【Utonbot Controller】Privacy Policy

[Special Note]

• This Privacy Policy applies to commercial robotic cleaning devices, the Utonbot Controller mobile application, and supporting software systems, cloud platforms, management backends, and related services that may be provided (hereinafter collectively referred to as the "Service").
• The Service is primarily deployed and operated in public places such as malls, hospitals, office buildings, hotels, and transportation hubs; the service targets are mainly corporate customers.
• The Service may be provided within the People's Republic of China and other countries or regions. If cross-jurisdictional needs arise, we will take corresponding compliance protection measures based on applicable personal information and data protection laws.

[Important Compliance Statement] The Service is not intended to identify specific natural persons; We do not actively perform facial recognition, identity identification, or individual profiling; Data collected by commercial robotic vacuum cleaners is mainly used for device operation, safety control, and maintenance management; Corporate customers should legally fulfill the obligation to fully and clearly inform the public on-site about device deployment and data collection. By using the Service as a corporate customer, administrator, or authorized operator (collectively, "Users"), you indicate that you have fully read, understood, and agreed to this Privacy Policy.

1. Information We Collect

1.1 Corporate and Account Related Information

• Enterprise/Organization Information: Enterprise name, Unified Social Credit Code (if applicable), contact person info.
• Account Information: Username, mobile number, email, role permissions, login credentials.
• Authorization Information: User roles, permission configurations, and authorization records.

1.2 Device and Operational Information (Commercial Robotic Vacuum Related)

• Basic Device Info: Device model, serial number, MAC address, firmware version, app version.
• Operational Status Info: Working status, fault info, battery level, consumable status, cleaning area, cleaning duration.
• Location Info: Device positioning info in indoor venues, map data (e.g., floor structure, path planning results).

1.3 Scenario and Environmental Data (Applicable to Public Places)

• Spatial and environmental modeling data collected via LiDAR, depth sensors, ultrasound, infrared, etc.
• If certain robot models or future features provide visual perception, patrol, or camera viewing capabilities, the related image or video data will come from the robot device's own sensors and may be used for real-time obstacle avoidance, safety control, path planning, anomaly detection, or management purposes authorized by enterprise customers.

[Special Note] The aforementioned data collection and processing are not for the purpose of identifying specific natural persons; We use technical means to avoid collecting information that can identify personal identities as much as possible; The App currently does not access the phone camera, photo library, or microphone; If personal images are unavoidably captured in specific public scenarios, they will be processed via blurring, de-identification, instant overwriting, etc., and deleted or anonymized after the necessary period.

1.4 Log and Network Information

• Log Info: Login logs, operation records, command issuance records, exception logs;
• Network Info: IP address, network type, carrier info.
• Permission-related Info: Bluetooth is used to discover and connect robots pending network provisioning; local network and multicast are used to discover robots on the same LAN; Android 11 and earlier may require location permission for Bluetooth scanning compatibility, but it is not used to locate users.

2. How We Use Information

We use information only within a legal, legitimate, and necessary scope, including but not limited to:

• Providing operation, obstacle avoidance, safety control, and cleaning services for commercial robotic vacuum cleaners in public places;
• Realizing remote device management, task scheduling, map maintenance, and O&M support;
• Device fault diagnosis, performance analysis, security auditing, and risk prevention;
• Product and algorithm optimization based on de-identified or anonymized data;
• Sending necessary service notifications, maintenance reminders, and security alerts to corporate customers;
• Fulfilling applicable laws, regulations, and regulatory compliance obligations.

3. Information Sharing, Transfer, and Disclosure

3.1 Information Sharing

We will not sell your personal information to third parties. In the following circumstances, we may share your information legally:

• Sharing with service providers entrusted by us (e.g., cloud computing, data storage, communication services) to realize core functions;
• Necessary for device maintenance, after-sales support, or security protection;
• Obtained explicit authorization from the corporate customer or user;
• Other situations stipulated by laws and regulations.

3.2 Information Transfer

In the event of a merger, acquisition, or asset reorganization, we will require the new recipient to continue to be bound by this policy and fulfill notification obligations legally.

3.3 Information Disclosure

Disclosure will only occur if required by laws, regulations, or judicial or administrative organs.

4. Information Storage, Cross-border Transfer, and Protection

4.1 Information Storage

• Information will be stored for the period necessary to achieve the service purpose.
• Data storage location is determined based on the service deployment region and applicable laws.

4.2 Cross-border Data Transfer

If cross-border data transfer is involved due to overseas deployment, global O&M, technical support, or cloud services, we will take necessary compliance measures legally, including but not limited to:

• Signing Standard Contractual Clauses (SCCs);
• Conducting Data Protection Impact Assessments (DPIA);
• Fulfilling necessary notification or obtaining corresponding authorization.

4.3 Security Measures

We protect information security through encrypted transmission, access control, permission grading, log auditing, etc., and continuously improve security protection capabilities.

5. Your Rights (Corporate Customers and Authorized Users)

To the extent permitted by applicable law, you enjoy the following rights:

• Inquire and copy relevant information;
• Correct or supplement inaccurate information;
• Delete information under circumstances compliant with the law, or request account and related data deletion through the contact information stated in this policy;
• Manage account permissions and authorizations;
• Submit opinions or complaints regarding our information processing behavior.

6. Compliance and Liability Statement

• Corporate customers should ensure that their use of the Service in public places complies with local laws and regulations;
• Corporate customers should legally fulfill the obligation to fully and clearly inform the public on-site about environmental or image data that the device may collect;
• Legal liability arising from the corporate customer's failure to perform the aforementioned obligations or illegal use of the Service shall be borne by the corporate customer.

7. Protection of Minors

The Service does not target minors. If minor activity areas are involved in places like malls or hospitals, corporate customers should legally fulfill corresponding guardianship and notification obligations.

8. Updates and Application of This Policy

• We may update this Privacy Policy based on business development, changes in service regions, or legal updates, and notify via announcements, system prompts, etc.
• If laws in different countries or regions have higher requirements for personal information protection, we will provide corresponding supplementary protection measures legally.

9. Contact Us

If you have any questions, opinions, or complaints regarding this Privacy Policy, please contact us:
Email: [ut.market@emdoor.com]
Phone: [+86-185-8840-2043]