GoldSmart Privacy Policy
Last modified: March 22th, 2023
Effective: March 22th, 2023
Scope
GoldSmart, its affiliates and subsidiaries (“we”, “us”, “our”, “GoldSmart”) recognizes that your privacy is important and we take it seriously. This Privacy Policy describes how we collect, receive, use, store, share, transfer and process your information, as well as your rights in determining what we do with the information that we collect or hold about you when you access or use our websites and online properties, including www.GoldSmart.com and our career portal (collectively, the “Sites”). The Sites, the GoldSmart Platform and smart solutions we provide in connection with one or more of the foregoing are collectively referred to as the “Services.”
This Privacy Policy covers our processing of information you provided through contacting us for business communication and negotiation, which is limited to the purpose of providing the service for which you have engaged us and GoldSmart has no direct relationship with the individuals which business customer’s products or services target at.
The Services does not contain processing activities that are operated and maintained by third parties. Therefore, it does not apply to how third parties information processing situations.
If you have any questions or concerns regarding the data protection practices, please do not hesitate to contact us through email: service@goldsmart.com
You are not obliged to provide to us your Personal Data (as defined below). However, we may be unable to communicate with you about certain products and/or Services that you request.
Definitions
In this Privacy Policy,
Personal Data means, unless otherwise provided by applicable laws in your region of residence, information that can be used to identify a particular individual, either by that information alone, or in combination with other information.
User Data refers to the data submitted by users or collected by GoldSmart in order to provide its services, such as user name, contact information, etc., when user registers for an account on GoldSmart's website, interfaces with GoldSmart's products or services. For clarity, User Data includes, but is not limited to, Personal Data.
Smart Devices refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.
What Personal Data do We Collect
When you use our Service as a web user:
- (Optional)Account registration data: account name and contact details, such as your email address, phone number, user name, and login credentials. During your use of our Services, we may also collect your nickname, country code, language preference or time zone information as related to your account.
- Device information: Information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), which may qualify as Personal Data.
- If you would like to have further business cooperation with us, we may collect following information from you:
- your occupational information, such as job title and job functions;
- your country/region of residence;
- your name and contact details, such as work phone number and business email address so that we can contact you.
When you use our Service as an App user:
- Account registration data: When you register an account with us, we may collect your account name and contact details, such as youremail address, phone number, user name, and login credentials. During your interaction with the Services, we may further collect your nickname, country code, language preference or time zone information into your account.
- (Optional) If you authorize login to your account with a third-party account, we will obtain from such third party certain account information (such as avatar, nickname, region etc.) which may be bound with your GoldSmart account for quick login.
- Feedback: When you provide feedback and suggestion regarding our Services, we will collect your email address, mobile phone number, and other Personal Data that may be provided in your feedback contents, so as to contact you regarding the feedback.
- Mobile Device Information: we automatically collect mobile device information, such as model number, IP address, wireless connection information, the type and version of the operating system, App version number, push notification identifier, log files, and mobile network information. Meanwhile, we will collect your software version number. In order to ensure the security of the operating environment or to provide Services, we will also collect information about your installed mobile applications and other software you use.
- Usage Data: When you use our websites and/or Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our websites and Services.
- Log Information: When you use the App, in order to improve your user experience, the system and exception log may be uploaded, including your IP address, language preference setting, operating system version, date or time of access, so that we can facilitate and accurately identify problems and help you solve them in timely manner.
- Smart device related information if you connect to mobile App:
- Basic Information of Smart Devices: When you use Smart Devices in combination with the Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.
- Information collected during the process of connecting to a Smart Device: Based on the type of Smart Devices you use in combination with the Services, we may collect the following relevant information:
- Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device MAC address;
- After establishing a local connection via Bluetooth, Smart Devices connected via Wi-Fi: Wi-Fi information (SSID, Wi-Fi password), device MAC address;
- Smart Devices connected via Bluetooth: device MAC address;
- Smart Devices connected via Zig-bee: device MAC address.
- Information Reported by Smart Devices: Depending on the different Smart Devices you use in combination with the Services, we may collect different information reported by your Smart Devices
By contacting us we may deem it is your explicit consent to provide your information.
Purpose and Legal Basis for Processing Personal Data
The purpose for which we may process information about you are as follows:
- To Provide Our Services to You. We process your name and contact details in order to provide Services that you have requested. The legal basis for this processing is to perform our contract with you according to ourTerms of Use.
- To Operate and Improve Our Services. We process your only for fulfilling the requirements that you requested, if you have provide some relevant and useful feedback, we may take it to improve our services. The legal basis for this processing is to perform our contract with you according to ourTerms of Use.
- Legal Compliance. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- a)comply with a legal obligation, process or request;
- b)enforce ourTerms of Useand other agreements, policies, and standards, including investigation of any potential violation thereof;
- c)protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or
- d)detect, prevent or otherwise address security, fraud or technical issues.
If there is any change in the purposes for processing your Personal Data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.
Who do We Share Personal Data with?
At GoldSmart, we only share Personal Data to affiliates within our corporate family for purpose of regular business activities based on our instructions and in compliance with applicable law, this Privacy Policy and other appropriate confidentiality and security measures.
As we believe in good faith that access to, or use, preservation, or disclosure of the information is reasonably necessary or appropriate to:
- a)Comply with applicable law, regulation, legal process, or lawful governmental request;
- b)Enforce ourTerms of Useand other agreements, policies, and standards, including investigation of any potential violation thereof
- c)Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.
- d)Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.
Data Transfer
GoldSmart operates globally, and Personal Data (stated in What Personal Data do We Collect) may be transferred, stored and processed outside of the country or region where it was initially collected.
Also, the applicable laws in the countries and regions where we operate may differ from the laws applicable to your country of residence. Under the Personal Data protection framework and in order to facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live.
We protect Personal Data in accordance with this Privacy Policy wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws.
The European Commission has determined that certain countries outside of the European Economic Area (EEA), the UK or Switzerland can provide adequate protection of Personal Data. Where Personal Data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. You can review the agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information,see here. If you would like further details on the safeguards we have in place under the data transfer, you can contact us directly as described in this Privacy Policy.
Security
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. GoldSmart provides various security strategies to effectively ensure data security of user and device.
As for device access, GoldSmart proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization.
As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported.
As for data processing, strict data filtering and validation and complete data audit are applied.
As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing service@goldsmart.com in accordance with the section below.
Data Subject Rights
We respect your rights and control over your Personal Data. You may exercise any of the following rights by: Emailing us at service@goldsmart.com.
You do not have to pay a fee for executing your personal rights. According to different data protection laws, your request of personal rights will be handled within 30 calendar days due to different response requirement.
In your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.
You may:
- Request access to the Personal Data that we process about you;
- Request that we correct inaccurate or incomplete Personal Data about you;
- Request deletion of Personal Data about you;
- Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
- Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated;
- Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests even though we do not provide marketing communication.
You may opt-out from receiving marketing-related emails through the email selection or other communications from us on a going-forward basis by emailing service@goldsmart.com.
Your California Privacy Rights
California Civil Code Section 1798.83 permits users of the Software that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please contact us by emailing to service@goldsmart.com.
Data Retention
We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data.
- 1.For as long as you require us to fulfill the products and services you request from us as defined in theTerms of Use;
- 2.Personal Data will no longer be retained when you request to remove your Personal Data, we will accordingly complete the task.
When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.
Children’s Privacy
In the first place, our Services are NOT target on child and they are not expected to use the Services.
Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13) (or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information.
Changes to this Privacy Policy
We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (send to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us as follows:
GoldSmart, SINBAY GROUP LIMITED
Postal Mailing Address: 2/F, Palm Grove House, P.O. Box 3340, Road Town, Tortola, British Virgin Islands.