Site’s privacy policy and practices, you should familiarize yourself with the Social Site’s privacy policy and practices before sharing.

 

3.5. Disclaimer. We cannot ensure that all of your personal information will never be disclosed in ways not otherwise described in this Policy. For example, we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the Alfred Services. No transmission of data over the internet can be 100% secure.

 

4. THIRD-PARTY PROVIDERS.

 

4.1. General. We use third parties to help us operate and improve the Alfred Services. We may provide these third parties information we collect and they may collect information from you and about your use of the Alfred Services. We may provide information we collect to third parties and it will, unless specifically noted otherwise in this Policy, be governed by this Policy and may only be used by those third parties to help us operate or improve our business or the Alfred Services and provide services to us. We do not control information collected by third parties and are not responsible for their use of that information. Please review their privacy policies for more information on their information collection, use, and sharing practices.

 

4.2. Google Analytics. We use Google, a third-party analytics provider, to collect information about Alfred Services usage and the users of the Alfred Services, including demographic and interest-level information. Google uses cookies and pixels to collect demographic and interest-level information and usage information from users that visit the Alfred Services, including information about the pages where users enter and exit the Alfred Services and the pages users view on the Alfred Services, time spent, browser, operating system, and IP address. Cookies and pixels allow Google to recognize a user when a user visits the Alfred Services and when the user visits other websites. Google uses the information it collects from the Alfred Services and other websites to share with us and other website operator’s information about users including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link the information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies, pixels, and collection and use of information, see the Google Privacy Policy.

 

5. ONLINE TRACKING AND YOUR CHOICES

 

As discussed above, because we and our third-party service providers automatically collect Alfred Services usage information through the use of cookies, pixels and other tracking technologies (including as described in the “Automatically Collected Information” section above, and otherwise in this Policy), your selection of the “Do Not Track” option provided by your browser may not have any effect on our automatically collected information. One way to attempt to “opt out” of the collection of any information through cookies and some (but not all) other tracking technology is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult and may not be possible. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.

 

6. INFORMATION SECURITY MEASURES

 

Keeping secure personal information that we collect is of great concern to us. While we have mechanisms in place to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. When you provide information to the Alfred Services, you do so at your own risk.

 

7. CHILDREN

 

The Alfred Services are intended for general audiences and are not directed to children under 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information without parental consent, please contact us by using the contact information in the Privacy Questions section at the bottom of this Policy, and we will take steps to remove the information and terminate the child's Account.

 

8. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

 

If you would like to cancel your Account or update your personally identifiable information associated with your Account, you may make such changes by logging in Alfred Apps. If you do not want your information accessed or stored as described in this Policy, you should not access, use, or register an Account with the Alfred Services.

 

9. MODIFICATION OF THIS POLICY

 

We will occasionally update this Policy. We recommend that you check our Alfred Services from time to time to inform yourself of any changes in this Policy or any of our other policies.

 

10. PRIVACY QUESTIONS

 

If you have questions or concerns about our privacy practices, please email us at: [email protected]