This Policy is issued by each of the Controller entities listed in Section (Q) below (together, “Anker”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, or recipients of any of our other products, (together, “you”). Defined terms used in this Policy are explained in Section (X) below.
This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, Personal Information or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.
You may also have certain rights regarding the information we collect about you. Specifically, the rights of Data Subjects under the GDPR are explained in Section (N) below. Similarly, U.S. residents in general and California Residents in particular may find information on their rights as a Consumer in Section (U) below.
Intended Audience: Our Apps, products, or services are not directed to children under the age of 13. As a result, our Apps, products, or services do not request or knowingly collect personal information from individuals under the age of 13. If you are not 13 or older, you should not visit or use our Apps, products, or services .
This Policy was last updated on July 15th, 2022.
Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:
We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, products or services, including where those data are collected from different devices.
We Process the following categories of Personal Data about you:
Except as specified in this Policy, we do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.
The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
| Processing activity | Legal basis for Processing |
|---|---|
| Provision of Sites, Apps, products, and services: providing our Sites, Apps, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, products, or services. | The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; orWe have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, products, or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orWe have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
| Operating our business: operating and managing our Sites, our Apps, our products, and our services; providing content to you; displaying advertising and other information to you; monitoring and analysing trends, usage, and activities; communicating and interacting with you via our Sites, our Apps, our products, or develop and display content, features, and advertising tailored to your interests on our services as well as on other platforms and services; and notifying you of changes to any of our Sites, our Apps, our products, or our services. | The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; orWe have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, our products, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orWe have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
| Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable. | The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; orWe have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orWe have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
| Product safety communications: communications in relation to product safety, including product recalls and product safety advisory notices. | The Processing is necessary for compliance with a legal obligation; orWe have a legitimate interest in carrying out the Processing for the purpose of ensuring the safety, and proper use, of our products (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
| Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems. | The Processing is necessary for compliance with a legal obligation; orWe have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
| Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations. | The Processing is necessary for compliance with a legal obligation; orWe have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orThe Processing is necessary to protect the vital interests of any individual. |
| Financial management: sales; finance; corporate audit; and vendor management. | We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orWe have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
| Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, our products, or our services. | We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orWe have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
| Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details). | The Processing is necessary for compliance with a legal obligation; orWe have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
| Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law. | The Processing is necessary for compliance with a legal obligation; orWe have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
| Legal compliance: compliance with our legal and regulatory obligations under applicable law. | The Processing is necessary for compliance with a legal obligation. |
| Improving our Sites, Apps, products, and services: identifying issues with our Sites, our Apps, our products, or our services; planning improvements to our Sites, our Apps, our products, or our services; and creating new Sites, Apps, products, or services. | We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, our products, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orWe have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). |
| Fraud prevention: Detecting, preventing and investigating fraud, breach of policies or terms, and threats or harm. | The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); orWe have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms). |
| Establishment, exercise and defence of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings. | The Processing is necessary for compliance with a legal obligation; We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); orThe Processing is necessary for the establishment, exercise or defence of legal claims. |
We disclose Personal Data to other entities within the Anker group, for legitimate business purposes and the operation of our Sites, Apps, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
We Process Personal Data for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:
| Profiling activity | Logic of the Profiling activity | Consequences for you |
|---|---|---|
| Customised discounts and promotion | Where we analyse your purchasing activity and your interests. This information is analysed to determine the most appropriate promotions and discounts to offer you. | This Profiling activity may mean that you receive discounts that are not available to others, and that others receive discounts that are not available to you. |
| Customised message and notification | Where we analyse your activity and products log. This information is analysed to determine which service manual or public comments suitable for you. | This Profiling activity may mean that you receive notification that are not available to others, and that others receive notification that are not available to you. |
Because of the international nature of our business, we transfer Personal Data within the Anker group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located, including China, the EU, the UK, and the US.
If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (Q) below.
Please note that when you transfer any Personal Data directly to any Anker entity established outside the UK or the EEA (as applicable), we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Policy.
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.
We take every reasonable step to ensure that:
From time to time we may ask you to confirm the accuracy of your Personal Data.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:
| we will retain Personal Data in a form that permits identification only for as long as: we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); oryour Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data), |
|---|
| plus: |
| the duration of: |
| any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and |
| an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim), |
| and: |
| in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim. |
During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:
the right to request, on legitimate grounds:
erasure of your Relevant Personal Data; or
restriction of Processing of your Relevant Personal Data;
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:**the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; andthe right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.**
This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:
All use of our Sites or services is subject to our Terms of Service. We recommend that you review our Terms of Use regularly, in order to review any changes we might make from time to time.
We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, Apps, products, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, Apps, products, or services. If we provide Sites, Apps, products, or services to you, we may send or display information to you regarding our Sites, Apps, products, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send or by unsubscribing online at INSERT LINK. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, products, or services you have requested.
For the purposes of this Policy, the relevant Controllers are:
| Controller entity | Contact details |
|---|---|
| Anker Technology (UK) Ltd. | 205 Kings Road, Fairgate HouseSuite BB11 2AA Birmingham+49 (0) 69 9579 7960 support@eufylife.com |
| Room701, Bldg 7, Zhongdian Software Park, 39 Jianshan Road, Hi-tech Zone, Changsha City, Hunan Province, China | |
| Shenzhen Oceanwing Smart Innovations Technology Co., Ltd | B701-705, Jianxing Tech Bldg, Xinxing industrial park, 3151 Shahe West Road, Nanshan District, Shenzhen City |
| Fantasia Trading LLC | 5350 Ontario Mills Pkwy, Suite 100, Ontario, CA 91764 Delaware地址：Business Filings Incorporated, 108 West 13th St, Wilmington, DE, 19801 |
For general enquiries, or to exercise any of the rights set out in this Policy, please contact support@eufylife.com.
Each of the controllers established outside the EEA and listed in Section (Q) above has appointed Support Team to be its representative the purposes of Article 27 of the GDPR, where applicable.
Each of the controllers established outside the UK and listed in Section (Q) above has appointed Support Team to be its representative the purposes of Article 27 of the UK GDPR, where applicable.
When you visit a Site, we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with applicable laws.
Certain Cookies may be stored on your machine by third parties when you use our Sites. We have no control over these Cookies or how the third parties use them. These Cookies allow third parties to provide us with a service, for example, analytics about the effectiveness of our marketing activities and user behaviour.
Regular Cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. With respect to our web services you can stop all collection of information via a web service by not using that web service. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device or internet browser. You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.
You may opt-out of targeted advertising utilizing the Digital Advertising Alliance (“DAA”) AdChoices Program at optout.aboutads.info. For more information on the DAA AdChoices Program at visit www.youradchoices.com. In addition, the Network Advertising Initiative (“NAI”) has developed a tool that allows consumers to opt out of certain Tailored Advertising delivered by NAI members’ advertising networks. To learn more about opting out of such targeted advertising or to use the NAI tool, see https://optout.networkadvertising.org/.
Most browsers can be set to send signals to third party websites requesting them not to track the user’s activities. At this time, we do not respond to “do not track” signals. Consequently, third parties may indeed track and collect information about your online activities over time while navigating to, from and on our online services, notwithstanding any “do not track” signals we may receive.
Under the California Consumer Privacy Act (“CCPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents (“Consumers”). Consumers are also afforded additional rights with regard to the Personal Information we collect about them that include the rights of access, deletion, and to be free from discrimination. This section of our Privacy Policy includes the disclosures required by the CCPA and Section (V) below describes the rights afforded to Consumers. We also describe the methods by which a Consumer may exercise these rights and some of the statutory exceptions that may apply.
| Anker Sites, Apps, products, or services | Collection of Personal InformationWe have collected and will collect the following general categories of Personal Information about Consumers: | Use of Personal InformationWe may use the categories of Personal Information described for the following business or commercial purposes: |
|---|---|---|
| Eufy SecurityApplication | Personal identifiers, including name, alias, postal address, unique personal identifier, online identifier, Internet Protocol Address, email address, bank account name, or other similar identifiers; Categories of personal information enumerated in Cal. Civ. Code § 1798.80(e), including signature, physical characteristics or description, telephone number, state identification card number,; Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; Geolocation data;Audio, electronic, visual, thermal, olfactory, or similar information; Professional or employment related information; andInferences for use in creating a consumer profile. | To advance a commercial or economic interest (such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information or services, or enabling or effecting, directly or indirectly, a commercial transaction) ；Audit customer activity (such as counting ad impressions);Maintain or service customer accounts;Provide customer service; Process or fulfil orders and transactions;Verify customer information;Process payments;Provide advertising or marketing services;Provide analytic services;Short term, transient use (such as for behavioural advertising)Internal research for technological developments;Ensure quality and safety of services or devices; andImprove quality and safety of services or devices. |
Categories of Sources of Personal Information
We collect or obtain Personal Information about you on our Websites and Applications from the following sources:
Disclosure of Personal Information
We do not Sell any personal information to third parties. In particular, we do not Sell the personal information of minors under 16 years of age. In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of recipients:
| Categories of Recipients | Categories of Personal Information |
|---|---|
| Advertising networks, data analytics providers. | Personal Identifiers |
| Internet Service Providers | Personal Identifiers; andCategories of personal information enumerated in Cal. Civ. Code § 1798.80(e) |
| Vendors who may need access to your personal information to help us provide our services | Personal Identifiers; andCategories of personal information; enumerated in Cal. Civ. Code § 1798.80(e)Internet or other electronic network activity informationCommercial Information |
| Payment processors | Personal Identifiers; andCategories of personal information; enumerated in Cal. Civ. Code § 1798.80(e)Internet or other electronic network activity informationCommercial Information |
The purposes for which we disclose personal information are described in more detail in Section (G) above.
Consumer Rights under the California Consumer Privacy Act
If you are a Consumer, the CCPA grants you the following rights regarding your Personal Information. Generally, in order to verify your requests to exercise your rights, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable consumer request. To exercise your rights under the CCPA, please follow the instructions described in this section.
Right to Know About Personal Information**. Consumers have the right to submit a verifiable consumer request that we disclose the following in a readily useable format, covering the 12 month period preceding the verifiable consumer request:
Verifiable consumer requests to know may be submitted through the following method:
Right to Request Deletion of Personal Information**. Consumers have the right to request that we delete any Personal Information that we have collected from them. However, we are not required to comply with a request to delete where it is necessary for us to retain the Personal Information in order to:
Verifiable consumer requests to delete may be submitted through the following method:
Right to Non-Discrimination**. Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:
Notice of Financial Incentive. We do not offer financial incentives or price or service differences to consumers who provide personal information.
Authorized Agent. Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.
Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of personal customer information Anker shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this Policy, please submit a written request to support@eufylife.com.
If you have questions or concerns with respect to our Privacy Policy, you may contact us at [Contact Us].
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:
“Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. A business does not sell personal information when:
The business transfers to a third party the personal information of a consumer as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of the business provided that information is used or shared consistently with Sections 1798.110 and 1798.115 of the CCPA.