Thank you for choosing UBTECH Robotics Corp. Ltd UPET APP!

We will provide you with detailed information about how we collect, use, and store your personal information when you use the UPET app, the relevant rights that you are entitled to, and other matters in the Privacy Policy of UPET (hereinafter referred to as the "Policy").

The main points, among others, are as follows:

1. For the purposes of the Policy, UBTECH Robotics Corp. Ltd (hereinafter referred to as "we") is UPET's service provider, UBTECH Robotics Corp. Ltd Corp., with its registered address at 22/F, Building C1, Nanshan Zhiyuan, 1001 Xueyuan Avenue, Nanshan District, Shenzhen. Email: ucare@ubtrobot.com.

2. For the purposes of the Policy, UPET refers to the UPET app and its corresponding Smart Cat Litter Box.
3.We will collect some of your personal information after obtaining your authorization or consent. For example, you are required to verify your mobile phone number or email address when you log in for the first time. We will record your mobile phone number or email address. You may also have certain rights, and information about your rights as a consumer can be found in Section 7 below.
4. Target Audience: Minors are not permitted to use our products or services. As a result, our products or services do not request or knowingly collect personal information from minors. If you are minors, you should not use or access our products or services.
5. The Policy may be revised or updated at any time to incorporate changes in our practices regarding the processing of personal data and personal information, as well as changes in applicable laws. We encourage you to read the Policy carefully and to visit this page on a regular basis for any changes we may make in accordance with the Policy's terms.
6. You may obtain relevant supplementary information by consulting our Jurisdiction-specific Appendix.
This policy is last updated on 01/03/2023

I. How Do We Collect and Use Your Personal Information

To ensure the product and services can operate as intended, we need to process your personal information in certain circumstances. We have implemented the appropriate technical and organizational measures to protect the security of personal information in accordance with the requirements of the law.

1. Purpose of collecting personal information

Your personal information will be collected and used for the following purposes during your use of this product:

(a) to help you become a user of UPET and keep your personal information secure;

(b) to help you control the machine and manage your cat's activities through UPET;

(c) to make it easier for you to quickly and conveniently resolve any issues you have while using the product;

2.Types of personal information to be collected

(1) Personal information you provide to us directly
■ Identification information, including your mobile phone number and email address. If you refuse to provide your identification information, you may be restricted to some of UPET's functions or services. You can also choose to enter your name, gender, date of birth, and other information to improve your account. After you voluntarily deregister your account, your personal information will be deleted or anonymized as required by law.
■ Geolocation information. After you grant us permission to access geolocation (under the Google framework of the Android system, the location information must be obtained before a Bluetooth connection is set up) and Bluetooth, the app will collect your geolocation information and connect to the litter box through the Bluetooth scan. Such information will be stored locally only on the device and will not be uploaded to the Cloud. The legality of such information processing is based on your consent. You will be unable to pair the device with your mobile phone if you do not provide the above personal information.
■ Network connection information. We will collect your Wi-Fi information (SSID, Wi-Fi password) in order to connect your machine to the network of the app. Such information will be stored locally only on the device and will not be uploaded to the Cloud. The legality of such information processing is based on your consent. If you refuse to provide the above personal information, you will not be able to use the network connection function.

(2) Information required to be collected to improve the product and provide the services

■ Services and after-sales related personal information. If you contact our customer service hotline to report any issues, we may ask you to provide the necessary personal information for identity verification in order to protect the security of your account. We may also store your contact information (mobile phone number, email address, or other contact information you use or voluntarily provide), the record and content of your call, and other information necessary to provide and record the customer services for you.
■ Cat profile: when you use UPET to sync the data of the relevant device, we will record your cat's profile, including the avatar, nickname, breed, gender, date of birth, activities, toileting, pictures and weight of the cat. Such information is stored separately from your identity information, is not identifiable or associated with it, and is generally not considered personal information.
■ Cat Video Information: We may collect video information related to cat activities using the camera of the Smart Cat Litter Box, such as movement in the area, cat toileting, and triggering of smart scenes so that you can view and manage your cat's relevant toileting data through UPET. The video data includes the recording date, time, triggering event, video length, and video content. Such information is stored separately from your identity information, is not identifiable or associated with it, and is generally not considered personal information.
■ Device and App Operation Information: On the basis of our compliance with our legal obligations, we will receive and record your Smart Cat Litter Box's configuration and cell phone model information, including device failure information, configuration information, and performance information, to analyze the product for operation and maintenance and security assurance, in accordance with the specific permission granted by you during product installation and use. Relevant information includes cell phone model, system version, system time zone, system language, network operator, App version number, device SN, android_id, regular cleaning time, time requiring no disturbance, and other information. Such information cannot identify or be associated with a natural person. For other device information, we will ask you whether you grant the corresponding permission, and we will not receive your relevant personal information until you agree.

II. How Do We Use Cookies and Similar Technologies
To ensure the normal functioning of our services and to provide you with a smoother and easier user experience, we occasionally access small data files known as cookies on your computer, mobile communication terminal, or device. We may collect and store data about your visits to our website or mobile app through a variety of technologies for us to identify you, save you from re-entering registration information or help determine the security status of your account. Such data files may include cookies, clickstreams, webs, and other local storage files provided by your browser or associated apps (hereinafter collectively referred to as the "Cookies"), allowing you to save time by not having to re-enter or re-set your user settings each time you open the app or browser. You can clear the cache in the corresponding settings of your browser or app. Please be aware that some of our services are only available by using Cookies.

III. How do we share, transfer, and disclose your personal information?

We may share your personal information with affiliates for legitimate business operations in accordance with applicable laws. We may use third-party services providers' software development kits (SDKs) to enable the relevant functions described in the Policy, such as data storage, message pushing, and log analysis. To protect data security, we strictly monitor the use of security of SDKs used by service providers to obtain information. We will not transfer or disclose your personal information to any company, organization, or individual, except in the following circumstances:

(1) the information is provided with your prior express permission or authorization.

(2) the information is provided in accordance with laws and regulations, legal process, or mandatory administrative or judicial requirements.

(3) the information is provided as agreed in the relevant agreements signed by you (including the online electronic agreements and the corresponding platform rules) or other legal documents; and

(4) we will require the new company or organization that will hold your personal information to continue to be bound by the Policy in the event of a merger, acquisition, asset transfer, or similar transaction involving the transfer of personal information, or we will require that company or organization to seek your authorization again.

IV. How do we transfer your personal information on a global scale?
We process and back up personal information through our global operation and control facilities. We store operational data in different countries and regions on servers located in different countries and regions. We will take the necessary organizational and technical measures to protect your personal information. If we need to transfer personal information outside of your jurisdiction, whether to our affiliates or service providers, we will abide by the applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing consistent security measures. The specific data storage locations are listed below:

Operating Country/Region

Data Storage Location

The Chinese mainland

The Chinese mainland

EU, UK and Turkey

Germany

USA and other North American countries

USA

Japan and South Korea

Japan

V. How Do We Protect Your Personal Information

When you provide us with your personal information, we will only retain your personal information for as long as it is necessary to fulfill the purposes set forth in the Policy, except where longer storage periods are required or permitted by law. We have appropriate organizational safeguards and security measures in place to protect your personal information against accidental loss, unauthorized use or access, alteration, or disclosure. For example, if possible, we use encryption to transmit and store data. We use access controls and confidentiality undertakings to further restrict access to such data. We advise you to give adequate consideration to the protection of your personal information, particularly your login credentials, password, and other important personal information when using the product. Additionally, we will make every effort to ensure the security of your personal information. In the event of a personal information security incident, we will initiate an emergency plan to prevent the damage caused by the security incident from getting worse and take the initiative to report the disposal of the personal information security incident in accordance with the requirements of relevant laws and regulations and regulators. In accordance with the requirements of relevant laws and regulations, if necessary, we will also inform you of the basic situation of the security incident and the disposal and remedial measures we will take or have taken via App notification, email/SMS, telephone, etc. If it is difficult to inform users individually, we will issue warnings through announcements and otherwise.

VI. How Do We Handle Minors' Personal Information

Our app is not intended for use by minors. If you are a parent or legal guardian and you believe that your child may have given us his or her personal information, please contact us to request an erasure.

VII. How Do We Ensure Your Exercise of Personal Rights

We are committed to observing data protection laws of different countries and regions around the world. Subject to applicable laws, you may exercise the following rights:

Right of access: Subject to any limitations imposed by laws and regulations, you have the right to access and review copies of your personal information;

Right to rectification: if you find that the personal information you provided is inaccurate or incomplete you have the right to update or rectify it;
Right to erasure: you have the right to require us to erase your personal information. If the proper conditions are met, we will evaluate your request for erasure and take the relevant actions, including using technical means. You can request to unregister your account directly from our App. Your cell phone number/email address is used to create your personal account. You can deregister your personal account by clicking your avatar and then entering "Account Management" - "Login Security" - "Deregister Account" in the upper right corner. Please be cautious as all information related to your account may be cleared if you unregister your account.
Right to data portability: you have the right to have your personal data transmitted to other parties.
Right of interpretation: you have the right to request that we notify you of the purposes for which your personal information is used, disclosed, corrected, erased, or otherwise disposed of. Please contact us if you exercise this right.

Right to restrict processing: the right to request to suspend the processing of your personal data.
Refusing automated decision-making: you have the right to refuse the processing of your personal information based solely on automated decision-making if the automated decision-making has legal effect on you or otherwise has a significant impact on you. We will not use your personal information to participate in automated decision-making that has legal or other significant effects.
According to applicable laws, you may also have certain rights, such as the right to be informed about the processing of your data and the right to file a complaint with the authorities, as well as other possible rights. Please contact us if you have any questions about your rights or how to exercise them.

VIII. How to Update the Policy

We reserve the right to periodically update or modify the Policy in response to changing circumstances, such as those related to product functions, services, or organization. Any modification to the Privacy Policy will be posted on this page. If there are material modifications, we will notify you of the modified Privacy Policy via a pop-up window when you log in.

IX. Our Contact Information

If you have any questions about this Privacy Policy or have any complaints or comments about the handling of your personal information, you can contact us through the APP Device interface "More" - "Customer Service", or you can contact us at: Email: ucare@ubtrobot.com Office address: 22/F, Building C1, Nanshan Zhiyuan, 1001 Xueyuan Avenue, Nanshan District, Shenzhen, Guangdong Province We will reply to you within the legally required time frame. If you are not satisfied with our reply, especially if our handling of your personal information has harmed your legitimate rights and interests, you may also file a complaint or tip-off with the data protection regulatory authority.

X. Others
In the event of any discrepancy between the English version and any other language version hereof, the English version shall prevail.