Proudeer Robot APP Privacy Policy
Effective Date: Janurary 1st, 2026
Issued by: Proudeer Robot (Shanghai) Co., Ltd. (hereinafter referred to as "we", "us" or "our")
We are the operator of the mobile application "ProudeerMow" (hereinafter referred to as "the App"). We attach great importance to protecting the personal information and privacy of users (hereinafter referred to as "you"). This Privacy Policy (hereinafter referred to as "this Policy") explains the types of personal information we collect when you use the Proudeer Robot APP – designed to set up, control and manage Proudeer Robotic Lawn Mowers (available on both iOS and Android platforms) – the reasons for collection, the methods of processing your personal information, and your rights under this Policy.
By downloading, installing or using the App, you acknowledge that you have read, understood and agreed to the collection, use and disclosure of your personal information in accordance with this Policy. This Policy constitutes the entire Policy between you and us regarding personal information protection when using the App, replacing all previous oral or written Policys, understandings or arrangements related to the subject matter herein.
Preliminary Note on Current vs. Future Functionality
This Privacy Policy describes the full scope of data collection, usage, and service practices that may apply to this App now or in future versions.
Please note that:
- The current version of the App does not implement or support all features, data collection, or services described herein.
- Specifically, the App currently does NOT:
(1) Collect the device’s MAC address and DID of user data referenced in subsequent section;
(2) Send marketing communications, push notifications for promotional purposes, or personalized ads;
(3) Share user data with third parties for non-essential purposes.
- Provisions related to unimplemented features are retained solely to outline potential practices for future updates (e.g., new functionalities, service expansions). Such provisions will only become effective if and when the corresponding features are rolled out, and we will comply with applicable legal requirements (including transparency obligations and user consent) before activating any such features.
- For the App’s potential future data practices, please refer to the "Potential Future Functionality" subsections throughout this Policy, which reflects that the current App does NOT implement or support.
We reserve the right to update this Policy to reflect changes in functionality or legal requirements, and will notify you of material changes (including the activation of previously unimplemented features) in accordance with applicable laws. By using the App, you acknowledge reading and understanding this note and agree to the terms of this Policy as it applies to the current version and any future updates .
1. How We Collect Your Personal Information
To provide our services to you, we will ask you to provide personal information necessary for those services. If you fail to provide relevant personal data, we may not be able to provide you with our products or services. For your better understanding, definitions of some commonly used terms in this Policy are as follows:
Mobile Device: Any device running the App, such as smartphones, tablets, etc. (supporting iOS and Android systems).
Device: Any smart device that can be connected to the IoT platform through the App, such as Proudeer Robotic Lawn Mower.
We only collect information necessary for specific, explicit and legitimate purposes, and will not further process it for any other irrelevant purposes. We may collect the following types of information (which may include personal information):
1.1 Mobile Device Information and App Operation Information
We may collect information about the mobile device running the App, such as operating system version (iOS/Android), language settings, time zone settings, device manufacturer, device model and name.
1.2 Device Information
We may collect information about the device associated with your account, such as the device’s MAC address and DID (-Potential Future Functionality); device network information (IP address/network signal), firmware version, App version, OS version, and datarecorded by the device’s visual sensors during mowing operations (e.g., obstacle avoidance, boundary recognition).
1.3 Coarse Location Information (Required Only for Specific Services/Functions)
Location-related information, including your region and country code.
1.4 Network Access Information
SSID and password of the relevant router. Please note that your password will only be stored locally on your mobile device and will not be uploaded to our servers.
1.5 Account Credentials
Information about your account credentials, such as account username, email address and password (for account login and authentication).
For any personal information collected by the device due to your instructions or settings in the App, we reasonably assume that you have obtained legal authorization (or sufficient and valid consent from relevant individuals) or other legal bases. We strictly abide by this Policy to collect, use and transmit such personal information.
Note: If you choose to share device control rights with an App account other than yours, the data collected from your device by the holder of that account during the sharing period will be recorded under their account (-Potential Future Functionality).
2. How Your Personal Information Will Be Used
We collect your personal information to provide you with our products or services and to comply with applicable laws. You hereby agree that we may process and disclose your personal information to our affiliates and third-party service providers for the purposes stated in this Policy. Specifically, we may use your personal information for the following purposes:
1. Provide, process, maintain, improve or develop the products and/or services we provide to you, as well as the services provided through your device or the App.
2. Communicate with you about your device, our services or general inquiries (e.g., update notifications, device firmware/software upgrade reminders, customer support responses).
3. Analyze and generate statistical information about the use of our products and services to improve product and service quality.
4. Store and maintain information related to our business operations or legal obligations.
5. Provide local services without communicating with our servers.
Further details on the use of your information are as follows:
Create Your Proudeer Account: The email address collected during registration is used to create your personal account and profile; login information ensures the basic functions of the App, and associated device information ensures the basic functions of the device.
Provide Location-Based Services: Coarse location information is used to help identify the data center connected to your device and mobile device.
Secure Device Access: To connect your device to the network, you need to enter your Wi-Fi name and password through the App for configuration. This information is only used in conjunction with your time zone settings, coarse location information, username and token. You can clear the Wi-Fi name and password at any time by resetting the device or uninstalling the App.
Display Device Status: You can remotely view the operating status of your Proudeer Robotic Lawn Mower.
Provide Push Services: Use your account to send you device and system notifications.
Verify Your Identity: The App uses your password to verify your identity and prevent unauthorized logins.
Persistent Login: You do not need to re-enter login information when re-accessing the App after logging out.
Collect User Feedback: To track your feedback, your username, feedback content, and your mobile device’s model and system version will be stored on our servers to improve services and resolve issues.
Provide Firmware Upgrade Function: When an upgrade package is available, we will remind you to upgrade based on the firmware version information of devices associated with your account.
Improve Products and Services: Use information about your mobile device and App functions to optimize our products and services.
3. How We Store and Protect Your Personal Information
3.1 Data Security Management
We are committed to maintaining information security in accordance with legal requirements. To prevent unauthorized access, disclosure or other similar risks, we have adopted reasonable physical, electronic and management measures to protect the information collected from your mobile device or the Proudeer platform. We take all reasonable steps to protect personal data to the best of our ability. Employees and third-party service providers who access this information to assist in providing our products and services are bound by strict contractual confidentiality obligations, and will be subject to disciplinary action or termination of cooperation for non-compliance. In addition, we have implemented special access controls for cloud-based data storage. Generally, we regularly review our information collection, storage and processing practices (including physical security measures) to prevent unauthorized access or use.
3.2 Personal Information Security Incident Reporting Mechanism
Please understand that due to technical limitations or potential malicious attacks, personal information security incidents may occur due to factors beyond our control. If a security incident occurs, in accordance with legal requirements, we will immediately inform you of the general facts and potential impacts of the incident, the measures we have taken or will take, information protection suggestions to reduce risks, remedial measures, etc. We will notify you of the incident through email, push notifications or other means based on your communication settings. If it is impossible or difficult to contact each affected user individually, we will issue a notice through reasonable and effective methods (e.g., App announcements, official website notifications).
3.3 Time-Limited Storage of Your Information
We will only store your personal information for the period necessary to fulfill the purposes outlined in this Policy or as required/permitted by law. When assessing storage periods, we carefully examine the necessity of collecting the disclosed personal information, and only retain it for the shortest period required to achieve the collection purpose (unless a longer retention period is required by law). After the expiration, we will irreversibly destroy or anonymize your personal information. If we stop providing Proudeer services or terminate business operations, we will immediately stop collecting your personal information and promptly delete or anonymize the collected personal information, and notify you through App announcements or other appropriate methods.
4. Third-Party SDKs
Our product may integrate third-party SDKs to provide relevant services (e.g., statistical analysis, customer support). The information collected by SDKs (such as device OS) will strictly comply with their respective privacy policies.
5. Your Responsibilities for Information Protection
Do not disclose your account information to any unauthorized third parties. Proudeer shall not be liable for any security breaches caused by third-party access to your personal information due to your failure to properly protect your personal information. If you discover unauthorized use of your account or other security vulnerabilities, please immediately notify us – your cooperation will help protect the security of your personal information.
6. Your Right to Control Your Information
6.1 Delete Information (-Potential Future Functionality)
You can delete locally cached personal information through the "Clear Cache" function in the App. To delete your personal information stored on our servers, please send your request to: services@proudeerobot.com.
6.2 Withdraw Consent (-Potential Future Functionality)
You can withdraw your consent to this Policy at any time by clicking "Me" > "About Us" > "User Policy and Privacy Policy" in the App. After withdrawing consent, we will stop collecting, using and disclosing your personal information. Please note that withdrawing consent may result in legal consequences – you may no longer be able to use Proudeer’s products and services.
7. Personalized Optimization & Remote Assistance
1. During mowing operations, lawn management-related data may be collected, including but not limited to lawn area, soil moisture, lawn health status, device operation paths, and obstacle avoidance images. This data will be strictly confidential and used solely to optimize the performance of Proudeer Robotic Lawn Mowers.
2. To improve user experience, remote assistance may be provided during use (e.g., troubleshooting abnormal device behavior, assisting with device configuration). With your prior explicit consent, remote control operations such as map creation may also be performed.
8. Updates to This Privacy Policy
We will periodically review this Policy and may update it to reflect changes in our information processing practices. For material changes, we will notify you through your mobile device (e.g., App push notifications, email) so that you understand the changes in the types of information we collect and how we use it. Such changes will take effect from the effective date specified in the notice. We encourage you to periodically review this Policy for the latest privacy practices. Your continued use of the App after the update constitutes acceptance of the revised Policy. If we need to collect additional personal information or change the purpose of using/disclosing your personal information, we will obtain your consent again.
9. Complaints and Contact
9.1 Complaint Rights
If you believe that our processing of your personal information violates applicable personal information protection laws, you may file a complaint with the relevant supervisory authority in your jurisdiction at any time. We will actively cooperate with the supervisory authority to investigate and handle the matter.
9.2 Contact Channels
If you have any questions, complaints, comments or requests related to this Policy, our data processing practices, or the exercise of your rights (e.g., accessing, correcting, or deleting personal information), please contact us through the following channels:
Dedicated Email for Privacy Matters: services@proudeerobot.com
Company Address: 2nd Floor, Building 38, Lane 1088 Shenhong Road, Minhang District, Shanghai, China
Response Time: We will acknowledge receipt of your inquiry within 3 working days and provide a formal response within 15 working days (extended to 30 working days if the matter is complex, and we will notify you of the extension and reason in advance).
10. Supplementary Provisions (Basic)
10.1 Separability
If any clause of this Policy is deemed invalid, illegal or unenforceable by a court or other competent authority, such clause shall be deemed to be severed from this Policy, and the validity, legality and enforceability of the remaining clauses shall not be affected.
10.2 Governing Law
This Policy shall be governed by the laws of the People's Republic of China, and shall also comply with the data protection laws and regulations of the country/region where you use the App. If there is a conflict between the applicable laws of your country/region and the provisions of this Policy, the relevant provisions of the local laws and regulations shall prevail (the conflicting clauses of this Policy shall be adjusted accordingly to comply with local requirements without affecting the overall effect of other clauses).
10.3 Language Version
This Policy is provided in English versions only.
11. Minors' Personal Information Protection
11.1 Applicability Restriction
The App is not intended for minors under the age of 13. We will not intentionally collect, use or disclose personal information of minors under 13. If we inadvertently collect such information with the consent of legal guardians (for minors aged 13-18), we will only use it for the purpose of providing necessary services and obtain prior written consent from legal guardians for any additional use.
11.2 Guardian Rights
Legal guardians may request access to, correction of, or deletion of the minor's personal information by contacting us via services@proudeerobot.com. We will verify the guardian's identity and process the request in accordance with applicable laws.
11.3 Additional Protection Measures
For minors aged 13-18, their use of the App and provision of personal information shall be under the supervision and consent of legal guardians. We will take additional security measures to protect minors' personal information, such as limiting data retention period and restricting access permissions.
12. Supplementary Explanations on Data Subject Rights
12.1 Additional Rights Under Local Laws
In addition to the rights specified in this Policy (access, correction, deletion, withdrawal of consent), you may exercise the following rights in accordance with local data protection laws (e.g., GDPR):
1. Right to Data Portability: Request us to provide your personal information in a structured, commonly used and machine-readable format, or transmit it directly to another data controller (where technically feasible);
2. Right to Restriction of Processing: Request us to restrict the processing of your personal information if you dispute the accuracy of the information or object to the processing purpose;
3. Right to Object: Object to the processing of your personal information for direct marketing or statistical purposes, and we will stop such processing unless we have compelling legitimate reasons.
12.2 Exercise of Rights
To exercise the above rights, please submit a written request to services@proudeerobot.com with your account information and identity verification materials. We will review and respond to your request within the time limit required by local laws (no more than 1 month, extendable by 2 months for complex requests).
12.3 Fee and Rejection Rules
We will not charge any fees for exercising your legitimate rights, unless the request is excessive, repetitive or unfounded. In such cases, we may charge a reasonable fee based on the actual cost or refuse to process the request.
13. Cross-Border Data Transfer Measures
13.1 General Principle
For users outside the People's Republic of China, your personal information may be transferred to our servers located in Mainland China or other countries/regions where our affiliated companies or service providers are located. We will ensure cross-border data transfer complies with local laws through the following measures:
1. For EU users: Signing Standard Contractual Clauses (SCCs) approved by the European Commission;
1. For U.S. users:
Complying with the Trans-Atlantic Data Privacy Framework (TADPF) – this framework, approved by the European Commission in July 2023, enables legal data transfers between the EU and the U.S. We adhere to the requirements of TADPF, including compliance with the U.S. Data Protection Review Court mechanism and restrictions on signal intelligence collection, to ensure adequate protection of U.S. users' personal information;
Adhering to U.S. state-level data protection regulations, including but not limited to the California Consumer Privacy Act (CCPA) and its amendments (CPRA), Virginia Consumer Data Protection Act (VCDPA), and Colorado Privacy Act (CPA). We will disclose data transfer practices as required by these regulations, obtain necessary user consents, and ensure the right to access, correct, and delete personal information;
Complying with the Cloud Act (Clarifying Lawful Overseas Use of Data Act) for cross-border data access requests, ensuring legal response to authorized data disclosure requirements from U.S. regulatory authorities while protecting user privacy;
2. For users in other regions:
For Brazil: Complying with the General Data Protection Law (LGPD) requirements for cross-border data transfers, including prior notification to the Brazilian Data Protection Authority (ANPD) where necessary;
For Canada: Adhering to the Personal Information Protection and Electronic Documents Act (PIPEDA) for cross-border data transfer consent and disclosure obligations;
For Australia: Complying with the Privacy Act 1988 and Australian Privacy Principles (APPs) for cross-border data transfer risk assessments;
3. Universal security measures: Regardless of the user's jurisdiction, we ensure the receiving party meets the "adequacy" standard of data protection or implements equivalent security measures (e.g., end-to-end encryption, access control, regular security audits).
13.2 Access to Transfer Documents
You may request a copy of the cross-border data transfer mechanism documents (such as SCCs text, TADPF compliance certification, state-level regulatory compliance statements) by contacting us. We will provide relevant materials in a readable format after verifying your identity.
14. Cookie and Similar Technologies
14.1 Purpose of Use
The App may use Cookies, SDK tracking tools and other similar technologies to improve user experience, including but not limited to:
Remembering your login status to avoid repeated authentication;
Analyzing function usage frequency to optimize App interface and functional logic;
Providing personalized service recommendations based on your usage habits.
These technologies will not collect sensitive personal information (e.g., password, precise location) without your explicit consent.
14.2 User Control Rights
You may disable non-essential Cookies through your mobile device settings (iOS: "Settings > Safari > Block All Cookies"; Android: "Settings > Privacy > Cookies") or App preferences ( "Settings > About > Cookie Settings");
Disabling non-essential Cookies may affect the normal use of some functions (e.g., persistent login, personalized recommendations), but will not impact core services (e.g., device connection, mowing control);
Essential Cookies (for core service operation, such as data transmission security) cannot be disabled, as they are necessary to ensure the App's basic functionality.
14.3 Transparency Disclosure
We will list detailed information about Cookies and similar technologies in the "Settings > About > Cookie Policy" section of the App, including:
Type of technology (e.g., session Cookies, persistent Cookies, SDK tracking);
Purpose and scope of data collection;
Retention period (session Cookies will be deleted after you close the App; persistent Cookies will be retained for up to 1 year);
Third-party providers (if applicable) and their privacy policies.
We will update this information in a timely manner when there is a change in the use of Cookies or similar technologies.
15. Third-Party Data Processors' Liability
15.1 Selection and Supervision of Third Parties
When entrusting third-party service providers (e.g., cloud storage providers, technical support companies, statistical analysis tools) to process your personal information, we will:
Conduct due diligence on the third party's data protection capabilities, including reviewing their security measures, compliance records, and privacy policies;
Sign a Data Processing Policy (DPA) with the third party, clarifying the scope, purpose, and duration of data processing, as well as security obligations, liability for breach, and termination clauses.
15.2 Liability for Breach
We will conduct regular audits (at least once a year) and ongoing supervision of third-party service providers to ensure they comply with the DPA and applicable data protection laws;
If a third party fails to fulfill its data protection obligations and causes personal information leakage, damage, or other losses, we will assume corresponding liability to you (including compensation for direct losses) and have the right to pursue the third party's liability for breach of contract or tort;
If we terminate cooperation with a third party, we will require the third party to delete or return all processed personal information and provide written confirmation to ensure the data is no longer retained or used.
16. Notification of Privacy Policy Updates
16.1 Notification Methods for Material Updates
For material updates to this Policy (including but not limited to changes in data collection scope, processing purpose, cross-border transfer rules, or user rights), we will adopt a "dual notification mechanism":
1. Send a separate reminder to your registered email address, clearly stating the "Last Updated Date" and a summary of key changes;
2. Display a prominent pop-up notification in the App when you log in next time, requiring you to confirm acceptance of the updated Policy before continuing to use the App.
16.2 Notification Methods for Non-Material Updates
For non-material updates (e.g., correcting typos, optimizing wording), we will post the updated Policy in the App ( "Settings > About > Privacy Policy") and mark the "Last Updated Date" without additional individual notification. Your continued use of the App after the update takes effect constitutes acceptance of the revised Policy.
16.3 Right to Refuse
If you do not agree to the updated Policy, you may withdraw your consent and terminate the use of the App. We will stop collecting and using your personal information in accordance with Clause 6.2 of the Policy, and delete or anonymize your account data as required by law. And you may expect to encounter some known issues/problems which should be fixed in the later version of App, you may not have new features which should be added in the later App only.
17. Sensitive Personal Information Processing
17.1 Scope of Sensitive Personal Information (-Potential Future Functionality)
For the purpose of optimizing product functions, we may collect sensitive personal information in specific scenarios, including but not limited to:
Precise location information (for intelligent path planning of the lawn mower);
Biometric data (e.g., facial recognition for device access, if applicable);
Audio/visual data (e.g., images recorded by the lawn mower's camera for obstacle avoidance, which may involve surrounding environmental information).
17.2 Special Processing Rules
Separate consent: We will obtain your explicit, separate consent for the collection and use of sensitive personal information, which will not be bundled with other service consents (e.g., you can refuse to provide precise location information without affecting basic device connection functions);
Stricter security measures: Sensitive personal information will be subject to end-to-end encryption during transmission and separate storage (physical isolation from non-sensitive information) during storage. Access to such information is restricted to authorized personnel only, with operation logs retained for at least 1 year;
Right to withdraw consent: You may withdraw your consent to sensitive personal information processing at any time through the App's "Settings > Privacy > Sensitive Data Authorization" section. Withdrawal of consent will not affect the validity of previous processing based on legitimate consent, nor will it impact the use of other non-sensitive related services. (-Potential Future Functionality)
18. Anonymization and De-Identification of Data
18.1 Processing Standards
For data that does not need to be associated with specific individuals (e.g., aggregated lawn mowing efficiency data, regional usage statistics, device failure rate data), we will conduct anonymization or de-identification processing in accordance with the following standards:
Remove all information that can directly or indirectly identify specific individuals (e.g., account ID, device serial number, regional code narrowed to less than 10,000 people);
Ensure the processed data cannot be restored to a state that can identify specific individuals through technical means (e.g., algorithm encryption, data fragmentation);
Conduct regular verification (at least twice a year) to confirm the irreversibility of the anonymization/de-identification process.
18.2 Use of Processed Data
Anonymized/de-identified data shall no longer be deemed "personal information" under this Policy, and we may use it freely for the following purposes without additional consent:
Product research and development (e.g., optimizing lawn mower navigation algorithms, improving battery life);
Market analysis (e.g., compiling industry reports on regional usage habits);
Public welfare publicity (e.g., publishing environmental protection data such as water-saving and energy-saving benefits of intelligent lawn mowers).
We will not attempt to re-identify anonymized/de-identified data, nor will we cooperate with any third party to conduct re-identification without legal authorization.
19. Data Breach Notification Obligations
19.1 Emergency Response Mechanism
We have established a dedicated data breach emergency response team and formulated a contingency plan. If a personal information breach occurs that may cause significant risks to your legitimate rights and interests (including but not limited to leakage of sensitive personal information, large-scale data leakage involving more than 100 users), we will:
Immediately activate the contingency plan within 2 hours of discovering the breach, including blocking leakage channels, isolating affected systems, and strengthening data encryption;
Conduct an investigation into the cause, scope, and impact of the breach within 24 hours, and formulate targeted remedial measures;
Notify you and the relevant regulatory authorities in accordance with the time limits specified in local laws.
19.2 Notification Requirements by Region
EU users: Pursuant to GDPR Article 33, we will notify you and the relevant supervisory authority (e.g., ICO in the UK, CNIL in France) within 72 hours after discovering the breach. If the breach is unlikely to result in a risk to your rights and interests, we may be exempt from individual notification but still need to retain relevant records;
U.S. users: In accordance with state-level regulations:
California (CCPA/CPRA): Notify you without unreasonable delay (generally within 72 hours) after discovering the breach;
Texas (Texas Identity Theft Enforcement and Protection Act): Notify you within 60 days if the breach involves personal identifying information;
Other states: Comply with the notification time limit specified in the respective state's data breach notification law (ranging from 30 to 720 hours);
Chinese Mainland users: Pursuant to the Personal Information Protection Law of the People's Republic of China, notify you within 72 hours after discovering the breach, and report to the Cyberspace Administration of China;
Other regions: Comply with the notification time limit and content requirements specified in local data protection laws (e.g., Brazil LGPD requires notification within 72 hours; Canada PIPEDA requires notification without unreasonable delay).
19.3 Content of Notification
The breach notification shall include the following key information in a clear and understandable manner:
Nature and scope of the breach (e.g., type of data leaked, number of affected users, time of breach);
Potential impacts of the breach (e.g., risk of identity theft, property loss);
Remedial measures taken by us (e.g., account password reset, identity verification enhancement);
Suggestions for risk prevention (e.g., changing relevant account passwords, monitoring financial transactions);
Contact information for further inquiries (dedicated email: services@proudeerobot.com, customer service hotline if applicable).
If it is impossible to notify each affected user individually (e.g., large number of affected users, unknown contact information), we will issue a public announcement through the App's homepage, official website, or social media accounts.
20. Marketing Communications Compliance (-Potential Future Functionality)
20.1 Consent Requirements
We will only send marketing information (including but not limited to new product promotions, discount activities, service upgrade notifications) to you if you have explicitly consented to receive such communications. The consent shall be obtained through a clear, affirmative action (e.g., checking a box in the App settings, replying to a confirmation email), rather than through pre-checked boxes or implied consent.
20.2 Regional-Specific Compliance
U.S. users: We will comply with the Telephone Consumer Protection Act (TCPA) and Do Not Call Registry requirements:
Obtain prior written consent before sending marketing calls or text messages;
Honor your request to be added to the Do Not Call list within 30 days;
EU users: Pursuant to GDPR, we will not send unsolicited marketing communications, and will provide a simple unsubscribe mechanism in each marketing message;
Chinese Mainland users: Comply with the Advertising Law of the People's Republic of China, and will not send marketing information to your mobile phone without consent, and clearly mark "advertisement" in the message.
20.3 Unsubscribe Mechanism
You may withdraw your consent to marketing communications at any time through the following convenient channels:
Click the "Unsubscribe" link at the bottom of the marketing email (unsubscription will take effect within 24 hours);
Disable marketing push notifications through the App's "Settings > Privacy > Marketing Authorization" section;
Send an unsubscribe request to services@proudeerobot.com with your account information (processing will take effect within 3 working days).
After you withdraw consent, we will stop sending relevant marketing information and will not use your contact information for marketing purposes again without your re-consent. We will retain your unsubscribe record for at least 1 year to comply with regulatory requirements.
21. Cross-Regional Additional Rights for Data Subjects
21.1 Rights for Brazilian Users (LGPD)
In addition to the rights specified in this Policy, Brazilian users may exercise the following rights in accordance with the General Data Protection Law (LGPD):
Right to confirmation: Request confirmation of whether we are processing your personal information;
Right to erasure (right to be forgotten): Request erasure of your personal information if the processing is no longer necessary, or if you withdraw consent and there is no other legal basis for processing;
Right to opposition: Object to the processing of your personal information based on our legitimate interests, and we will stop such processing unless we can prove that there are compelling legitimate reasons that override your interests;
Right to data portability: Request transmission of your personal information to another data controller in a structured, commonly used format (including direct transmission where technically feasible).
21.2 Rights for Canadian Users (PIPEDA)
Canadian users may exercise the following additional rights pursuant to the Personal Information Protection and Electronic Documents Act (PIPEDA):
Right to access detailed processing records: Request a comprehensive explanation of how your personal information is collected, used, and disclosed;
Right to complain to authorities: File a complaint with the Office of the Privacy Commissioner of Canada (OPC) if you believe your privacy rights have been violated;
Right to withdrawal of consent: Withdraw consent for any processing activity at any time, with the withdrawal taking effect immediately (except for processing already completed based on prior consent).
21.3 Rights for Australian Users (Privacy Act 1988)
Australian users may exercise the following additional rights in accordance with the Privacy Act 1988 and Australian Privacy Principles (APPs):
Right to correction of inaccurate data: Request correction of your personal information if it is inaccurate, out-of-date, incomplete, irrelevant, or misleading;
Right to request cessation of processing: Request us to stop processing your personal information if the processing is in breach of the APPs;
Right to privacy impact assessment (PIA) access: Request access to the PIA report for high-risk processing activities that involve your personal information (e.g., cross-border data transfers).
21.4 Exercise of Cross-Regional Rights
To exercise the above regional-specific rights, please submit a written request to services@proudeerobot.com with your account information, identity verification materials, and a clear description of the right you wish to exercise. We will review and respond to your request within the time limit required by local laws (e.g., 30 days for Brazil LGPD, 45 days for Canada PIPEDA).
22. Records of Data Processing Activities
22.1 Content of Records
In accordance with GDPR Article 30 and other applicable laws, we will maintain detailed records of all personal information processing activities, including:
Basic information of the data controller (our company name, address, contact information, and data protection officer if applicable);
Categories of data subjects (e.g., EU users, U.S. users, minors) and personal information collected (e.g., account credentials, device information, sensitive personal information);
Purpose and legal basis of processing (e.g., performance of contract, user consent, legitimate interests);
Categories of third-party recipients (including cross-border recipients) and the basis for transferring data to them;
Data retention period and the criteria for determining the period;
Security measures adopted (e.g., encryption technology, access control, regular security audits);
Details of cross-border data transfers (e.g., transfer mechanism, receiving country/region, security measures).
22.2 Access to Records
Data subjects: You may request access to the processing records related to your personal information by submitting a written application to services@proudeerobot.com. We will provide the records in a readable format (e.g., PDF) after verifying your identity, free of charge for the first request. For subsequent excessive or repetitive requests, we may charge a reasonable fee based on the actual cost;
Regulatory authorities: We will provide the processing records to relevant supervisory authorities (e.g., EU supervisory authorities, U.S. state attorneys general) upon their legal request, and cooperate with their investigations.
22.3 Retention of Records
We will retain the data processing records for at least 6 years from the date of completion of the processing activity, or in accordance with the longer retention period required by local laws (e.g., 7 years for China's Cybersecurity Law). After the retention period expires, we will irreversibly delete or anonymize the records.
23. Final Confirmation of Compliance
23.1 Completeness of the Policy
This Policy constitutes the complete and exclusive Policy between you and us regarding the collection, use, storage, transfer, and protection of your personal information when using the App. It covers all core requirements of global mainstream data protection laws and regulations, including but not limited to:
General Data Protection Regulation (GDPR) (EU);
Trans-Atlantic Data Privacy Framework (TADPF) (U.S.-EU);
California Consumer Privacy Act (CCPA)/California Privacy Rights Act (CPRA) (U.S.);
General Data Protection Law (LGPD) (Brazil);
Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada);
Privacy Act 1988 (Australia);
Personal Information Protection Law of the People's Republic of China.
23.2 Regular Review and Update
We will conduct a comprehensive review of this Policy at least once a year, or immediately when there are changes in the following circumstances:
Changes in applicable laws, regulations, or regulatory requirements;
Changes in our business practices (e.g., new product functions involving additional data collection);
Changes in technical standards or security risks (e.g., new data breach methods);
Feedback from users or regulatory authorities.
All updates to this Policy will follow the notification mechanism specified in Clause 16 of the Policy.
23.3 Severability
If any clause of this Policy is deemed invalid, illegal, or unenforceable by a competent court or regulatory authority, such clause shall be deemed to be severed from this Policy. The validity, legality, and enforceability of the remaining clauses shall not be affected, and the parties shall negotiate in good faith to replace the severed clause with a valid clause that achieves the original purpose of the severed clause.
23.4 Entire Policy
This Policy supersedes all previous oral or written Policys, understandings, or arrangements between you and us regarding the subject matter herein. No amendment to this Policy shall be effective unless it is made in writing and notified to you in accordance with the update mechanism specified in this Policy.
23.5 Acceptance of the Policy
By downloading, installing, or continuing to use the Proudeer Robot APP, you confirm that you have read, understood, and fully agreed to the entire content of this Policy. If you do not agree to any part of this Policy, please immediately cease using the App and contact us to delete your account and related data.
24. Contact Information for Privacy Matters
For any questions, complaints, comments, or requests related to this Policy, your personal information, or the exercise of your rights, please contact us through the following channels:
Dedicated Email for Privacy Matters: services@proudeerobot.com
Company Address: 2nd Floor, Building 38, Lane 1088 Shenhong Road, Minhang District, Shanghai, China
Response Time: We will acknowledge receipt of your inquiry within 3 working days and provide a formal response within 15 working days. For complex matters (e.g., data portability requests, large-scale breach inquiries), the response time may be extended to 30 working days, and we will notify you of the extension and reason in advance.
We will handle all your inquiries in accordance with applicable laws and regulations, and protect the confidentiality of your information during the handling process.
