Privacy Policy
Last Updated: [·] September 2024
Xi’an NovaStar Tech Co., Ltd. and its affiliated companies (hereinafter referred to as "NovaStar" or "we") are committed to protecting and respecting your privacy. Therefore, we have developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal data while you use our Vnnox Care software (“Services”). Please read carefully and familiarize yourself with our privacy practices before using our Services or providing your personal data.
This policy will help you understand the following:
I Definitions
II How We Collect and Use Your Personal Data
III How Long We Keep Your Personal Data
IV How We Disclose Your Personal Data
V How We Protect Your Personal Data
VI Your Rights with Regards to Your Personal Data
VII How We Process Children's Personal Data
VIII Third-Party Service Providers and Their Services
IX How Your Personal Data Is Transferred Globally
X How This Privacy Policy is Updated
XI Contacting us
I Definitions
“Affiliated Company” refers to a company that is related to NovaStar due to joint ownership or control.
“Third Parties” refer to companies or persons who do not have a related relationship arising out of joint ownership or control with NovaStar (i.e., a non-affiliated company) or other non-related persons. Third parties can be financial or non-financial companies, or persons other than you and NovaStar.
“Personal Data” refers to any information relating to an identified or identifiable natural person.
II How We Collect and Use Your Personal Data
We collect data to improve operational efficiency and to optimize your product experience. Our channels for collecting personal data include: (1) you providing your data to us directly, (2) we obtaining certain data about how you interact with our Services. The data we collect depends on the environment in which you interact with NovaStar, the choices you make, such as your privacy settings and the Services you use.
1. Personal data we collect
(1) Personal data directly provided by you
The Services we provide require you to provide certain personal data directly to us. For instance.
a. Applying for a main account ID and initial password requires you to provide personal data such as your name, company name, business email, company address, company scale, business type, ,you may also provide your phone number or email address for basic authentication during account registration.
b.Registering a sub-account ID requires you to provide personal data such as account name, password, your name, function permissions, associated screens.
We may ask you to provide personal data under other circumstances, such as when you contact us for customer support, register to receive our questionnaire survey, newsletter, or participate in promotional or marketing activities organized by us or our business partners. The information you provide helps us design and improve the Services. We may match your personal data with third-party data to better understand your needs.
(2) Service usage information
In addition to the information you provide, we may also collect information about your use of our Services through software on your device and other means. We may collect the following information.
a. Product information — such as NovaStar products: SN number, product version, region, operating system version, product model, product warranty, product IP.LED screen information: LED screens name, configuration files, backup files, operating status such as temperature, humidity, configuration information, voltage, equipment connection state, network port state, registered time, LED display resolution etc.
b.Device information — such as Memory Utilization, device memory, device hardware information and status, usage habits, IP address, operating system version, settings of the device used to access our Services.
c. Location information — such as the city level location of the NovaStar products, the longitude and latitude of the GPS signal of your product.
d. Photos, videos and messages information -information about the filename and file size of your photos, videos and messages uploaded when you access our Services;information about the content of photos, videos and messages uploaded when you access our Services;
We may also collect other information about your use of our Services — such as the version of the application being used, the website visited, and how you interact with the content provided through our Services.
2. How we use your personal data
(1) We may process your personal data for the purposes described in this Privacy Policy, to perform our obligations to you under our user agreement and/or service contract,
a. with your prior explicit consent which can be withdrawn at any time at your request;
b.so that we can perform or carry out a contract with you in relation to our Services;
c. for compliance with a legal obligation to which NovaStar is subject;
d.when necessary for the purposes of the legitimate interests pursued by NovaStar or a third party to whom it may be necessary to disclose information. Where we process your information in reliance on such grounds, we will only do so where we have appropriately balanced such interests against your right to privacy. Such legitimate interests may include (without limitation), as follows:
· Providing Services. The personal data we collect will be used to provide you with Services, or fulfil the contract between you and NovaStar to ensure the functionality and safety of our Services.
· Customer support. We use data to diagnose product issues, repair customer equipment, and provide other customer care and support services. We also use this information to improve our products and analyse the efficiency of our business operations. We may also use your phone number, email address to reply your questions or comments.
· Product improvements. We use data to constantly improve our Services, including the addition of new features and functionality.
(2) We will strictly abide by the terms of this Privacy Policy and any updates to it (any material changes to the Privacy Policy will be notified to you according to Section X) when we use your personal data. Your personal data will only be used for the purposes determined at the time it is collected.
(3) When we want to use the information for other purposes not covered by this Privacy Policy, we will notify you and ensure we comply with applicable requirements.
(4) We do not take any decisions involving the use of algorithms or profiling that significantly affects you. If certain of our Services require us to do so in the future, we will inform you in advance.
(5) We may use your personal data such as mobile number or/and email address which you’ve provided to us when Registering an account ID to sending marketing messages and delivering marketing after obtaining your prior explicit consent.
III How Long We Keep Your Personal Data
Our retention period for personal data is the minimum time necessary to realise the purpose of collection unless a longer retention period is required by law. Beyond the above retention period, we will delete or anonymise your personal data.
IV How We Disclose Your Personal Data
1. At times NovaStar may make certain personal data available to affiliated companies and other third parties that work with NovaStar necessary to provide Services. Your information will not be shared with third parties for their own independent marketing or commercial purposes.
(1) Affiliated Companies: your personal data may be shared with NovaStar’s affiliated companies. We only share necessary personal data subject to the purposes stated in this Privacy Policy.
(2) Sharing with other third parties: to realise the purposes stated in this Policy, some of our Services will be provided by other third parties. We may share some personal data with them to provide better services and user experience.
(3) If we sell any of our business or assets, we may need to disclose your personal data to the prospective buyer for due diligence purposes and on completion of the sale.
We will only share your personal data for lawful, legitimate, necessary, specific and clear purposes, and only personal data necessary for service provision will be shared. Our partners are not allowed to use the shared personal data for any other purposes.
2. We will only publicly disclose your personal data under the following circumstances:
(1) After we obtain your explicit consent;
(2) Disclose in accordance with laws: we may disclose your personal data if it is compulsorily required by laws, such as to comply with a subpoena or other legal proceedings, legal actions or government agencies, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
V How We Protect Your Personal Data
1. We have taken reasonably practical and technical measures to protect the collected personal data related to our Services. While we have taken reasonable measures to protect your information, no websites, Internet transmissions, computer systems or wireless connections are absolutely secure.
2. We have taken safeguarding measures in accordance with industry standards to protect the personal data you provided and prevent data from unauthorised access, public disclosure, use, modification, damage or loss.
3. In case of personal data security incident, we will act, in accordance with the applicable law.
VI Your Rights to Your Personal Data
We respect your legal rights to your personal data. We list below your legal rights and the measures we take to protect these rights.
1. The right to be informed: NovaStar is publishing this Privacy Policy to keep you informed as to what we do with your personal data. We strive to be transparent about how we use your data.
2. The right to access: If you wish to access your personal data, you are entitled to ask us.
3. The right to rectification: If you find that your personal data we hold is inaccurate or incomplete, you are entitled to ask us to make rectifications.
4. The right to erasure: You can submit a request to us to delete personal data if we do not have a legal reason to continue to process and hold it.
5. The right to restriction of processing: You have the right to ask us to restrict how we process your personal data. This means we are permitted to store the data but not further process it unless we are legally entitled to continue processing.
6. The right to data portability: To the extent permitted by laws and regulations, you have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format.
7. The right to object: You have the right to object to NovaStar processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics.
8. The right to withdraw consent: If you have given us your consent to process your personal data but change your mind later, you have the right to withdraw your consent at any time, and NovaStar must stop processing your data.
9. The right to object automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling.
10. The right to lodge a complaint: You have the right to lodge a complaint about the way we handle or process your personal data with the data protection authority of your jurisdiction.
You can exercise your rights by submitting a request to privacypolicy@novastar.tech. In principle, we do not charge a fee for your reasonable request. However, for multiple and repetitive requests that exceed reasonable limit, we may charge a reasonable fee to cover some costs depending on the nature of the request. We may refuse requests that are manifestly unfounded, unreasonably repetitive, or require disproportionate technical effort (for instance, require the development of new systems). In addition, we may not respond to requests that directly concern significant issues of public interest or may cause serious damage to the legitimate rights and interests of you or other individuals or entities.
VII How We Process Children’s Personal Data
1. Our Services are mainly adult-oriented and may not be used by children without guardian consent. A child should not create his/her own user account. We treat anyone under 16 years old (or equivalent minimum age for full legal capacity in relevant jurisdiction) as a child.
2. When we find that a child’s personal data is collected without expressed and verifiable guardian’s consent, we will delete the relevant data as soon as reasonably possible.
VIII Third-Party Services Providers and Their Services
1. Our Services may contain links to third-party websites, products, and services. You can choose whether to access websites, products and services provided by third parties or not.
2. We have no control over third-party privacy and data protection policies and such third parties are not bound by this Privacy Policy. Before submitting personal data to third parties, please refer to the privacy protection policy of such third-parties.
IX How Your Personal Data Is Transferred Globally
1. We provide Services through resources and servers around the world. This means, in compliance with applicable laws, your personal data might be transferred to or accessed from jurisdictions outside of the jurisdiction where you use our products or services.
2. In case your personal data is transferred to countries located outside of the European Economic Area (EEA) and United Kingdom (UK), we will ensure that it will be protected in a manner that is consistent with legal requirements. This can be done in a number of different ways, such as:
(1) the recipient of the personal data is located within a country that benefits from a full “adequacy” decision of the European Commission;
(2) the recipient may have adhered to binding corporate rules (only for intragroup transfers); or
(3) the recipient has signed a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your personal data.
The personal data that we collect from you may also be otherwise transferred to, and stored at, destinations outside the EEA or UK. It may also be processed by individuals operating outside of the EEA and UK who work for our affiliates or for one of our suppliers.
In all cases, however, we will ensure that any transfer of your personal data is compliant with the applicable data protection law.
X How This Privacy Policy Is Updated
We reserve the right to update or modify this Privacy Policy from time to time. If there is any material change to this Privacy Policy, we will notify you by posting a notice on our website or by sending you an email notice or in a form we deem appropriate.
XI Contacting us
Xi’an NovaStar Tech Co., Ltd. is the controller of your personal data and its designated EU representative is NovaStar Technology Europe B.V.
If you have questions or concerns regarding our Privacy Policy or practices, please contact us at:
[No.1699 Yunshui 3rd Road, Software New Town, High-tech Zone, Xi'an, Shaanxi Province, China]
Email: privacypolicy@novastar.tech