Linklike Personal Information Protection Policy


Date of Publication: March 13, 2025
Effective Date: March 13, 2025

Introduction:
Linklike is a product and service provided by Shenzhen Linglai Technology Co.,Ltd. (registered in C707, Block C, Zhantao Technology Building, at the intersection of Minzhi Avenue and Gongye East Road, Xinniu Community, Minzhi Sub-district, Longhua District, Shenzhen, hereinafter referred to as "we" or "Linklike"). It is our obligation to protect the security of your personal information, and we will provide adequate protection for the security of your personal information in accordance with legal requirements. To this end, we have created the Linklike Personal Information Protection Policy ("this Policy") to help you understand how we handle your personal information and your rights in connection with your use of Linklike hardware, firmware and software.

Software Name: Linklike
  *The basic function of the software is to "monitor and remotely control the operating status of your device after connecting Linklike smart wearable devices (hereinafter referred to as smart devices) using the Linklike software". The software requires a mobile number/ email to log in, and after logging in and bounding the device, you can use its functional services.

Before you are ready to interact with our products, please make sure you read this Policy (especially those marked in bold) carefully and understand the purposes and security measures for which we process your personal information, including how we collect, use, store, share and transfer your personal information. In this Policy, you may enforce your rights related to personal information, such as the right of access, deletion, etc., through our prompts.
At the same time, you have the right to refuse to agree to this Policy, but please be aware that if you choose to refuse, you may not be able to use the relevant services and functions of Linklike in full, or to achieve the results of the services we intend to achieve. Your consent to this Privacy Policy means that you understand the functions provided by the application and the personal information necessary for the operation of the functions, and that you have given the corresponding authorization to collect and use them, but it does not mean that you have separately agreed to the opening of additional functions, the processing of non-essential personal information, the opening of relevant additional functions, the processing of non-essential personal information and the processing of sensitive personal information, we will seek your consent separately according to your actual use. The use of these additional features, the processing of non-essential personal information and the processing of sensitive personal information will be subject to your consent. During the reading process, if you have any questions, comments, suggestions or complaints, please contact us through the contact information in Section IX of this Policy.

This Policy describes:
I. How we collect and use your personal information
II. How we share, transfer and publicly disclose your personal information
III. How you exercise your rights
IV. Safety and security measures
V. Data Retention Period
VI. Protection of personal information of minors
VII. How your personal information is transferred globally
VIII. Statement on policy changes
IX. Contact us

How we collect and use your personal information

Definition

Personal information: all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding information after anonymization.
Smart device: Specifically refer to Linklike smart wearable devices that have the functions of Internet access, data transmission capabilities, and a human-machine interaction interface, or other smart devices that can be bound to the Linklike software.
Application: the mobile app - Linklike App provided by Shenzhen Linglai Technology Co., Ltd. This is an application that can provide users (you) with operation services of smart terminals and data display services.

The types of personal information we collect and the purposes for which we use it

In the course of your use of Linklike services, Linklike will collect the information that you voluntarily provide when using the services or that is generated due to the use of the services in the following manner, in order to provide you with services, optimize our services, and safeguard the security of your account:

Information that you voluntarily provide to us, the purpose of use of such information

Permission type

Scenario or purpose of use

Does it ask for permission when you turn on

Whether the permission can be turned off

Effect of turning off

Phone operating system

Camera

App using camera, profile picture uploading/changing, problem feedback, need to get your camera permission

Yes

Yes

Camera is not available for profile picture upload/change and issue feedback

Android/iOS

Albums

Retrieve your selected image/video information from your phone album for image upload/replacement to profile picture and question feedback

Yes

Yes

Unable to retrieve pictures/videos from your phone album for uploading to profile picture and question feedback

Android/iOS

Local Network (Cellular Data/Wi-Fi)

Mobile cellular data/Wi-Fi to enable App/device updates/device connection

Yes

Yes

Unable to implement App/device updates/device connection

Android/iOS

Bluetooth

Phone searches for nearby devices via Bluetooth and pairs with them

Yes

Yes

Unable to search and connect to devices

Android/iOS

Storage

App reads pictures/video information from phone storage; App writes pictures/video information to mobile phone storage

Yes

Yes

Cannot store, select photo/video information

Android/iOS

Location

Get the list of Bluetooth devices

Yes

Yes

Can't connect with device Bluetooth; can't determine the region correctly and count the usage of devices

Android/iOS

Please note that by turning on any permission, you authorize us to collect and use the relevant personal information to provide you with the corresponding services, once you turn off any permission, you cancel the authorization, we will no longer collect and use the relevant personal information based on the corresponding permission, and cannot provide you with the services corresponding to that permission. However, your decision to close the permission will not affect the collection and use of information based on your authorization.
For an itemized list of the access rights to your mobile device that may be enabled by the implementation of relevant business functions, please refer to the System Permissions Management List.

Information we collect automatically and purpose of use

Information about the Linklike Smart Device

 

Please note that device information and service log information alone is information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or use it in combination with personal information, such non-personal information will be treated as personal information during the period of combined use, and we will anonymize and de-identify such information unless we obtain your authorization or unless otherwise required by law or regulation.
Linklike provides an itemized list of the information collected and used about you. Please refer to the Personal Information Collection List for specific scenarios of use and purposes of use and storage times.

Legal basis for processing personal information

The purposes for which we process your information are as follows:

Exception for prior authorized consent

Please note that your prior authorized consent is not required for the collection and use of personal information in the following cases:

We will not share your personal information with any company, organization or individual outside of Shenzhen Linglai Technology Co. Ltd. except as follows:
(1) Sharing with explicit consent: we may share your personal information with other parties after obtaining your explicit consent.
(2) Fulfillment of legal obligations: we may share your personal information to the public in accordance with laws and regulations, or in accordance with mandatory requirements of government authorities.
(3) Sharing with our affiliates: where permitted by law, we may share your information with our affiliated companies in order to provide you with Linklike products and services. We will only share the necessary personal information, which is subject to the purposes stated in this privacy policy. Our affiliated company is Shenzhen LANHE Technology Co., and we will share your personal information with our affiliated company. If an affiliated company wishes to change the purpose of processing personal information, it will again seek your authorized consent.
(4) Sharing with authorized partners: Some of our services will be provided by authorized partners only to fulfill the purposes stated in this policy. We may share some of your personal information with our partners in order to provide better customer service and experience. We will only share your personal information for purposes that are legal, legitimate, necessary, specific, and explicit, and only as much personal information as is necessary to provide the services. Our partners do not have the right to use the personal information shared for any other purpose.Currently our authorised partners are:
Third party SDK service providers : In order to ensure the stable operation and function of the application, so that you can use and enjoy more services and functions, we will embed the third party's SDK in the application. This privacy policy only applies to the information we collect from you, not to the products or services provided to you by the third party alone, and we are not responsible for how the third party's products or services collect, use, or process your personal information. We are not responsible for how third party products or services collect, use, or process your personal information. When you use the products or services provided by the third party alone, the third party may collect your personal information; when you use the third party products or services, please also carefully read and fully understand the privacy policy of the products or services provided by the third party; please refer to the valid version provided by the third party when you use the third party products or services. In order to provide you with more services, ensure the stability and quality of services or upgrade the relevant functions, we may need to adjust the third-party SDK/API that we access, and we will update the directory of the third-parties that Linklike app accesses in a timely manner to explain to you the latest situation involving the third-party SDK so that you can check the third-party data usage rules.
For the third-party SDKs embedded in the platform and the information that needs to be collected by or shared with these third-party SDKs, please refer to the Third-Party Information Sharing List.

Transfer

We will not transfer your personal information to any company, organization or individual unless we obtain your explicit consent, or in the case of a merger, acquisition or bankruptcy and liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Privacy Policy, otherwise we will require the company or organization to seek authorized consent from you again.

Public Disclosure

We will only disclose your personal information publicly when.
(1) After obtaining your express consent.
(2) Disclosure based on law: we may disclose your personal information publicly if compelled to do so by law, legal process, litigation or governmental authority.

Exceptions to Prior Authorized Consent

Prior authorized consent of the subject of personal information is not required for sharing, transferring, or publicly disclosing personal information in the following cases:
(1) directly related to national security or national defense security;
(2) directly related to public safety, public health, and significant public interest;
(3) directly related to crime investigation, prosecution, trial, judgment execution, etc;
(4) for the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals but it is difficult to obtain his or her consent;
(5) personal information disclosed to the public by the subject of personal information himself/herself;
(6) personal information collected from information that is lawfully and publicly disclosed, such as lawful news reports, government information disclosure and other channels.

You have the right to manage your information, including

Access to your personal information

(1) Your personal information
Path: Personal Center
You can access or edit the personal information in your account. For information that cannot be accessed through the above path, you can contact us at any time through the contact information in Section IX of this policy, and we will respond to your request for access within fifteen(15) business days after verifying your identity information.
(2) Your other personal information
Path: Personal Center - Privacy Management Rules - Personal Information Collection List
You can learn about the information we collect about you by reviewing the Personal Information Collection List.

Correction of your personal information

Path: Personal Center - Account and Security (you can change your password, replace the bound mobile phone number, switch third-party login account)
If you find that we have processed your personal information incorrectly, and for information that cannot be corrected through the above path, you may contact us at any time through the contact information in Section IX of this Policy, and we will respond to your request for correction within fifteen (15) business days after verifying your identity information.

Deletion of your personal information

You may delete your personal information yourself by the following means: Personal Center - Account and Security.
Your personal information will not be recovered after seven (7) days of deletion. If we have processed your personal information in violation of laws and regulations, or if we have collected or used your personal information without your consent, or if you no longer use our products or services and cancel your account, and you need to delete your personal information, you may submit a request to delete your personal information to us through the contact information in Section 9 of this Policy, and we will respond to your request for deletion within fifteen (15) business days. When your information is executed for deletion, we will no longer use the data, but may not be able to delete it immediately to accommodate necessary related legal policy requirements or to protect the integrity of the data necessary for the proper operation of the service, and may store or back up the data within the necessary time period, but we will delete it promptly after that time period.

Cancellation of your account

You can cancel your account at anytime. Once you cancel your account on the Linklike App, you will not be able to use the Linklike services of remote operation of smart devices, we will delete or anonymize your personal data as required by applicable law, and the relevant data will not be recoverable after seven (7) days of your account cancellation, so please proceed with caution!
Cancellation path: Personal Center - Account and Security - Cancel your account
You can also apply to the third party to cancel your account. However, you may also contact us through the contact information in Section IX of this policy and we will respond to your cancellation request by deleting your personal information under the account bounded with your registered mobile number within fifteen (15) business days after verifying your identity information.

Copy of Personal Information

You have the right to obtain a copy of your personal information by sending a request to the email address: linklike.audio@gmail.com
After an individual user cancels, the system may delete personal information and we will not be able to provide a complete copy of personal information.

Constraint information system automatic decision making

In some business functions, we may make decisions based solely on non-manual automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legitimate interests, you have the right to request an explanation from us and we will provide appropriate remedies.

Restrictions on processing

In some cases, you have the right to request that we stop processing your personal information and only store such information. However, we may process your personal information if we have a legitimate reason to do so (for example, to defend a legitimate request or to protect others).
If we agree to stop processing personal information, then we will take reasonable steps to do so. Please inform any third party to whom we have disclosed the personal information in question so that they may also stop processing it.
You may request that we stop processing the personal information we hold about you and only store it if

To respond to your request as described above

For security purposes, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before we process your request. We will respond within fifteen (15) business days.
In principle, we do not charge a fee for your reasonable requests. We may deny requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical (for example, involving information stored on backup tapes).
If you are a user located in one of the following countries or regions: Hong Kong, China, Macau, China, Taiwan, United States and California, Japan, Republic of Korea, then the terms set out in the Supplementary Terms under your jurisdiction apply to you in addition to the terms set out in our Privacy Policy.

In accordance with legal and regulatory requirements, we will not be able to respond to your request for correction or deletion of information in the following cases:

(1) directly related to national security or national defense security;
(2) directly related to public safety, public health, or significant public interest;
(3) directly related to crime investigation, prosecution, trial, execution of judgments, etc.;
(4) where we have sufficient evidence of subjective malice or abuse of rights (such as where your request would jeopardize public safety and the legitimate rights and interests of others, or where your request is beyond the scope of what can be covered by ordinary technical means and commercial costs);
(5) responding to the request of the subject of personal information will lead to serious damage to the legitimate rights and interests of you or other individuals or organizations;
(6) where commercial secrets are involved.
IV. Safety and security measures
1. In terms of the secure collection of data, we confirm the legality, legitimacy and necessity of data collection through personal information security impact assessment, identify and inform and obtain your consent in a clear and accurate manner, and we will record your authorized consent in the log; we will use technical measures to identify the source party collecting or generating the data to ensure the accuracy and resistance to denial of the data source.
2. In terms of secure transmission of data, we will use a secure channel to transmit your personal information, and securely encrypt and desensitize it through reasonable encryption algorithms to ensure the confidentiality and integrity of personal information during data transmission.

Although we have taken reasonable and effective measures as described above and have complied with the standards required by relevant laws and regulations, we cannot guarantee the security of your personal information when it is communicated through insecure means. Therefore, you should take active measures to ensure the security of your personal information, such as: setting complex passwords, changing your account password regularly, and not disclosing your account password information to others to help us keep your account and personal information secure. If you discover that your personal information has been compromised, especially your account or password, please contact us immediately at the contact information provided at the end of this Privacy Policy so that we can take appropriate measures to protect the security of your information.
V. Data Retention Period
We will continue to store your personal information for the duration of your use of the Linklike App for the time specified in the Personal Information Collection List. If you need to delete your personal information, you can delete it yourself or by contacting us as described in Section IX of this policy. After your personal information is deleted, the copy of relevant data will be kept for seven (7) days. In addition, we will delete or anonymize your personal information after the above retention period, except as expressly provided by law or regulation. If we are unable to destroy the data for technical reasons, we will take appropriate measures to prevent further use of your personal data.
VI. Protection of personal information of minors
We attach great importance to the protection of children's (or minors') personal information. If you are under the age of 18 (or the age of majority according to the user's relevant local laws), it is important to obtain the prior written consent of your parent or legal guardian before using our services. We will protect children's personal information in strict accordance with the provisions of the relevant laws and regulations of each country or region. Please note that if we discover that personal information of children has been collected without the prior consent of a verifiable parent or legal guardian, we will attempt to delete the relevant personal information as soon as possible. If a guardian has reason to believe that we have collected personal information from a minor without the guardian's consent, please contact us through the contact information in Section IX of this policy and we will delete the relevant data as soon as possible upon your request.

VII. How your personal information is transferred globally

In principle, personal information collected and generated by us in the People's Republic of China will be stored in the People's Republic of China. Because we provide our products or services through resources and servers located around the world, this means that your personal information may be transferred to, or accessed from, jurisdictions outside the country where you use the product or service, with your expressly authorized consent. Such jurisdictions may have different data protection laws or even no such laws. In such cases, we will ensure that your personal information is adequately protected to the same extent as it is in the People's Republic of China. For example, we may request your consent for cross-border transfers of personal information or implement security measures such as data de-identification prior to cross-border data transfers.

VIII. Statement on policy changes

We may make changes to this Policy from time to time. We will not reduce your rights under this Policy without your express consent. We will post any changes to this Policy on this page. For material changes, we will notify you by pop-up information, email, etc., and ask for your consent again.
Material changes referred to this policy include, but are not limited to:

By continuing to use the service after we update this Policy, you agree to the contents of this Policy (including the updated version) and consent to our collection, use, retention, disclosure, and transfer of information about you in accordance with this Policy.
IX. Contact Us
1.We have established a dedicated personal information protection team and person in charge. If you have any questions, comments or suggestions regarding this policy or our services, you can contact us through the following ways:
(1) By sending an e-mail to the person in charge of personal information protection: Name of the person in charge (legal representative): He Lianwei; linklike.audio@gmail.com (contact email address)
(2) By sending a letter in the following way:
Address: C707, Block C, Zhantao Technology Building, at the intersection of Minzhi Avenue and Gongye East Road, Xinniu Community, Minzhi Sub-district, Longhua District, Shenzhen.
Contact number: +86 17820543241
Zip code: 518000

If you are not satisfied with our response, especially if you think our personal information processing behavior has harmed your legitimate rights and interests, you can first consult with us, and if you are not satisfied with the results of the consultation, you can apply to the Shenzhen International Arbitration Court for arbitration. The laws of Mainland China (excluding Hong Kong, Macau and Taiwan) shall apply to all issues related to this Privacy Policy, including performance, interpretation and dispute resolution.