TOSOT+ Privacy Policy

Before using the TOSOT+ App (hereinafter referred to as "the App"), be sure to carefully read and understand the following privacy policy. This privacy policy informs you how we process your personal data when you use the App and associated services.
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in member states of the European Union and other provisions related to data protection is Al Balsan for General Trading Co. Ltd.（Here in after referred to as“Albalsan”），address: IRAQ-BAGHDAD AL-KARADA STREET ,INFRONT OF AL-HINDYA CLUB, Tel: +00964-7730553817.
Our representative for the purposes of Article 27 GDPR is Al Balsan for General Trading Co. Ltd.，address：IRAQ-BAGHDAD AL-KARADA STREET ,INFRONT OF AL-HINDYA CLUB，Tel: +00964-6544. In case of questions on how your personal data is processed by the Product, you may also contact our data protection coordinator via e-mail (info@al-balsan.com) or at our address listed above.

1. Collecting and using personal information

When you use the Product and service, you may be asked to provide some personal information, because this personal information is needed to that we can provide our services to you, e.g. setting up your account. Personal information is defined in data privacy laws applicable in your country. It includes any information relating to an identified or identifiable natural person. This means any individual who can be identified directly or indirectly by reference to an identifier such as name, identification number, location data, online identifiers (for example, IP addresses – if they can be used to identify you) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Put simply, this includes data which either by itself or with other data held by us or available to us, can be used to identify you.
Set out below are the types and categories of personal information that may be collected for the App and the purposes your personal information is used for.

1.1 Types of personal information

- When you create an account, we will ask you to provide the following personal information: your name, e-mail address, password, user address (optional)
- (a) Geographic location information: when you add a new appliance, we may obtain your location information via IP address, GPS, WLAN (eg.WIFI) or base station, but will not track your location. In this regard, the software will use the pop-up window to request consent and will only obtain your geographic location information after your consent;
(b) Status of the devices : When you have added a home appliance, we may obtain the status of the device before you use it.(e.g. the temperature and wind speed setting status, data collected by sensor in the equipment of indoor temperature and humidity);
(c) Information of equipment fault: When the equipment fails, we will automatically obtain equipment failure information;
(d) User feedback: When you submit feedback, we will record the feedback and related account information, and the data will only exist in the server in your area;
(e) Third party service provider:

1）When you use WeChat, QQ and other third parties to create an account or log in to the account, we will use the share SDK (mob.com) to obtain third-party account information (including but not limited to avatar, nickname), this service is limited to mainland China. Please read the MobTech official privacy policy carefully.
2）When you use Facebook (Facebook.com) to create an account or log in to an account, we will get your Fcaebook account information (including but not limited to avatar, nickname), please read the official Facebook privacy. 3）When you use iFlyTek (openspeech.cn) voice service to control the device, we will obtain your microphone permission. This service is limited to mainland China. Please read the iFlyTek official privacy policy carefully. 4）To protect your information in this application, we will use 360 ​​Advanced Hardening Service (ebjvn.cn), please read the official privacy policy of 360 Advanced Hardening Service (ebjvn.cn) carefully

(f) Information of your mobile device: In order to support better using experience for you, we will obtain your information of your mobile device (including but not limited to network status, mobile phone status, mobile phone identification code, program task information);
(g) Image : When you install the application provided by us or when you change your avatar, we will request permission to access your mobile photo album, and we will access your photo album with your consent. The pictures you upload will be stored on your regional server.
(h)System permissions

-When you install the application we provide, we will request permission to read or write to external storage. Only after your consent,we will read or write the necessary data (including but not limited to cached data and pictures).
-When installing the application we provide, we will request permission to install the software program, and the application will be installed and upgraded only after your consent.
-When installing the application we provide, we will request permission to modify the system settings, and we will modify the system settings through the application only after your consent.

1.2 Purposes of collection and processing, legal basis of processing
Your personal information will primarily be processed to fulfil this Agreement with you:

- Set up and manage your user account;
- Provide you the services and the App.
- Product development and service optimization

For any other purposes, we will obtain your explicit consent in advance.
The personal information we collect may also be used to communicate with you, e.g., we will send you a notice when Albalsan's products or services are updated and released for the first time. Where required under applicable laws, this will only be done with your prior consent.
We consider it to be our legitimate interest to process your personal information to implement personalized product design and provide you with more personalized services, e.g., recommend and display to you the contents and advertisements specially provided to you, or study our services.
Your mobile phone user identification information and unique identifier and location information of mobile device can be used to activate your warranty service and specific software license. This personal information is also used to perform our contract with you.
With your consent, you may be take part in surveys.
We consider it to be our legitimate interest to process your personal information to improve our products and analyze the efficiency of our business operation. However, we will not use the information to track your location.

2. Cookie and related technologies

We may obtain your information by placing secure Cookie and related technologies in order to provide you with a more personalized user experience and service. We strictly abide by the relevant provisions of this policy.

3. Send a message

- We may send a verification code to your email address when you forget your password and try to retrieve it.
- - We use AURORA Services (jPush.com) push message to your device when necessary, the messages including but not limited to equipment failure information, and family members change information. Please read the official privacy policy of Aurora Service carefully.

4. Your rights under privacy laws

You have various rights under data privacy laws in your country. These may include (as relevant): the right to request access to the personal information we hold about you; the right to rectification including to require us to correct inaccurate personal information; the right to request restriction of processing concerning you or to object to processing of your personal information, the right to request the erasure of your personal information where it is no longer necessary for us to retain it; the right to data portability including to obtain personal information in a commonly used machine readable format in certain circumstances such as where our processing of it is based on a consent; the right object to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual; and the right to withdraw your consent to any processing for which you have previously given that consent.

5. Data security

We endeavor to provide protection to the User to prevent unlawful, unauthorized access, tampering, divulgence, accidental loss of, damage or destruction of your personal information. We maintain physical, electronic and procedural safeguards to protect the confidentiality, integrity and availability of your personal information. Therefore, we specially take the following measures:

(1) We will review the information collection, storage and processing methods (including physical security measures) to avoid unauthorized access to all the systems.
(2) We only allow Albalsan employees who need to know the information to help us process personal information and the persons who are entitled to come into contact with the service company to get personal information, and they need to strictly fulfill the obligation of maintaining confidentiality of the contract. If they fail to fulfill these obligations, they may have to assume legal responsibility or terminate their relationships with Albalsan.
(3) Your information security is important to us. Therefore, we will continue to strive to protect your personal information security, and implement security measures such as storage and transmission security encryption to prevent your information from being illegally acquired, used or disclosed. Meanwhile, only the User has the right to access certain specific contents of the encrypted data.

6. Scope of application of the privacy policy

Our privacy policy does not apply to third party products and/or services. The App and service may contain third party products and services. When you use third party products or accept third party services, they may receive your information. Therefore, we remind you to read the third party's privacy policy.

7. External websites and links

This privacy policy does not apply to collection of data from an external website after clicking a link.

8. Children

We require that children under the age of 16 use the App or service under the permission and guidance of legal guardians.

9. Disclosing your personal data

The protection of user privacy is a basic policy of Albalsan. Albalsan promises that it will not make public the registration information of a single user and the user's non-public content stored in Albalsan network when using network services or provide it to a third party, except for the following circumstances:

(1) Clear authorization is obtained from the User in advance;
(2) According to the requirements of the relevant laws and regulations;
(3) According to requirements of the relevant government authorities;
(4) According to investigation requirements of the public security organ, procuratorate and court;
(5) To safeguard the interests of the public;
(6) To safeguard the legitimate rights and interests of Albalsan

10. Recipients or categories of recipients of the personal data

Albalsan cooperates with third party service providers who provide related network services (e.g. hosting) to the User. In this case, if the third party agrees to undertake the same responsibility for protecting user privacy as Albalsan, Albalsan shall have the right to provide the User's registration information to the third party. We will therefore check any third party that we use to ensure that they can provide sufficient guarantees regarding the confidentiality and security of your data. We will have written contracts with them which provide assurances regarding the protections that they will give to your data and their compliance with our data security standards and international transfer restrictions.
The third parties are located outside the EU, namely in the USA and China. We have put in place adequate safeguards with respect to the protection of your privacy, fundamental rights and freedoms, and the exercise of your rights, e.g. we establish an adequate level of data protection through EU Standard Contractual Clauses based on the EU commission’s model clauses.

11. On an aggregate and anonymized basis (i.e. under the premise of not disclosing the privacy information of a single user), Albalsan has the right to analyze the entire user database and make commercial use of the user database. Again, this will not identify you.

12. Privacy protection principles

Albalsan has established the following four privacy protection principles to guide us on how to deal with issues involving user privacy and user information in the App:
(1) Use the information we collect to provide the User with valuable products and services.
(2) Develop products that conform to privacy standards and privacy practices (privacy by design and by default).
(3) Make personal information collection transparent and invite an authoritative third party to conduct supervision.
(4) Make the utmost efforts to protect the information we have.

13. Duration of storage

We will keep your personal information for as long as we need it to fulfil the purposes for which it was collected (see above) and in order to comply with legal and regulatory requirements. This may mean that some information is held for longer than other information. If you would like further information about our data retention practices, please contact us

Our software targets smart products with a service cycle of 5-10 years.

14. Provision of Personal Information / Automated decision making.

Please note that the personal information we collect from you is necessary to providing the services and the features of the App. Failure to provide such data may not enable us to provide our services to you. We do not use automatic decision-making or profiling.

15. Data protection authoriry:

If you consider that we are in breach of our obligations under data protection laws, you may lodge a complaint with the competent data protection authority, which may be the supervisory authority in your country of residence, place of work or of an alleged infringement of data protection laws.

16. This policy update

We may revise this Privacy Policy as appropriate. We will not reduce your rights under this Privacy Policy without your express consent. We will post any changes to this policy on this page.
In this case, if you continue to use our products or services, it means that you will agree to be bound by the revised Privacy Policy.