UBTECH uKit Educational Module Robot Privacy Agreement

Ubtech Robotics Corp. (hereinafter referred to as "UBTECH" or "We") respects your privacy rights. This privacy notice explains who We are, how We collect, share and use your personal information, and how you exercise your privacy rights. This privacy notice applies to the personal information We collect through our product - uKit Educational Module Robot, the APP (uKit EDU) and CBI operation platform , as well as your use of our services ("Services").

If you have any questions or concerns regarding our use of your personal information, please contact us using the contact details at the bottom of this privacy notice.

What Are Our Products and Services?

Founded in 2012, Ubtech Robotics Corp. is a global high-tech enterprise integrating artificial intelligence and humanoid robot development, platform software development and application, as well as product sales. UBTECH has established a joint laboratory for intelligent service robots together with Tsinghua University. UBTECH is actively creating a "hardware + software + service + content" robot ecosystem and striving to become a world-class technology company in the artificial intelligence and humanoid robot sector, committed to realizing the dream of introducing robots into people's life.

Our uKit educational module robot is an educational robot used in STEAM education field, providing users with academic services such as model building, logic programming and robot control applications.

For more information about UBTECH, please refer to the Company Profile section of our website.

Personal Information We Collect and Why We Do It

We may collect your personal information, which can be divided into the following categories:

Information You Voluntarily Provide

In order to use our services, including robotic model building, logic programming and remote control operations, We will ask you to voluntarily provide the following personal information and authorization:

  • Contact information such as your nickname, phone number, email address and gender, used for account registration and identification.
  • We may collect your approximate location information based on the IP address of your device. We may also detect the time and address of your activation of the uKit robot. In addition, We will improve user experience based on the information.
  • Usage data is the information about how users use our App. We will collect the data in order to better understand how users use our products. The usage data We may collect includes: the features you used and the operations you performed; the time, frequency, and duration of your online activities; the pages you visited; the links you clicked; the content, images, and videos you viewed.
  • We may collect information about the model of the device and the version of the software you use, its available memory or operating space, and Bluetooth signal, as well as the hardware parameters, firmware version and system statusof the uKit robot for diagnostics and analysis of possible hardware and software defects to improve user experience.
  • We may access the settings of your device, including: language, for the purpose of providing the content in relevant language; region and country, for the purpose of providing the content that matches your location; and network information used, for the purpose of mobile traffic alerts. At the same time, We will request relevant authorization of your device, such as photo taking, photos, and Bluetooth to provide corresponding product features.

We use the personal information to facilitate your use of the product. We will explain what personal information we need and why We need it to you when We ask you for the personal information.

Information We Collect Automatically

When you use our uKit product and App, We may automatically collect your specific information from your device. In some countries, including countries in the European Economic Area (EEA), the information is considered personal information according to applicable data protection laws.

In particular, the information We automatically collect include your IP address, unique device identification number, and other technical information. We may also collect information about how your device interacts with our App, including the App pages you visited and the links you clicked. The information is used only as overall data statistics and will not be assigned to a personal account or specific device;

The information helps us understand more about the users of our robots and what features of our robot they are interested in. We use the information for internal analysis purposes to enhance the features and experience of the robots.

Information We Obtain from Third Parties

We may obtain personal information about you from third party sources from time to time, but this only happens when We confirm that the third party has obtained your consent, or that the third party is legally permitted or required to disclose your personal information to us.

Unless prohibited by applicable laws, We will use your information in the manner detailed below:

  • Provide you with the products and services you request.
  • Communicate with you about your account and send you information about changes to the features or policies of our products and applications.
  • Other users send you messages in a public way.
  • Detect, investigate and prevent activities that may violate our policies or illegal activities.

At the same time, We will work with third-party partners to improve the products or services We provide to you, and may need to share data other than your personal data with third-party partners. Below are the types of third-party partners We may share information with and the information We may share and purposes of the sharing:

  • Share information with application data service providers to obtain statistics and analysis of content usage, user behavior data, use of data for products, operations, and promotion decisions.
  • Share information with application exception monitoring service providers to enable us to discover application exceptions in a timely manner, quickly locate and solve problems with the help of device attributes, system information and usage data.

In general, We will only use the personal information We collect for the purposes described in this privacy notice or for the purpose We explain to you when We collect your personal information. However, if local applicable data protection laws permit, We may also use your personal information for purposes different from what We explain to you (e.g., for public interest, scientific or historical research, or statistics).

With Whom Do We Share Your Personal Information?

We may disclose your personal information to entities in the following categories:

  • Our group corporation, third-party service providers, the partners that provide us with data processing services (e.g., service providers that support our speech recognition and semantic understanding), or the partners that deal with personal information in other ways for the purposes described in this privacy notice, or for the purposes We explain to you when collecting your personal information.
  • We believe that it is necessary to disclose your personal information to any competent law enforcement agency, regulatory agency, government agency, court or any other third party, for any of the following reasons: (1) required by applicable laws; (2) for exercise, establishment, and maintenance of our legal rights; or (3) for protecting your or others' interests.
  • Communicate with any actual or potential purchaser (and its agent or consultant) about any actual or proposed purchase, merger or acquisition of any part of our business, but We should notify the purchaser that your personal information must be used only for purposes mentioned in this privacy notice.
  • Disclose to anyone else after obtaining your consent

Legal Basis for Processing of Personal Information (only for visitors and users in the EEA)

If you are a visitor or user in the EEA, the legal basis for our collection or use of personal information above will depend on the relevant personal information and the specific context in which We collect personal information.

However, usually We only collect your personal information in the following circumstances: (1) your personal information is needed to perform a contract concluded with you; (2) the information processing is in line with our legitimate interests and you don't have any other prior right thereon; or (3) We have obtained your consent. In some cases, We may also be obligated to collect your personal information, or We may need the personal information to protect your or others' interests.

If We request you to provide personal information for compliance purposes or for fulfilling a contract concluded with you, We will clearly state and inform you within relevant time whether you are under mandatory requirements to provide personal information (and the consequences if you fail to provide the personal information).

If We collect or use your personal information for our own legitimate interests (or the legitimate interests of any third party), this benefit is usually for the purpose of: operating our company and communicating with you when necessary, so as to provide our services to you, and for the purpose of achieving our legitimate business interests, e.g.: replying to your questions, improving our products or services, marketing or inspection, and ensuring compliance with laws. In addition, We may have other legitimate interests.

If you have any doubts about the legal basis for our collection and use of personal information or if you need further information, please contact us using the details under the heading “How to Contact Us”.

How Do We Protect Your Personal Information?

We use appropriate technical means and organizational measures to safeguard the personal information We collect about you. The measures We take provide you with the security that matches the risk of processing your personal information. The specific measures We take include Secure Sockets Layer (SSL) encryption to ensure that your data is securely transferred from your browser to our network system.

Your personal information will be stored on a secure server and protected in a controlled facility. We classify your data by importance and sensitivity and ensure the highest level of security for your personal information. We guarantee that employees and third-party service providers who provide products and services to you by accessing the information have strict contractual confidentiality obligations, and if they fail to fulfill these obligations, they will be subject to disciplinary actions or termination of cooperation. Similarly, We have dedicated access control measures for cloud-based data storage. In summary, We regularly review our information collection, storage and processing practices, including physical security measures, to prevent any unauthorized access or use of your personal information.

We will take all practicable measures to protect your personal information. However, you should be aware that the use of the Internet is not always secure, therefore We cannot guarantee the security or integrity of any personal information when transmitted in both directions over the Internet.

We will promptly notify the relevant regulatory authorities about the disclosure of personal data, and in some special circumstances, notify the data owner of relevant data slope events to meet relevant applicable laws, including data protection regulations in your location.

At the same time, your assistance will help us protect the privacy of your personal information.

  • You can protect your personal information by not disclosing your login password or account information to anyone (unless duly authorized by you). Whenever you log in to the uKit App or other UBTECH products as an UBTECH account user, especially when logging in on someone else's device or public Internet terminal, you should always log out after the session is finished.
  • UBTECH is not liable for any security loophole in the event of any third party's access to your personal information due to your failure to maintain the privacy of your personal information. Notwithstanding the foregoing, you must notify us immediately in the event of unauthorized use of your account by any other user on the Internet or any other security loophole.

International data transmission

Your personal information may be transferred to countries other than your country of habitual residence for processing in those countries locally. The data protection laws in these countries may differ from your country (and your data may not be protected in certain situations).

Specifically, our third-party service providers and partners are located all over the world, and this means that when we collect your personal information, we will process the data in these countries where our providers and partners are located.

However, we have adopted appropriate security measures to protect your personal information in accordance with this privacy notice. This includes the implementation of the standard contractual clauses for the transfer of personal information within our group as dictated by the European Commission, which explicitly require our group to protect personal information obtained from within the European Economic Area according to the data protection law of the European Union.

We have already included the relevant requirements in our standard contract terms.

Data Storage

In order to support our sustained and legitimate business development needs, we may store personal information collected from you.

Whenever there is an adjustment in our sustained and legitimate business development needs, we will delete your personal information or make its source anonymous. If we are unable to adopt such measures (for example, because your personal information is stored in a backup or archive), we will store your personal information securely and prevent any further processing of this information until such time when this information can be deleted.

Your Data Protection Right

In the process of using our products or services, you have the right to access, modify, move and delete your own data.

  • You have the right to request access to and/or correction of any personal information We hold about you. When you update your personal information, you will be asked to verify your identity before We process your request. Once We have sufficient information that We may process your request for accessing or correcting your personal information, We will respond to your request within the time specified in the applicable data protection laws and regulations.
  • If you wish to request access to personal data held by us or if you believe that any information We hold about you is incorrect or incomplete, please contact us by sending a letter to us or by emailing us at the email address provided.
  • If you are an EU user under the General Data Protection Regulation, you have the right to ask us to delete your personal data. We will conduct an evaluation based on your deletion request. If the request complies with provisions of the General Data Protection Regulation, We will take corresponding steps including technical means to process it.
  • If you are an EU user under the General Data Protection Regulation, you have the right to ask us to restrict the processing of your personal data. We will conduct an evaluation according to your request for restriction. If the request complies with provisions of the General Data Protection Regulation, We will process your data according to the specific conditions applicable in the Regulation and notify you before canceling the restriction.
  • If you are an EU user under the General Data Protection Regulation, you have the right not to be bound by completely automated decision-making, including a user portrait that may have a legal effect or similar significant impact on you.
  • If you are an EU user under the General Data Protection Regulation, you have the right to receive your personal data in a structured and generic form and transfer it to other data controllers.

If you need to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings, you can:

  • Log in or log out of your account;
  • Delete any information stored in your account in the App;
  • Cancel your account in the App and be aware of all your personal data;
  • Enable or disable other services and features that involve your sensitive or personal information, such as geographic location information.
  • If you have previously agreed to our use of your personal information for the above purposes, you can change your decision at any time by contacting us in writing or by emailing us at the email address provided.

Children Privacy Policy

uKit insists on protecting the privacy of children who use our products. Under the US Children's Online Privacy Protection Act, children under the age of 13 are required to use our products under the supervision of parents or guardians. According to the special provisions of the EU's General Data Protection Regulation regarding protection of children's personal data, member states are allowed to adjust the standards of children's age between 13 and 16. Children under the age of 13 in the United States and children aged between 13 and 16 in the European Union are collectively referred to as children. The following is a description of the information provided to these users, our approach to information collection and disclosure that parents consent.

Register

It is recommended to register in this product under the guidance of the school for use by children. During the registration process, each child will be asked to enter the date of birth to ensure that the age of the registrant meets the statutory requirements. In this case, the email address of a parent, teacher or guardian is required so that the adult can create a user name and password for the child. We strongly recommend that adults do not provide any personal information about children in their user names. At the same time, We will not ask for any information that is not required for login.

If you suspect that your child or student is trying to use our platform and you have not received a notice from us asking for parent or guardian's consent, please feel free to contact us at any time.

Content Created by Children

We allow children to create and save content. Personal information may be included in the content created, including programs, images, videos, comments, and posts. Parents or teachers can refuse to post any content created by children, or they can decide that only children and their guardians can view the content. Otherwise, the content will be sent to the uKit administrator of the uKit robot platform, and the administrator can properly refuse to post certain content before public release. The uKit administrator is the only person who has the right to refuse to post any inappropriate content. The reasons for refusing to post any content are as follows:

  • pornographic content that contains sexual behavior or nude pictures.
  • aggressive content that propagates violence, causing physical harm to humans and/or animals.
  • Hatred or defamatory content that incites hostility to protected groups, minorities, and even individuals.
  • Child abuse content that contains sex, predatory or abusive information about minors.
  • Spam or misleading content massively posted or otherwise misleading readers.
  • Fraudulent content that violates the uKit protocol (such as uKit intellectual property and/or uKit privacy policy and terms of use).

About Verifiable Instructor Consent

If uKit is to collect personal information about children, the Children's Online Privacy Protection Act ("COPPA") requires us to first seek the consent of parents, teachers or guardians by email. In the email, We will explain what information We collect and how We plan to use or delete it. If We do not get parents' consent within a reasonable time, We will delete the contact information of the instructor completely.

In school activities, COPPA allows teachers and school administrators to act in place of parents or guardians unless they notify parents or guardians of such activities to obtain consent from parents or guardians. In general, schools should always notify parents of these activities.

Circumstances Where Others Can Obtain the Children's Information Collected

In addition to publicly publish children's personal information (parental consent must be obtained), We may also share or disclose children's personal information collected in the following limited circumstances:

  • We may share the information required for functional support to us with bulletin board solution team.
  • We may disclose personal information if required by law (e.g. responding to a court order or subpoena). To the extent permitted by applicable law, We may also disclose children's personal information in response to requests from law enforcement or public agencies; We may also do so if We believe that the disclosure may prevent abetting and ultimately protect the security or integrity of our platform.

Instructor Selection and Control

Parents, teachers or guardians can modify children's passwords, user names, user avatar pictures or delete their accounts at any time to prohibit children from accessing the uKit robot platform. Deleting an account will immediately block the display of any publicly posted content. If you have problems while editing or removing children's information, please email us at the email address provided to seek our assistance.

Update of This Privacy Notice

We may update this privacy notice from time to time to accommodate legal, technical or commercial developments. When We update this privacy notice, We will notify you in an appropriate manner to meet our intention of revising it. If any applicable data protection law requires us to obtain your consent before substantial revision of this privacy notice, We will comply with the law. You can view the latest update date of this privacy notice at the date of the” latest updates” at the top of this privacy notice.

How to Contact Us

If you have any questions or concerns regarding our use of your personal information, please contact us using the details below:

For Chinese users: 4006666700, email: ucare@ubtrobot.com

For users in North America: 800-276-6137, email: ubtechedu.support@ubtrobot.com

International hotline: 408-846-1329, email: ubtechedu.support@ubtrobot.com

The data controller of your personal information is Ubtech Robotics Corp.