RHOME Privacy Policy

Our Privacy Policy has been updated as of June 1, 2022 .

This Privacy Policy makes privacy representations and commitments with respect to the "(RHOME) Software" (hereinafter referred to as "RHOME"), and we encourage you to read this agreement in detail.

RHOME is a platform for controlling and managing smart devices provided by Shenzhen Mantolo Technology Co., LTD (hereinafter referred to as "we"). RHOME respects and protects the privacy of all users of the service. RHOME respects and protects the privacy of all users of the Service. However, the Software will treat this information with a high degree of diligence and due diligence. Except as otherwise provided in this Privacy Policy, the Software will not disclose or make available such information to third parties without your prior permission. The Software may update this Privacy Policy from time to time. You are deemed to have agreed to this Privacy Policy in its entirety when you agree to the Software Service Use Agreement.

At the end of the day, we want the best possible experience for our users. If you have any questions about the handling of personal information practices described in this Privacy Policy, or if you do not wish to use our services, please through the email support@redroadglobal.com and support@redkey.cc contact us so that we can address your specific needs. We are happy to receive your feedback.

I. We promise you

1. This Privacy Policy governs how we collect, use, disclose, process and protect the information you provide to us when you use RHOME. If we ask you to provide certain information in order to verify your identity when using our products and services, we will use that information in strict compliance with this Privacy Policy and/or our User Agreement.

2. This Privacy Policy has been developed with you in mind, so that you are fully aware of our personal information collection and use practices and are confident that you ultimately have control over the personal information you provide to us.

3. For the purposes of this Privacy Policy, "personal information" means data that identifies a particular individual, either by the information itself or by linking it to other information about the individual to which we have access. Such personal information includes, but is not limited to, information provided by you, information relating to your mobile device, etc.

4. By using RHOME, you acknowledge that you have read, acknowledged and accepted all of the terms and conditions set forth in this Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including your local data protection regulations, we may specifically seek your explicit consent to the processing of particular categories of personal information. We are committed to protecting the privacy, confidentiality and security of your personal information in accordance with applicable law, and all of our employees and agents will fulfill these obligations.

5. All we want is the best experience for our users. If you have any questions about the data processing practices outlined in this privacy policy, Please through email support@redroadglobal.com or support@redkey.cc contact us so that we can address your specific needs. We are happy to deal with your questions directly.

II. Information Collection and Use
(I) Circumstances that require you to authorize us to collect and use your personal information
1. In order to provide you with our services, we may ask you to provide personal information that is necessary to provide you with the services. If you do not provide personal information, we may not be able to provide you with our products or services.
2. In order to facilitate a clearer understanding of the Privacy Policy, some common terms in this document are explained:
(1) Mobile Terminal: A mobile device that runs RHOME, e.g.: cell phone, tablet, etc;
(2) Devices: Intelligent hardware devices that can access the IoT platform through RHOME, e.g.: our sweeping robots.
3. We will only collect information that is necessary for specific, explicit and legitimate purposes, and will not further process the information in a way that is incompatible with those purposes. We collect the following types of information (whether or not it is personal information):

(1) Information you provide to us (including your contact information): We may collect personal information that you provide to us, such as your cell phone number, e-mail address, feedback messages sent, avatars uploaded by you on your own initiative in RHOME, other information filled in by you on your own initiative, and so on. Since your cell phone number and email address are important information for you to log in to RHOME, this information will always be stored in the mobile device running the RHOME. If you want to delete this information, you can choose to delete your account. For more information on how to delete an account, please refer to "Deleting Information" below.

(2) In order to provide you with RHOME services so that you can securely connect and manage your smart devices, we may collect your Wi-Fi information, location information, cell phone camera, login information, mobile phone-related information, smart device-related information, etc. This information will be used to provide you with RHOME services. This information will be used to provide you with smart device quick connect, connectivity, discovery of nearby devices, and device management features. Each of the above information is listed in detail below:

-Login account information: cell phone account, nickname, avatar information.
-Mobile terminal information: hardware device ID (IMEI/OAID, Mac address, Android ID), mobile terminal model, system version information, system language, country or region where the mobile terminal is set up, version number of the application store, mobile terminal camera, mobile terminal screen size and resolution, CPU and display device information, information of cellular network operator used by the mobile terminal, RHOME crash information, and so on. Information about the mobile device's screen size and resolution, CPU and display device, information about the cellular network operator used by the mobile device, and information about RHOME crashes.
-Smart device related information: device identification (e.g. device IMEI, Mac address, IP address), Bluetooth information, software and firmware version number information of smart devices.
-Software Installation List: Get sensitive information about user's software installation list.
-Rough Location Information (only for specific services/functions): Information related to your location, including: area and country code.
-Network access information: SSID and password to access the router. For the avoidance of doubt, the password information is only stored on the device side and is not uploaded to the server.
. Storage permission: user change avatar or background image, need to open the user album and read the selected image

(Ⅱ) How the personal information will be used

1. Personal information is collected for the purpose of providing you with products and/or services and to ensure that we comply with applicable laws. You hereby consent to our processing of Personal Information for the purposes set forth in this Privacy Policy and to the disclosure of Personal Information to our Affiliates, Third Party Service Providers (as defined below).

2. Device Sharing

We support you to share your smart device with others through your cell phone account. After sharing, the person being shared can also control the smart device. In order to enjoy this feature, we may collect the sharing account information you provide, the sharing status of the device, which is used to provide you with the ability to share the device to other RHOME users for common control and use, as well as for the device list page to display the sharing status.

2. We may use your personal information for the following purposes:

(1) Providing, processing, maintaining, improving, developing our products and/or services to you, and services offered through the Device or RHOME.

(2) Communicating with you about your Device, the Services or any general inquiries (e.g. updates, Device firmware/software upgrades, customer enquiry support, related information, notifications), etc.

(3) To analyze and develop statistical information related to the use of our products and services in order to better improve our products and services.

(4) To store and maintain information about you for the purpose of operating our business or fulfilling legal obligations.

(5) Provide a more detailed description of how we use your information, which may contain personal information, below:

-Create your RHOME account. The cell phone number collected during account creation via mobile is used to create your personal account and profile page. The avatar you upload is used for display in the profile page.
-Securing basic RHOME and device functionality. We collect your login information to ensure the realization of the basic functions of RHOME; we collect the information of the relevant equipment bound to the account to ensure the realization of the basic functions of the equipment.
-Providing location-based services. We may use coarse location information to assist in determining the data center to which devices and mobile terminals are connected.
-Device Access. In the event that the device needs to be connected to a network for use, it is necessary to set up the appropriate network settings for the device through RHOME. This process requires you to enter the appropriate Wi-Fi name and password, combined with the collected time zone settings, rough location information, and account name, which is only used for the purpose of network allocation for the device.
-RHOME uses a password to verify your identity and ensure that unauthorized persons cannot log in.
-Collecting user feedback. We may collect questions, feedback logs, and phone numbers or email addresses that you send us for feedback, which will be used to let us better understand the problem you are having, and to contact you.

(7) Provide firmware upgrade function. In order for you to continue to enjoy the latest RHOME services, we may use the version information of your RHOME application and the model number of your cell phone to provide you with the upgrade service of the RHOME application. At the same time, we may collect a list of your connected smart devices and their version numbers for the purpose of providing you with smart device upgrades to ensure that you can use the latest version of the Services (including firmware versions).

(8) Improving Products and Services. We use your mobile device and RHOME to run information that we use to better improve our products and services.

(Ⅲ) Who do we share your information with?

1. We do not sell any personal information to third parties.

2. From time to time, we may disclose your Personal Information to Third Parties (as defined below) in order to provide products or services that you have requested.

3. We may make disclosures to third party service providers and affiliates listed below in this section. In each case described in this section, you can be assured that we will only share your Personal Information in accordance with your authorization, and that your authorization to us will include sub-processors that process your Personal Information. You should be aware that in any of the circumstances described below, where we share your Personal Information with third party service providers, we will contractually obligate the third party to comply with applicable local data protection laws. We will contractually ensure that third party service providers comply with the privacy standards applicable to them in your jurisdiction.

(Ⅳ) Sharing of information with our affiliated companies and third party service providers
1. In order to conduct smooth business operations to provide you with the full functionality of our products and services, we may disclose your personal information to our affiliated companies (which are involved in manufacturing, product sales, after-sales services, etc.) or our third party service providers (our mailing stores, delivery service providers, telecommunication companies, data centers, data storage facilities, technical support, customer service providers, IOT service providers). ) disclose your personal information. Such third party service providers may process your personal information on our behalf or for one or more of the above purposes. If you no longer wish to allow us to share this information, Please through email support@redroadglobal.com or support@redkey.cc contact us to delete your account or stop sharing it by revoking your authorization (see below for the specific process for revoking authorization).
2. In order to recognize your device ID, improve the security of our services, and ensure the quality and efficiency of our operations, we collect information about your device (including IMEI, MEID, AndroidID, IMSI, GUID, and MAC address) and information about the apps you have installed.
3. Third-party software development kits (SDKs) that we access In order to adapt to the use of RHOME and third-party platform services on different mobile devices, and to realize your mobile device authentication, mobile device security, receiving information push, logging in to the third-party platform account, and sharing of information through third-party platforms, RHOME accesses the third-party SDKs The above third-party SDK providers include These third-party SDK providers include mobile device manufacturers, social media platforms and telecommunication carriers. Some of these third-party SDKs may call your device permissions and obtain information about you so that you can use the corresponding functions on different mobile devices or third-party platforms. The types of device permissions and information obtained by different third-party SDKs may vary and may include obtaining your location information, reading/writing your external memory card, reading your phone status and identity, viewing WLAN links, and retrieving running apps/Bluetooth. Regarding the specific types of device permissions called by the third-party SDK, and how the phone and your personal information are used, we recommend that you refer to the relevant service agreement and privacy policy of the third-party SDK. The following are specific instructions:

(v) Information for which consent is not required

For the avoidance of doubt, we will collect, use or disclose your personal information without your consent to the extent and only to the extent expressly permitted by local data protection laws.

(Ⅵ) Non-personal information

We may also collect other information that does not identify a specific individual (i.e., information that is not personal information), such as statistical data generated by your use of a product, such as user actions (including clicks, page jumps, and browsing time). The purpose of collecting such information is to improve the services we provide to you. The type and amount of information collected depends on how you use our products or services. We may aggregate this information to help us provide more useful information to our customers about which parts of our products and services are of most interest to them. Aggregated data is considered non-personal information for purposes of this Privacy Policy. If we use non-personal information in combination with personal information, such information will be treated as personal information for the duration of the combination.

(Ⅶ) You are fully aware that your consent is not required for the collection and use of personal information in the following cases:

1. It is related to the fulfillment of the obligations of personal information controllers as stipulated by laws and regulations;

2. Directly related to national security or national defense;

3. Directly related to public safety, public health and vitality, and significant public interests;

4. Directly related to criminal investigation, prosecution, adjudication, and enforcement of judgments;

5. When it is difficult to obtain the authorization of consent from this people for the purpose of safeguarding the life, property, and other significant legitimate rights and interests of the subject of the personal information or other individuals;
6. When the personal information involved is disclosed to the public by the subject of personal information on his or her own initiative;
7. It is necessary for the conclusion and performance of a contract at the request of the subject of the personal information;

8. To collect personal information from legally disclosed information, such as legal news reports, government information disclosure, and other channels;
9. Necessary for maintaining the safe and stable operation of the products or services provided, such as detecting and dealing with product or service malfunctions;
10. When the personal information controller is a news organization and when it is necessary for legitimate news reporting;
11. When the personal information controller is an academic research organization and it is necessary to conduct statistical or academic research in the public interest, and when it provides the results of academic research or descriptions to the public, it de-identifies the personal information contained in the results.

III. You can control your information

1. You have the right to request access to, correction of, or deletion of any personal information we hold about you (hereinafter referred to as a request), in accordance with the laws and regulations of the country or region to which you are subject.

2. Most laws require that requests made by the subject of personal information should follow specific requirements, and this Privacy Policy requires that your request should meet the following circumstances:

(1) Through our dedicated request channel, and for the purpose of protecting the security of your information, your request should be in writing (unless local law expressly recognizes oral requests);

(2) Provide sufficient information to allow us to verify your identity and to ensure that the requestor is the person or legally authorized person who is the subject of the requested information.

3. Once we have sufficient information to confirm that we can process your request, we will respond to your request within the timeframe set out in applicable data protection legislation. Specifically:

(1) Upon your request and in accordance with applicable law, we may provide you with a copy of the records of your personal information that we have collected and processed free of charge, or, if you make other requests for such information, we may charge you a reasonable fee in accordance with the relevant applicable law, taking into account the actual costs of administering the information.

(2) If you believe that any information we hold about you is incorrect or incomplete, you may request that the personal data be corrected or improved for the purposes for which it was used.

(3) You may have the right to request us to delete your personal data in accordance with your applicable laws and regulations. We will evaluate your request for deletion and, if the corresponding regulations are met, we will take appropriate steps, including technical means, to process it. After you or we have assisted you in deleting the relevant information, we may not be able to delete the corresponding information from our backup system immediately because of applicable laws and security technologies, and we will securely store your personal data and isolate it from any further processing until the backup can be erased or anonymization is achieved. For example, according to the Law of the People's Republic of China on Electronic Commerce, your goods and services information and transaction information shall be kept for a period of not less than three years from the date of completion of the transaction.

4. We have the right to refuse to process insubstantial/repeated requests, requests that jeopardize the privacy of others, requests that are extremely impractical, requests that require disproportionate technical work, requests that do not need to be granted under local law, information that has already been made public, information given under conditions of confidentiality. Requests for deletion of data or access to data may also be refused if we believe that some aspect of the request may prevent us from making legitimate use of the data for the aforementioned anti-fraud and security purposes.

(Ⅰ) Logging out of your account

If you want to cancel your account, you can do it in RHOME. After receiving your request and confirming your identity, we will process the account cancellation and data emptying within 48 hours.

(Ⅱ) Accessing, updating and correcting your personal information
1. 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, we will ask to verify your identity before we process your request. Once we have sufficient information to process your request to access or correct your personal information, we will respond to your request within the timeframe set out in applicable data protection legislation.
2.If you wish to request access to personal information we hold or if you believe that any information we hold about you is incorrect or incomplete, please contact us at support@redroadglobal.com or support@redkey.cc.

Ⅳ. Withdrawal of Consent
1. You may withdraw consent by submitting a request, including the collection, use or disclosure of your personal information in our possession or control. Please through email support@redroadglobal.com or support@redkey.cc according to the specific service you are using. We will process your request within a reasonable time after you have made it and will not collect, use or disclose your personal information thereafter in accordance with your request.
2. Please note that your withdrawal of consent may result in certain legal consequences. Depending on the extent to which you withdraw your consent for us to process your personal information, this may mean that you cannot enjoy our products and services.

Ⅴ. Retention Policy
We will retain personal information as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable law. Where it can be reasonably inferred that the retention of personal information is not necessary to fulfill the purpose for which it was collected, we will no longer retain personal information or will eliminate the means of associating personal information with specific individuals. We will continue to retain personal data if further data processing is required for public interest, scientific, historical research or statistical purposes, even if the further data processing is not related to the original purpose of collection. In addition, in the following cases, we are required to retain your personal information in accordance with relevant laws and regulations:

According to the “Law of the People's Republic of China on Electronic Commerce”, your goods and services information and transaction information shall be kept for a period of not less than three years from the date of completion of the transaction.

Ⅵ. How your personal information is transferred globally
1. We process and back up personal information through our global operations and control facilities. Currently, we have data centers in China, Germany, and the United States. For the purposes described in this Privacy Policy, your information may be transferred to these data centers in accordance with applicable law.

2. We may also transfer your Personal Information to third party service providers and business partners, and as a result, your information may also be transferred to other countries or regions. The jurisdictions in which these global facilities are located may not protect Personal Information to the same standards as the jurisdiction in which you are located, and there may be different risks under different data protection laws. However, this does not change our commitment to comply with this Privacy Policy and to protect your personal information.

3. We will store personal information collected and generated in the course of our operations within the mainland of the People's Republic of China in data centers located in the mainland of China, except where cross-border transfers are permitted under the provisions of applicable law.

4. If we transfer your information generated within the EU EEZ to an organization or third-party service provider outside the EU EEZ, we will do so based on the EU standard contractual terms or the security protection mechanisms set forth in the General Data Protection Regulation (GDPR). Contact us at support@redroadglobal.com or support@redkey.cc to be informed of the security mechanisms we have in place or to request a copy of the Standard Contractual Clauses.

5. If we need to transfer Personal Information outside of your jurisdiction, whether to our affiliates or third party service providers, we will do so in accordance with the relevant applicable laws. In particular, we ensure that all such transfers meet the requirements of applicable local data protection laws by putting in place appropriate security safeguards.

Ⅶ、Other provisions

(i) Minors
1. We recognize that it is the responsibility of parents to monitor their children's use of our products and services. However, it is not our policy to request personal information from minors or to send any promotional materials to such persons.
2. We do not seek or attempt to seek to receive any personal information from minors. If a parent or guardian has reason to believe that a minor has submitted personal information to us without their prior consent, Please through email support@redroadglobal.com or support@redkey.cc contact us to ensure that such personal information is deleted and that the minor unsubscribes from any of our services.
(ii) Order of Priority
If you have agreed to an applicable user agreement and there is an inconsistency between such user agreement and this Privacy Policy, this Privacy Policy will take precedence.
(iii) Updates to the Privacy Policy
We conduct periodic reviews of our Privacy Policy and may update this Privacy Policy to reflect changes in our information practices. If we make material changes to this Privacy Policy, we will notify you via mobile so that you can understand what information we collect and how we use it. Such privacy policy changes will apply from the effective date specified in the notice. We encourage you to periodically check this page for updates on our privacy practices. Your continued use of RHOME will be deemed acceptance of the updated Privacy Policy. We will ask for your consent again when we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

Ⅷ. Third party websites and services

Our Privacy Policy does not apply to products or services provided by third parties. Depending on the products or services of our company that you use, which may include third party products or services involving location and other types, some of which will be provided in the form of links to third party websites, and some of which will be accessed in the form of SDKs, APIs, and so on. When you use these products or services, your information may also be collected. Therefore, we strongly recommend that you take the time to read that third party's privacy policy, just as you would read ours. We are not responsible for, and cannot control, how third parties use the personal information they collect from you. Our Privacy Policy does not apply to third parties linked through our Services.

IX.Contact Us

If you have any comments or questions about this Privacy Policy, or if you have any questions about our collection, use or disclosure of your personal information, please contact us at the address below, referring to "Privacy Policy":

Shenzhen Mantolo Technology Co., LTD

Room 1015, Block C, Zhantao Technology Building, Minzhi Avenue, Longhua District, Shenzhen City, Guangdong Province

Zip code：518108

Email：support@redroadglobal.com
Email：support@redkey.cc