Rokid Privacy Policy

Effective Date: June 10th, 2019

This Privacy Policy describes how Hangzhou Lingban Technology Co., Ltd. (杭州灵伴科技有限公司) and Rokid Inc. (“Rokid”, “we,” “our”, or “us”) collect and use your data in connection with your (“Customer”, “User,” or “you”) use of our website rokid.com/en (the “Site”) and the services provided therein (the “Services”). This Privacy Policy is part of the Terms of Use which govern your access to and use of our Services and Site.  

1. ACCEPTANCE OF PRIVACY POLICY

  By using Rokid’s Services and Site, you agree to accept this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Site or Services.  

2. INFORMATION WE COLLECT

Depending on how you use our Services, the information we collect includes, but is not limited to, the following categories of information about you and your company.   When you use our Site to submit a Request for Pre-order, or to Request a Demo, you will provide information such as your first name, last name, business email, country, company name, industry, job role, company size, the use cases of interest, your phone number, and how we can help you. We collect such information in order to better understand your need concerning our product and to contact you for follow-up.   When you use our Site to view, download or otherwise use our product SDK, you will provide information such as your first name, last name, business email, country, company name, developer team size, current development platform for product, and how soon you are planning to adopt AR technology to your product. We collect such information in order to better understand your need concerning SDK related development and to contact you for follow-up.   When you use our Site to Subscribe to Updates, you will provide your email address so that we can email you the latest news about our partnerships, promotions, new product releases, and our company.   When you Contact Us about our Site and Services, you may provide us with inputs and insights online or through emails.   Information We Do Not Intend to Collect   We do not intend to collect or retain records of personal data of European residents, any sensitive personal data such as data concerning health, finance, religion, sexual orientation, or otherwise deemed sensitive by applicable laws, data of individuals who may be deemed minors in relevant jurisdictions, or unauthorized third-party data. Specifically, we do not sell products for purchase or offer any Services to individuals under the age of 18.  

3. AUTOMATICALLY COLLECTED INFORMATION

Each time you visit our Site, Rokid, its partners, and/or vendors automatically collect the following anonymous information to improve the overall quality of your online experience.  

(a) Aggregated Data

Rokid collects data for internal reporting and counts, tracks, and aggregates the visitor’s activity for the purpose of analysis of general traffic flow and feature usage related to the Site. Information we collect to observe site traffic includes, but is not limited to, your browser-based information and general location. We compile traffic-based statistics that show the numbers and frequency of visitors to our Site and its individual pages. These are an aggregated statistical report that we use internally to better understand our Site traffic, manage our Site, and help diagnose any problems. The statistics contain no personally identifiable information and cannot be used to gather such information. To these ends, Rokid may include information about you in aggregated group data. Such anonymous data may be shared with our affiliates, business partners, service providers and/or vendors; if it does so, Rokid will not disclose your individual identity.  

(b) IP Addresses

An IP address is a number that automatically identifies the computer or device you use to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the web server owned by your Internet Service Provider. Rokid may use IP addresses to conduct analyses and performance reviews and to administer the Site, and also may use other information provided by you or your browser for purposes such as enabling support for applications and services being used.  

(c) Cookies

Cookies and similar technologies within a web browser allow persistent storage of data as you navigate a website. This functionality does not personally identify users, although it does allow the web server to differentiate one user from another. Many websites use cookies and similar technologies to provide website and application features when a user visits the website, and most web browsers are set up to accept cookies. Rokid uses cookies to allow our Site to function and improve delivery of your online experience. You can set your browser to refuse cookies, but most functionality of your experience with Rokid may not work properly and you may be required to re-enter certain information each time you use our Site. Some features allow data to remain only for the time that your browser is open, for example a session cookie. A persistent cookie is an example of functionality that your browser provides that allows the data to persist on your device/computer even after the browser is closed. Like many other organizations with websites, Rokid may use both types of functionality your browser provides.  

(d) Third-Party Analytics

We use Google Analytics and Baidu Analytics to better understand and personalize your use of the Services. Both Analytics collect analytics information such as: browser, operating system, device category, mobile device information, country, user type, service provider, the website(s) the user browsed prior to coming to our Site, number of users, new users, sessions, average session duration, average pages accessed per session and user bounce rate. To process analytics data when you visit our Site, both Google and Baidu Analytics may use various technologies including cookies to identify your browser and computer device. Neither Google nor Baidu receives your user account information, email address, or other personally identifiable information from us through the use of Google or Baidu Analytics.  

4. HOW WE USE YOUR DATA

Rokid processes your data in order to provide our Services to you, to comply with legal, regulatory, or contractual obligations, and for other purposes for which Rokid has a legitimate interest or other lawful basis including, but not limited to: (a) keeping our records up to date; (b) maintaining or administering the Services, performing business analyses, or for other internal purposes to improve the quality of our products and Services; (c) communicating with you concerning the Services; (d) sharing with our subsidiaries and members of the Rokid Partner Network for the promotion of our products and services; (e) participating in litigation, investigations, regulatory or governmental inquiries, or for other legal or regulatory purposes involving our Customers or other third parties; and (f) disclosing your data to comply with any legal or regulatory obligation, to enforce our Terms of Use, or to protect the rights, property or safety of Rokid.  

5. SHARING YOUR DATA WITH THIRD PARTIES

We share some of your data with, or obtain data from, the following categories of third parties:  

(a) In General

Rokid may share your data with (i) any U.S. or international governmental department or agency, including regulatory authorities with a legitimate interest in the data; (ii) our subsidiaries and members of the Rokid Partner Network for the promotion of our products and services; (iii) any third party with your consent; (iv) any other third party where Rokid has a legitimate interest in doing so; and (v) any other entity or individual if Rokid is satisfied that the third party has a legitimate interest in such information, including, but not limited to, when there is a need for those third parties to update and maintain their databases, to provide services to or for Rokid’s Customers; and for other purposes in support of Rokid’s products or services.  

(b) Disclosures to Third-Party Vendors

We may share your data, when required by law, under confidentiality agreements or data processing agreements with other third parties that work with or on behalf of Rokid to provide products and services to you such as, but not limited to, those who provide (i) email or mail services; (ii) cloud hosting services; (iii) analysis of usage of the Site; (iv) support and maintenance of the Services; and (v) surveys. We also may share your data with our legal, regulatory, audit, and other professional advisors. Those companies may use your data to assist us in our operations consistent with our legitimate business interests.  

(c) Disclosures to Other Third Parties

Some of your data will be shared with any other organizations with your approval or where Rokid has a legitimate interest in doing so, including, but not limited to: (i) when Rokid must verify information you have summited; (ii) where Rokid is satisfied that the third party has a legitimate interest in such information, including, but not limited to, where there is a need for those third parties to update and maintain their databases, to provide services to or for Rokid’s Customers; and (iii) for other purposes in support of Rokid’s products or services.  

(d) Disclosures under Special Circumstances

We may disclose your data to respond to subpoenas, court orders, legal processes, regulatory authority investigations, governmental regulations or inquires, to establish or exercise our legal rights or defend against legal claims, when we believe it is necessary to share such information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or as otherwise required by law or to protect the public.   Where applicable and mandated by privacy laws, Rokid may share your data with those parties under restrictions such as the requirement to keep your data confidential, destroy data once it is no longer needed for the intended purpose, and/or to prevent unauthorized release of such data. Rokid conducts such exchanges in a secure manner designed to protect against unauthorized access.  

6. HOW LONG WE KEEP YOUR DATA

We keep your data only for as long as is reasonably necessary to achieve the purposes for which it was collected, whether that is to provide services to you, for our own legitimate interests (described above), or so that we can comply with applicable law.  We reserve the right to retain it to the full extent not prohibited by law. We may delete data in our discretion, so you should retain your own records, and not rely upon our storage of any data or content.   We will actively review the information we hold and when there no longer is a legal or business need for us to hold it, we will either delete it securely or in some cases irreversibly anonymize it. When we delete any information, it will be deleted from our active databases but may remain in our archives.  

7. HOW WE PROTECT YOUR DATA

To prevent unauthorized access, maintain data accuracy, and facilitate the legitimate use of your data obtained through our Site, we have put in place appropriate physical, technical, and operational measures to safeguard and secure your data we collect online against unauthorized access, unlawful use, accidental loss, corruption, or destruction. However, messages you send to us through the Internet or otherwise electronically may not be secure. We recommend that you do not send any confidential information to us by email. If you choose to send confidential information to us, you accept the risk that a third party may intercept this information.  

8. LOCATION OF YOUR PERSONAL DATA /DATA TRANSFER

Hangzhou Lingban Technology Co., Ltd. (杭州灵伴科技有限公司) is incorporated under the laws of People’s Republic of China (“China”) and its US subsidiary Rokid Inc. is located in California, United States, subject to the applicable laws of China and/or United States. We store and process information we receive from and about you, as described in this Privacy Policy, in the United States and China. You agree that Rokid and those with whom we share your personal data (“Recipients”) may disclose, transfer, process, and store your personal data outside of your country of origin to our parent, affiliates, sponsors and partners, and any other third-party service providers for the purposes described in this Privacy Policy. Some of the Recipients may be located in countries that do not provide a level of data protection equivalent to that set forth by the United States and some other jurisdictions. If we do transfer personal data outside the United States, we will make sure that it is protected in the same way as if it were being used in the United States. If you choose to access or use the Services offered by Rokid, you consent to the worldwide transfer and processing of your information, even in jurisdictions that may have less restrictive privacy practices than your own.   By submitting any data or by using our Site and without limitation to any other rights or obligations we have, you consent to such transfer to and processing in the United States, China, and other countries. You acknowledge that your information may be subject to access by law enforcement and other government entities including courts and tribunals, in accordance with laws applicable in those jurisdictions.  

9. Consent to Electronic Notice upon Security Breach

We will safeguard your personal data and prevent such information from unauthorized access, disclosure, or use. If we or a Recipient is required by law to provide notice of unauthorized access to or other compromise to your personal data, you agree that we (or they) may do so when required (or voluntarily) by posting notice on our Site or sending notice to any email address we have for you, in our (or their) good faith discretion. You agree that notice to you will count as notice to others for whom you are acting, and agree to pass the notice on to them.  

10. YOUR RIGHTS OVER YOUR PERSONAL DATA

Where provided by applicable data privacy laws, you may have the right to review, verify, correct, and request erasure of the personal data that we hold about you under certain circumstances. You may also have the right to limit, restrict, or object to the processing of your personal data, and to request that we transfer your personal data to another party under certain circumstances.   Where applicable data privacy laws provide you with the rights such as: (a) to review, verify, correct, or request erasure of your personal data; (b) to limit, restrict, or object to the processing of your personal data; (c) to request a transfer of your personal data to another party; or (d) to file a complaint concerning Rokid’s processing of your personal data, you may contact us at glass@rokid.ai or write to us at Rokid Inc., ATTN: Privacy Inquiries, 1010 Commercial Street, Suite A, San Carlos, CA 94070. To protect your privacy and security, we may take reasonable steps to verify your identity before fulfilling your request.  

11. SCOPE OF PRIVACY POLICY

This Privacy Policy does not apply to third party websites (if any) that may be accessed through our Site. We may provide links to other websites that contain information that we believe may be useful to you or that you will find valuable. However, we have not investigated the security of those linked websites and you should not assume those sites have a privacy policy equivalent to ours. If you access such a third-party website through a link we provide, you will be subject to the privacy policy of the new site. Rokid is not responsible for the contents of any linked web pages referenced from our Site. If you have any questions regarding the privacy, security, or content of those sites, you should contact the appropriate contact(s) at those sites directly.  

12. CHANGES TO THIS PRIVACY POLICY

Rokid has the right, at any time and from time to time, to make changes to this Privacy Policy. If the changes are material, we will provide at least 30 days’ notice, by email or by any other means. Any changes to this Privacy Policy will be posted on this Site and will be effective when posted unless another date is referenced in the notice. We recommend you check the Privacy Policy on a regular basis so that you know the current terms and conditions that apply to you. If you use our Site after any changes are effective, you agree to comply with and be bound by them.  

13. CONTACT US

If you have any questions, comments, requests, or concerns related to this Privacy Policy, please contact us at glass@rokid.ai or write to us at Rokid Inc., ATTN: Privacy Inquiries, 1010 Commercial Street, Suite A, San Carlos, CA 94070.

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