Privacy Notice

Contact information: including first and last name, preferred name, phone number, email address, mailing address.

Account information: including first and last name, date of birth / age, alias, user ID, country, language preferences, email address, phone number, avatar, account credentials or one-time passcodes, single sign-on authentication tokens, loyalty and incentive program credits / rewards, and the products or services you purchased or have otherwise used.

Transaction information: including records of purchases and prices, consignee first and last name, shipping address and contact information, shipment tracking details, details of returns, and warranty details.

Payment details: such as invoice / payment records, payment amount, payment date, billing address, payment method. Please note that we use third-party payment providers, including Shop Pay, Stripe, Amazon Pay, PayPal, and Google Pay, to process payments made to us. We do not receive or retain any personally identifiable financial information such as payment card numbers; rather, all such information is provided directly by you to our third-party payment providers. The payment provider’s use of your personal data is governed by their privacy policy.

Information collected from third-party authentication services or other third-party accounts you link to our services: some of our Sites, Applications, products, or services may allow you to log in through a third-party social network or authentication service, such as Amazon, Apple, Google, and Facebook. When you use these single sign-on services to access our Sites, Applications, products, or services, we do not receive your login credentials for the relevant third-party service. Instead, we receive tokens from the single sign-on service to help identify you in our system (such as by your username) and confirm you successfully authenticated with the single sign-on services. In addition to authenticating your identity, these services will, in most cases, provide you the option to share certain Personal Data with us, which could include your name, email address, address book, friend list and other contacts, or other information in your public profile (e.g., profile picture, age range, gender, language, country). The data we receive is dependent on that third party’s policies and your privacy settings on that third-party site.

Product-specific information: we collect or otherwise facilitate the processing of the following types of information in connection with certain of our Sites, Applications, products and services, such as customer content, entertainment-related service information, home-related services information, car-related services information,Baby-related services information,Health-related services information, biometric services information. The specific information collected may vary depending on the product you use. For more information on which product-specific data we collect, please also refer to Annex 2.

Information about your device and network: including the device type, operating system, IP address, browser type, user ID and UUID, or your network (including, for example, a persistent device identifier or advertising ID).

Information about the way individuals use our services and interact with us: including the site from which you came, the site to which you are going when you leave our services, how frequently you access our services, whether you open emails or click the links contained in emails, whether you access our services from multiple devices, and other browsing behavior and actions you take on our services (such as the pages you visit, the content you view, the communications you have through our services, and the content, links and ads you interact with). We employ third-party technologies designed to allow us to collect detailed information about browsing behavior and actions that individuals take on our services, which may record your actions down to the level of mouse movements, scrolling, clicks, and keystroke activity on our services.

Event, contest, promotion, and survey information: including information provided when you sign up for an event, enter a contest or promotion, complete a survey or submit a testimonial.

Feedback and support information: including the contents of custom messages sent through the forms, email addresses, photographs or videos you file, or other contact information we make available to customers, as well as recordings of calls with us (where permitted by law).

Fulfill our contractual obligations, to deliver the products and services you have requested, including facilitating your messages to other users or groups and for account and contract management (including customer support);

Communicate with individuals, including via email, text message, social media and/or telephone and video calls;

Review our business performance;

Market our products and services to businesses and individuals, including through email, direct mail, phone, text message or online advertising. This may include targeted advertising and retargeting;

Administer, improve and personalize our products and services, including by recognizing an individual and remembering their information when they return to our Services and analyzing our customer base;

Process payment for our services;

Conduct market research;

Opportunity tracking, conversion and lead generation;

Test, enhance, update and monitor the products and services, or diagnose or fix technology problems;

Help maintain the safety, security and integrity of our property, products and services, technology assets and business;

Enforce our contractual rights, including without limitation, and to the extent applicable, the LOOPGEAR Terms of Service, General Terms and Conditions, Software Terms of Service; any addenda thereto or other applicable terms.

Resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties;

Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and

Enable functions of our Sites or Applications, including creating profiles, using our online-shop and rating products.

Display certain functionalities of our Sites or Apps in connection with third parties, such as the trusted shop banner, shipment tracking or product videos;

Enable you to use certain functionalities of our products；

Offer discounts to certain groups, such as students;

Decide whether to enter into a business partnership, such as the affiliate program or the merchant program;

Comply with legal obligations.

Perform our contractual services or prior to entering into a contract with you: If you order products or services from us or if you contact us to request our products or services, we use your Personal Data to provide you with these products or services, including for account and contract management, to facilitate user benefits and services, including customer support and process payment for our products and services or with information that may be relevant for you to decide on whether you want to order our products and services;

Justified by our legitimate interests: The usage of your Personal Data may also be necessary for our own business interests. For example, we may use some of your Personal Data to update and monitor the services, or diagnose or fix technology problems; help maintain the safety, security and integrity of our property and services, technology assets and business; enforce our terms, resolve disputes, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties; and prevent, investigate or provide notice of fraud or unlawful or criminal activity.

Consent: In some cases, we may ask you to grant us separate consent to use your Personal Data. In this case, you can revoke your consent at any time with effect for the future.

Compliance with legal obligations: We are obligated to collect or retain certain Personal Data because of legal requirements, for example, tax or commercial laws, or we may be required by law enforcement to provide Personal Data on request.

LOOPGEAR Affiliates: We share Personal Data amongst the legal entities that make up the LOOPGEAR group, for legitimate business purposes and the operation of our Sites, Applications, products, and services for you, in accordance with applicable law. These legal entities may use your Personal Data in the manner described in this Privacy Notice.

Legal Obligations and Rights: We may disclose Personal Data to third parties, such as legal advisors and law enforcement agencies, regulators, other authorities and other third parties for legal reasons if we reasonably believe that such action is necessary:

Third party Processors: We share Personal Data with third party contractors and service providers subject to reasonable confidentiality terms. The services provided on our behalf by such third-party contractors and service providers may include email service providers; marketing/advertising service providers; call service providers; video shopping support and showroom service providers; text message service providers; venue operators; payment services providers; shipping companies; and postal carriers, subject to the requirements noted below in this Section (6). These Processors support us in processing the types of Personal Data described above in Sections (1), (2), and (3), and for the purposes described in Section (4). They only are authorized to process that information as necessary and as directed by us;

Advertising networks: To efficiently market our products and services to you, we may share Personal Data with so called advertising networks. These parties may collect information automatically from your browser or device when you visit our websites and other services through the use of cookies and similar technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. For more information about how these technologies work and certain choices you may have in relation to these technologies, please refer to Section (13) below;

Business and marketing partners: We may also disclose Personal Data with other business and marketing partners with whom we jointly offer products or services or who are part of our partner program. We may obtain your consent where required by applicable law.

Third party services integrated in our services (for instance, third party voice-assisted technologies may receive information you choose to share directly with them);

Individuals you choose, for example through our device-sharing function; we recommend you share information with only people you trust;

Independent advisors: We may disclose Personal Data to our independent advisors such as accountants, auditors, consultants, lawyers, and other outside professional advisors to LOOPGEAR, subject to binding contractual obligations of confidentiality;

Corporate Transactions: if LOOPGEAR is involved in a corporate business transaction, such as a merger, acquisition, or sale of all or a portion of our company assets, we may disclose Personal Data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. If LOOPGEAR completes such a corporate business transaction, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership; and

We may also disclose your Personal Data to any other third party or publicly with your prior consent or direction.

permanently delete or destroy the Relevant Personal Data; or

anonymize or deidentify the Relevant Personal Data.

the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);

the right to request access to, or copies of, your Relevant Personal Data, together with additional information, such as information regarding the nature, Processing and disclosure of those Relevant Personal Data;

the right to request rectification of any inaccuracies or incompleteness in your Relevant Personal Data;

the right to request, on legitimate grounds:

the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;

the right to request the deletion or removal of your Relevant Personal Data where there is no other legal basis for us to keep using it. Please note that we may not be able to immediately remove the information from the backup system due to applicable laws and regulations or technological limitations. If this is the case, we will isolate your Relevant Personal Data from further processing until the backup can be deleted or be anonymized / deidentified .

where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases).

in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and

where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

Identifiers, such as first and last name, preferred name, phone number, email address, unique personal identifiers, and online identifiers.

Customer records, such as contact information, address book information, and account information.

Protected classification characteristics, such as age, gender, and health status.

Commercial information, such as records of purchases and prices, shipping address and contact information, and details of returns, and consumer histories and tendencies.

Biometric information, such as facial, fingerprint or other biometric recognition technology results processed and maintained solely on the user’s device (see below for more detail).

Internet / network information, such as the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network.

Geolocation data, including general geographic location, as well as more precise geolocation when you grant us access through your device settings (see below for more detail).

Audio, electronic, visual, thermal, olfactory, or similar information, including voice prompts / recordings and security /service images and video.

Professional / employment information, such as employer and job title.

Sensitive personal data, such as account credentials, biometric information, health data, and precise geolocation (as further described below).

Other Personal Data, such as your communication preferences, entertainment preferences, home configuration (for our home-related services), participation in our loyalty and incentive programs, and any other Personal Data you choose to share in custom messages sent through the forms, email addresses, or other contact information we make available to customers.

Inferences, including consumer preferences, predispositions, and characteristics.

Account credentials.

Payment card information (collected and processed solely by our third-party payment providers; LOOPGEAR does not have access to this data).

Biometric information (collected and processed solely on the user’s device; LOOPGEAR does not have access to this data).

Health metrics, including sleep patterns, movements, heart rate, height, weight, and body mass index .

Precise geolocation data.

Right to Know. The right to confirm whether we are processing Personal Data about you and, under California law only, to obtain certain personalized details about the Personal Data we have collected about you, including:

The categories of Personal Data collected;

The categories of sources of the Personal Data

The purposes for which the Personal Data were collected;

The categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom this Personal Data were disclosed;

The categories of Personal Data shared for targeted advertising purposes (if any), and the categories of recipients to whom the Personal Data were disclosed for these purposes; and

The categories of Personal Data sold (if any) and the categories of third parties to whom the Personal Data were sold.

Right to Access & Portability. The right to obtain access to the Personal Data we have collected about you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

Right to Correction. The right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.

Right to Control Over Sensitive Personal Data. The right to exercise control over our collection and processing of certain Sensitive Personal Data.

Right to Opt-Out of Targeted Advertising. The right to direct us not to use or share Personal Data for certain targeted advertising purposes.

Right to Opt-Out of Sales. The right to direct us not to sell Personal Data to third parties.

Right to Deletion. The right to have us delete Personal Data we maintain about you (subject to certain exceptions).

“Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.

“Application” means any applications operated, or maintained, by us or on our behalf.

“California Resident” means (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.

“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Privacy Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.

“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.

“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.

“EEA” means the European Economic Area.

“GDPR” means the General Data Protection Regulation (EU) 2016/679.

“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).

“Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

“Relevant Personal Data” means Personal Data in respect of which we are the Controller.

“Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. A business does not sell personal information when:

“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.

“Site” means any website operated, or maintained, by us or on our behalf.

Customer content: including any files, documents, audio, videos, images, data, or communications you choose to input, upload, or transmit to our Sites, Applications, products and services. In addition, certain of our Sites, Applications, products, and services may allow you to collect or process additional customer content directly on your device without transferring such content back to LOOPGEAR. For example, you may generate voice prompts when you use one of our voice-assisted technologies, such as our smart speakers, and transfer your voice prompts to your third-party voice-assistant service account (such as Amazon’s Alexa or Google Assistant) as a command. We may also enable you to collect images and video through certain of our products, such as the Roav Dash Cam and eufy security cameras. Note that depending on where you live, the surveillance laws in effect in your jurisdiction, and how you configure our services, you may need to obtain explicit consent from individuals before using our products to create and save video or images of them or provide notice informing visitors to your home that our products or services are in use. It is your responsibility to ensure that you comply with all such applicable laws.

Entertainment-related service information: when you use our entertainment-related services, include our Nebula Smart Projectors and SoundCore speakers and headphones, we collect information about your entertainment preferences, including audio / video settings, and the entertainment services you like to engage with. With your permission, we will also read call status for the SoundCore music player so that music played before a call can be paused and resumed after the call ends. With your permission, the SoundCore app may also seek permission to access your mobile device’s microphone to enable you to take advantage of certain speech-based speaker / headphone features. You may refuse or withdraw your permission at any time through the privacy settings of your mobile device.

Home-related services information: when you use our home-related services, including eufy Clean, eufy Pet and eufy Security, we collect information about your home and your activities around your home, including the location of your home, home environment data (such as level of dirt, smart device movement, floorplans and room names, existence and types of objects within the home, and floor type), pet information (such as pet type and activity), home occupancy data (such as the presence or absence of individuals within your home zone or specific areas of your home at any given time), home monitoring audio, images and videos (such as alerts triggered by your home security system). Note that depending on where you live, the surveillance laws in effect in your jurisdiction, and how you configure our services, you may need to obtain explicit consent from individuals before using our products to create and save video or images of them or provide notice informing visitors to your home that our products or services are in use. It is your responsibility to ensure that you comply with all such applicable laws.

Car-related services information: when you use our car-related services, including Roav DashCam, SmartCharge and Viva, information about your vehicle, such as the first nine digits of your VIN to confirm your vehicle’s make, model and year, and your driving experience, including the precise location of your vehicle, engine start/stop and idle times, your vehicle’s speed, braking and acceleration metrics, and your driving route, are collected locally on your device and/or mobile application.

Baby-related services information: when you use our baby-related services, including the eufy Baby Monitor and Smart Sock, we collect information that you choose to share about your baby, including your baby’s name, gender, due date or date of birth, weight, photographs, monitor images and video, and, when using the eufy Smart Sock, sleep patterns, nap patterns, movements, heart rate, and blood oxygen levels.

Health-related services information: when you use our health-related services, including the eufy Smart Scale, eufy Blood Pressure Monitor, and SoundCore health-connected devices, information that you choose to track in relation to your personal health, including weight, height, body mass index, body fat percentage, muscle mass, heartrate, water content, basal metabolic rate, visceral fat, lean body mass, body fat, bone mass, body age, protein, subcutaneous fat percentage, body type, skeletal muscle mass, blood pressure, blood oxygen, posture, calories burned, duration of exercise, and sleep metrics, such as estimated sleep time through real-time monitoring of sleep environment sound (though we will not store the underlying sound file), are collected by us or are otherwise maintained locally on your device and/or mobile application.

Biometric services information: certain of our services leverage biometric technologies (such as facial recognition tools) when a user chooses to turn on biometric-related features, such as face images and underlying face prints. In particular, we may provide you the ability to (i) log in to our Applications or authenticate yourself using facial, fingerprint or other biometric recognition technology available through your mobile device, or (ii) leverage facial recognition technology on your eligible eufy device to determine whether an individual in the device’s field of vision is a “familiar face” or a stranger. We do not store or have access to this biometric information. Instead, the applicable biometric assessment process is conducted entirely on your device. We may, however, receive confirmation of the results of the biometric assessment, such as in the form of a token from your mobile device indicating you successfully authenticated using biometric recognition technology or an alert attached to your security account indicating your camera saw a “familiar face” or a stranger. Depending on where you live, the laws in effect in your jurisdiction, and how you configure our services, you may need to obtain explicit consent from individuals before using our products to create, save and analyze video or photographic images of them (including to conduct biometric processing of their images) or provide notice informing visitors to your home that our products or services are in use. It is your responsibility to ensure that you comply with all such applicable laws.
Last Updated:  September 3rd, 2024