APP Privacy Policy

This Policy applies to “we/us”, referring to Hangzhou Future Key Technology Co., Ltd., the primary entity responsible for its implementation. We will handle personal information strictly in accordance with this Policy, the User Agreement, and the latest applicable laws and regulations, ensuring compliance with our obligations and responsibilities toward you. Unless otherwise specified, our Affiliates (as defined in Part X: Definitions of this Policy) are also subject to this Policy under the following conditions: if their products or services are linked to those covered by this Policy or their extended functionalities, or if their products are distributed and used through this application and do not have a separate privacy policy. In such cases, these Affiliates will also be bound by this Policy and will assume independent obligations and responsibilities toward you.

This Policy applies to you under the following circumstances, allowing you to exercise your rights and fulfill your obligations:

(1)Users who lawfully use our products by entering into a transaction with us;

(2)Users who become our product users by purchasing products provided by our partner enterprises;

(3)Users who access and use our products with the consent of the aforementioned users (or in cases where we reasonably deem consent to have been given by default).

Your acceptance of this Privacy Policy does not preclude you from fulfilling additional rights and obligations under any transaction agreement or other arrangement you have with relevant parties. If there is any inconsistency between this Policy and the provisions governing personal information and privacy in your transaction agreement or other arrangement with a relevant party, you acknowledge that such inconsistency does not affect our ability to act in accordance with this Policy. If you believe that our actions conflict with a commitment or agreement made to you by a relevant party under a transaction agreement or other arrangement, and that such party is in breach of contract, you may assert your rights and claims against that party. In such cases, we will make reasonable efforts to cooperate with you in pursuing your rights.

You understand and agree that to effectively safeguard the legitimate privacy rights of others, you should exercise caution when taking the actions described in Section (3) above, such as authorizing others to use our products or adding their information to our products (hereinafter referred to as “Affiliated Individuals”). In such cases, we may require you to provide proof that the Affiliated Individual has authorized us to collect, store, and process their personal information. If you do not inform us that an Affiliated Individual is a third party other than yourself, a minor, or a member of a particularly sensitive group, we may be unable to accurately verify their identity or determine whether their personal information has been collected, stored, or processed. Consequently, we can only extend the same protections under this Policy to such individuals, which may be insufficient or incomplete.

This Policy applies only to the equipment products manufactured by us that you have purchased. If the use of these products requires online registration, identity verification, permission configuration, functionality access, or data storage and usage, you will need to download and log in to the corresponding application to enable these features. Please be aware that failure to complete these steps may prevent you from using the product or certain features.

We encourage you to carefully evaluate and make informed decisions before purchasing and using our products to ensure they align with your expectations for functionality, security, and the protection of others’ legal rights.

Please note that this Policy does not apply to third-party websites or services that you may access through our application or products. For such cases, please refer to the respective third party’s privacy policy or similar statements. We will also provide a clear notification before you access any third-party website or service portal.

We provide various types of applications for our products. Under this Policy, “Applications” include, but are not limited to, the DESLOC APP, which supports our unified service system, as well as any new online applications that we may introduce as technology evolves (collectively referred to as “this Application”).

Before using our products, please carefully read and fully understand this Policy. Any content closely related to your rights and interests will be emphasized in bold. You must agree to this Policy in order to access this application and utilize the product features through them. If you choose not to accept this Policy after you are aware of its content but proceed to use or continue using this application or our products (certain features requiring the authorization of personal information will not be available without your consent), you will be deemed to have agreed to the terms of this Privacy Policy and to have acknowledged the features we provide, as well as the personal information necessary for their operation. However, this does not imply your consent for us to collect sensitive or non-essential personal information, which will only be collected with your explicit consent during your use of the product. Additionally, for sensitive or critical device permissions, we will request your consent through a pop-up notification or other means before enabling the relevant functions. Once granted, you may revoke these permissions at any time through your device settings.

If you decline this Policy, it means you do not authorize us to collect your personal information, which may result in your inability to access or use this application, the products, or certain product features.

We must work together to establish a secure mechanism for protecting personal information. While we will make every effort to provide you with a legal and technological framework for protection in accordance with this Policy, you acknowledge that no protection mechanism is flawless and may have limitations, delays, or other issues. Therefore, you agree to take necessary self-protection measures beyond this Policy to jointly safeguard the security of your personal information, which is crucial for both you and your associated individuals. We will also unconditionally support you in ensuring the integrity and consistency of these self-protection measures.

Your account credentials for this application, including your account number and password, as well as the device account number, authentication code, and password for our products, along with the password and SMS verification code for your client terminal device and any other private information related to the aforementioned applications, products, and client terminal device under this Policy, are solely your responsibility to safeguard. You should carefully assess your physical, electronic, and network environments when storing, entering, or using such information to prevent potential data leaks. In particular, if you permit affiliates or minors to use the products and this application, you should take appropriate measures to protect their personal information and ensure that their usage is properly managed and supervised as necessary.

If you have any questions, comments, or suggestions regarding this Policy or any matters related to your personal information, please contact us via email at privacy@desloc.com. Alternatively, you may send a letter to the following address:

Address: Room 102-2, Building 1, No. 7 South Jianghui Road, Changhe Street, Binjiang District, Hangzhou

Postal Code: 310051

In general, we will respond within fifteen days.

We will collect and use your personal information for the purposes outlined in this Policy, including but not limited to the following:

A.When you register or log in to your DESLOC account, we will collect your email address and email verification code. This information is essential for completing your DESLOC account registration and/or login and ensuring the security of your account. Failure to provide this information will prevent successful registration and/or login.

B.When resetting the password for your account, we will collect your email verification code. This is necessary for the password reset function. If you refuse to provide this information, you will be unable to successfully reset your password. However, this will not affect your ability to use the registration or login features (provided your previous password remains valid).

C.After completing your registration, you may choose to provide additional account profile information (including, but not limited to, a nickname and avatar) to access our other services. The services associated with your device’s applicable usage scenarios will be communicated to you through system prompts. This information is non-essential for the registration, login, and verification functions. If you choose not to provide such information, it may reduce the security level of your account, but it will not impact your ability to register or log in.

D.When binding a DESLOC device in this application, we require your Bluetooth, location, and camera permissions to offer our services. Bluetooth and location permissions are necessary to connect and activate the device, while camera permissions are used to scan QR codes to locate the device. This information is essential for device setup and activation. If you decline to grant these permissions, it may impact the device’s functionality within the app but will not affect your ability to use the device’s local features.

E.If you add personal information of a third party to this application or allow a third party to independently add personal information to enable their use of this application or devices linked to it, we will collect and use the third party’s personal information in the same manner as described above. In such cases, you must provide us with the necessary authorization and documentation confirming the third party’s consent for the collection and use of their personal information. Failure to provide this authorization may result in the suspension of services for both you and the third party.

For the scenarios outlined above, the following permissions on your device will be required by this application:

A. Android Operating System

[Network] Permission: This permission is required when using the [Registration, Login, and Verification] functions. If you refuse to grant this permission, you will not be able to use these features.

[Camera] Permission: This permission is necessary when [taking photos to upload a user avatar] or [scanning QR codes]. If you refuse to grant this permission, you will not be able to use these features.

[Bluetooth] Permission: This permission is required when [networking hardware devices] or [using Bluetooth smart lock devices]. If you refuse to grant this permission, you will not be able to use these features.

[Location] Permission: This permission is required when [networking hardware devices] or [using Bluetooth smart lock devices]. Additionally, we will use this permission to manage product channels. If you refuse to grant this permission, you will not be able to use these business functions.

B. IOS Operating System

[Network] Permission: This permission is required when using the [Registration, Login, and Verification] functions. If you refuse to grant this permission, you will not be able to use these features.

[Camera] Permission: This permission is necessary when [taking a photo to upload a user avatar] or [scanning QR codes]. If you refuse to grant this permission, you will not be able to use these features.

[Bluetooth] Permission: This permission is required when [networking hardware devices] or [using Bluetooth smart lock devices]. If you refuse to grant this permission, you will not be able to use these features.

[Location] Permission: This permission is required when [networking hardware devices] or [using Bluetooth smart lock devices]. Additionally, we will use this permission to manage product channels. If you refuse to grant this permission, you will not be able to use these business functions.

To help you stay informed about the usage of your DESLOC products, we will send you push notifications within this application, including:

1)Displaying and promoting products and services to you;

2)Providing feedback on trade orders and their status;

3)Delivering system service messages for this application, which we send in a timely manner based on business operation needs.

A. Product and Service Display and Push Function

When you use the push notification feature within this application, we will collect and use information from your terminal device, including network information, device type, device model, operating system, device platform, manufacturer, and brand, based on the requirements of the products and services. This information is essential for the proper functioning of the feature. If you do not consent to the collection of such information, you will be unable to use the push notification feature as intended.

You can manage and control the notifications by adjusting the [Message Settings]. The specific path to disable notifications within this application is: “Account” -> “App Permissions”.

This application requests the following terminal permissions when performing the information push function:

A. Android Operating System

[Network] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Device Information] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Push Notification] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

B. IOS Operating System

[Network] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Device Information] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Push Notification] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

To facilitate the relevant functionalities and ensure the security and stability of the service, we utilize third-party software development kits (SDKs). We maintain stringent security monitoring of the SDKs obtained from our partners to safeguard the security of your protected data.

In the table below, we outline the third-party SDKs accessed by the DESLOC applications for the Device Message Push service, the types of personal information collected, and the purposes for which this information is used:

1. Third-party SDK Name: Google Firebase

Type of Information Collected: Device identification information (e.g., phone serial number, phone model, operating system)

Purpose of Use: For targeted message push and quality monitoring

Operating Systems: Android and iOS

2. Third-party SDK Name: Crash

Type of Information Collected: Device identification information (e.g., phone serial number, phone model, operating system)

Purpose of Use: To collect the terminal information related to the application Crash

Operating System: Android

To enhance your network security experience while using this application and our products and to ensure the security of your account and the system’s operations, we will perform activities such as identity verification and the operation and maintenance of product hardware and software. In the course of these activities, we may directly or indirectly collect and store relevant information generated during your use of our products, including:

In accordance with network security requirements, we will collect and use your email address for purposes such as implementing security measures, archiving, and data backup. Please note that we may utilize or integrate the information collected from you, as well as information obtained from our partners with your authorization or in accordance with legal requirements, to perform identity verification, detect and prevent security incidents, and take necessary actions for recording, auditing, analysis, and resolution, as required by law. The information provided by you and obtained from our partners forms the essential basis for ensuring network security. If you refuse to provide this information, we will be unable to offer our services to you.

To ensure that the products you purchase are securely and promptly maintained for safe operation, as well as to provide regular operation and maintenance services for both hardware and software, we may collect and use your personal information under various circumstances, as detailed below:

For service provision and ensuring the normal operation of the product, as well as update notifications for DESLOC smart software: product model, client terminal device information (including client type, client version number, operating system version, operating system language, and IP address).

For ensuring the secure operation of smart hardware products: smart hardware product information (including type, model, firmware version, MAC address, system version number, and system settings).

To ensure the safe and stable operation of client terminal devices, we collect and use the following types of information: basic information about client terminal devices (client type, client version, terminal device model, operating system version, operating system language, and manufacturer), network information (IP address, network connection type, DNS, gateway IP, proxy settings, Wi-Fi network name, and operator), and your operational data (page views, button clicks, instances of lag, and crash data).

Please be aware that device and log information, when considered individually, does not constitute personally identifiable information. However, if we combine such non-personal information with other data to identify a specific individual or use it in conjunction with personal information, it may be treated as personal information for the duration of such combined use. In such cases, we will anonymize or de-identify the data unless we have obtained your consent or otherwise required by applicable laws and regulations.

Please understand that this information is essential for us to provide security and operational maintenance services for our applications and products. If you choose not to provide this information, we will be unable to deliver our services to you, and certain features of our applications or products may not be accessible.

In the provision of security and operation & maintenance services, this application requests the following permissions from your terminal:

[Network] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Device Information] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Storage] Permission: When you use the “Event Log” function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Network] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Device Information] Permission: When you use the [Receive Message Push] function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

[Storage] Permission: When you use the “Event Log” function, we require access to this permission. If you refuse to grant the relevant system permission, you will not be able to use this feature.

(1) Functional Maintenance When Event Reporting is Disabled

To effectively evaluate and diagnose the functional integrity of your product while it is in the disabled state and to improve any identified functional defects, we may still collect information about your smart hardware product when Wi-Fi is available, even if the “Allow Event Reporting” function is turned off (including, but not limited to, data such as the product’s type, model, firmware version, MAC address, motor door opening count, motor operation time, average motor current during door opening, the last two motor sampling values, battery level, unlocking method success/failure counts, and the total number of video calls made by the doorbell). This information is necessary for the effective operation of this feature. If you do not consent to the collection and use of this data, you will not be able to use this feature as intended.

(2) Biometric Information for Door Unlocking

When prompted by your terminal device, you may enter biometric information such as fingerprints (specific types of biometric data are subject to the specifications and requirements outlined in the corresponding models and product documentation) to facilitate unlocking and opening the door. Your terminal device will record and store relevant biometric information but will not retain your original biometric data. It is important to note that the aforementioned biometric data is stored locally on your terminal device and is not uploaded to our servers. As a result, we do not access, collect, or process such biometric information in any way, nor do we disclose it to any third party or use it for any other purpose. This also means that the processing of biometric information is entirely performed on your device and, as such, is not governed by this Policy. Should you wish to exercise rights related to your biometric data, or if you wish to modify or delete this data, we can only provide guidance on how to manage this information on your device.

(3) Enhancement of Our Services

To enhance the services provided by us and our affiliates, we may link and use the information collected in other contexts under this Policy as follows:

A.To offer you specific product or service content or to display information tailored to you, rather than general notifications;

B.We may involve you in surveys, investigations, and efforts to detect and prevent security incidents related to the services provided by us and our affiliates, and take the necessary measures for record-keeping, auditing, analysis, and resolution in accordance with applicable laws.

(4) If we intend to use your personal information for purposes other than those outlined in this Policy, or if we plan to use information collected for a specific purpose for other unrelated purposes, we will seek your consent in advance by having you actively check a consent box.

In the scenarios outlined above, this application requires access to the following permissions on your terminal device:

[Network] Permission: When you [allow the maintenance of functions in the closed state of event reporting], [add a biometric key for unlocking the door], or [improve our services], we will request this permission. If you refuse to grant the relevant system permission, you will not be able to use these features.

[Network] Permission: When you [allow the maintenance of functions in the closed state of event reporting], [add a biometric key for unlocking the door], or [improve our services], we will request this permission. If you refuse to grant the relevant system permission, you will not be able to use these features.

We rigorously control the circumstances under which your personal information is shared externally. We will only share your personal information for lawful, legitimate, necessary, specific, and clearly defined purposes, and only after ensuring that third parties involved are strictly required to fulfill their obligations for the protection of personal information.

We will not share your information with any third party outside of our organization without your consent except in the following circumstances:

1.To maintain and enhance our services. We may share your information with partners and other third parties in order to enable core functionalities or provide services that you require. These third parties are prohibited from using your personal information for purposes other than the DESLOC services and are obligated to safeguard your personal information in compliance with this Privacy Policy and applicable laws. For a list of trusted third parties that we engage to process your personal information, please contact us.

2.To achieve the purposes outlined in the “Collection and Use of Personal Information” section in Part I of this Policy;

3.To fulfill our obligations and exercise our rights as stipulated in this Policy or any other agreements between us;

4.Provided in accordance with the individual service agreement signed with you (including electronically signed agreements and corresponding platform rules) or other legal documents;

5.Provided in accordance with applicable laws and regulations based on social public interest.

As our business evolves, we may undergo mergers, acquisitions, asset transfers, or similar transactions, during which your information may be transferred as part of the transaction. In such cases, we will notify you by sending an email to the address associated with your account or through an in-app or website notification, which will include: (i) the identity and contact details of the transferee, (ii) your right to withdraw consent for the provision of your personal information, and (iii) the procedure for revoking such consent.

We will only disclose your information under the following circumstances and with appropriate security measures that meet industry standards:

1.At your request, we will disclose the information you specify in the manner to which you have explicitly consented;

2.If we are legally required to provide your information due to laws, regulations, mandatory administrative actions, or judicial orders, we may disclose your information in accordance with the type of information requested and the manner in which it must be disclosed. In compliance with applicable laws and regulations, when we receive a request for disclosure of information, we will require the requesting party to provide the necessary legal documents, such as a subpoena or inquiry letter. We are committed to maintaining transparency regarding the information we are asked to provide within the boundaries allowed by law. We carefully review all requests to ensure they are legally grounded and are limited to data that law enforcement agencies are lawfully entitled to access for specific investigative purposes.

We are fully committed to complying with applicable laws, regulations, and national and industry standards regarding the protection of the rights of data subjects. We will take all necessary measures to ensure that you can exercise your rights as a data subject in accordance with the law. You can exercise your rights by contacting us through the relevant channels provided in this application or by using the contact information explicitly outlined in this Policy. Your key rights within this application include:

You have the right to access, update, or correct your personal information, except in cases where legal or regulatory exceptions apply.

(1)Your Account Information: Within this application, you can access the avatar information and account nickname you have provided by navigating to [“Account” → “Settings” → “Avatar”]. You may also update the relevant information using the same path.

(2)DESLOC Device Usage: Within this application, you can view your linked smart IoT devices by navigating to [“Home” → “Device Name” → “Settings”]. You can also view product information for individual devices, including device model and Bluetooth MAC address, as well as your usage data, such as network connection methods and sharing settings.

You understand and agree that updating or correcting your information does not affect the validity of any transactions, services, or other actions that you have entered into with us or third parties based on the personal information prior to such update or correction.

You can modify and delete your personal account information directly within this application in accordance with the rules we have set. Order information cannot be deleted by the user, while device information requires unbinding and deletion by the user. The specific operation paths are the same as those for accessing or correcting your information, as described above. In the following circumstances, you may request the deletion of other personal information by contacting us through the contact details provided in this Policy. We will respond to such requests after assessing their compliance with applicable laws, regulations, and policy requirements:

(1)Our actions violate laws, regulations, or this Policy;

(2)We collect and use your personal information beyond the scope and authority outlined in this Policy;

(3)You deactivate your DESLOC account;

(4)We discontinue our services and operations.

If we decide to proceed with your deletion request, we will also notify the entities with whom we have shared or who are entrusted with processing your personal information, instructing them to delete it promptly (unless otherwise mandated by law or regulation, or unless those entities have received your independent authorization).

Following the deletion of the relevant information by you or with our assistance, due to applicable legal and security technology limitations, we may not be able to immediately remove the information from backup systems. In such cases, we will securely store your personal information and restrict any further processing until the backup can be cleared or anonymized.

You understand and agree that the deletion of your information does not affect the validity of any transactions, services, or other actions previously conducted between us or with third parties based on your personal information prior to its deletion.

You have the right to choose whether or not to grant permission for the provision of your information. While certain information is necessary for the use of our services, the provision of most other information is entirely at your discretion. You may modify the scope of your authorization for us to continue collecting information or withdraw your authorization by deleting the information, disabling product features, or using other available methods. Once you modify the scope of your consent or withdraw your authorization, we will no longer be able to provide services closely related to the scope of the modification or authorization withdrawal, and we will cease processing your corresponding information. However, please note that withdrawing your authorization will not affect the validity of any information processing that has already been conducted based on your prior consent.

The specific methods to modify the scope of authorized consent or withdraw authorization are as follows:

Modifying or Withdrawing Authorization Settings

(1)You may adjust the permissions for the camera, microphone, photo albums, and other relevant features directly within the operating system settings of your device to modify the scope of consent or withdraw your authorization as outlined in this Policy.

(2)Within this application, you can enable or disable corresponding permissions by navigating to [“Account” → “System Permissions”]. Once authorization is withdrawn, we will no longer collect information related to these permissions.

In accordance with the terms of our individual service agreements and applicable laws and regulations, your account for a specific service may be canceled or deleted. Upon cancellation or deletion, all associated service information and data will be deleted or handled in compliance with the relevant service agreement.

If, after careful consideration, you still wish to cancel your account on this application, you may submit a request via the settings page of the relevant features within the products and/or services you are using or follow the provided instructions. For example, the cancellation process for the DESLOC Smart App is as follows: “Account → Settings → Delete Account”.

You have the right to request a copy of your personal information. If you wish to obtain a copy of the personal information we have collected about you, please feel free to contact us at any time. We will provide you with a copy of your personal information, subject to compliance with applicable legal requirements and technical feasibility.

1.To ensure that the application can properly receive client push notifications while in a closed or background state, this application may utilize self-start functionality. This involves broadcasting a signal at certain intervals through the system to trigger the application’s self-start or associated startup actions, which are necessary for the functionality and services provided.

2.When you interact with content-based push notifications, you will be redirected to the relevant content only after your explicit consent is obtained. Without your consent, no self-start or associated startup will occur.

We are dedicated to safeguarding the security of your personal information. To protect your personal and product data from unauthorized access, alteration, use, or disclosure, we implement a range of security technologies and protocols.

Your personal data is stored in secure computer systems located in controlled environments, and access to these systems is strictly limited. We have established access control mechanisms that authenticate and regulate the privileges of employees handling personal information. Additionally, we clearly define the roles and responsibilities of employees and partners who may come into contact with your personal information, ensuring that only authorized individuals are granted access.

To protect the security of highly sensitive data (such as passwords), we utilize encryption technologies during transmission. When displaying personal information, we employ a variety of data desensitization techniques, including encryption and anonymization, to strengthen the security of personal information during use. In the context of technology development or internal market analysis, we exclusively utilize de-identified data for statistical analysis.

While we have implemented these measures, it is important to understand that the internet is not an entirely secure environment. Consequently, we cannot guarantee the security or integrity of personal information transmitted over the Internet. We remain committed to ensuring the security of your personal information, and in the event of any data breach, we will handle it in accordance with applicable data protection laws and promptly notify the relevant supervisory authorities and affected individuals when necessary.

Personal information that we collect and generate within the United States is stored domestically in compliance with applicable legal requirements.

Except where required by mandatory legal or regulatory retention obligations, we will retain your personal information only for the period necessary to achieve the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

Once the retention period has expired, we will delete or anonymize your personal information in accordance with applicable legal requirements. In the event you cancel your account or voluntarily delete your personal information, we will handle such data in accordance with the relevant laws and regulations.

To mitigate unauthorized access, disclosure, or other associated risks, we have implemented all legally mandated physical, electronic, and administrative safeguards to protect the information collected from your devices. We are committed to ensuring the protection of your personal information in compliance with applicable laws.

DESLOC places great importance on the protection of minors’ personal information and has implemented the following protective measures:

We are committed to safeguarding the personal information of minors. While we do not require age verification as a prerequisite for providing our products or services, the nature of our products and/or services requires that users be adults with full legal capacity for civil conduct. If you are a minor, we require that your parent or legal guardian carefully review this Privacy Policy and provide their consent before you use our products and/or services or share any personal information with us. Your use of our products and/or services should be conducted under their supervision.

If a parent or legal guardian has reason to believe that a minor has provided personal information to us without prior consent or has concerns about how we protect minors’ personal information, they are encouraged to contact us using the methods specified in this Policy.

If you, as a user, authorize a minor to use our product, grant them access privileges, or add their information as a user profile (collectively referred to as “authorizing a minor to use the product”), you must either be the minor’s legal guardian or have obtained explicit consent from their legal guardian for both your management of the minor’s personal information and our collection, storage, and processing of such information.

Given the unique nature of this product, when authorizing a minor to use it, you are responsible for appropriately supervising their usage to ensure compliance with legal and safety requirements, as well as adherence to this Privacy Policy.

We may update the terms of this Policy as necessary, and any such updates will become an integral part of the Policy. In the event of significant changes, we will notify you and seek your renewed authorization. You will have the option to discontinue using our services if you do not agree with the changes. If you choose to continue using our services after being notified, it will be deemed as your acceptance of the revised Policy.

The above significant changes include, but are not limited to:

(1)A material change in the way we provide our products or services that results in a substantial alteration in the purpose, method, or categories of personal information we collect and use.

(2)A significant change in the scope or content of your rights under this Policy.

(3)A major change in our corporate structure that necessitates modifications in the storage or management of personal information, or requires the transfer of personal information.

(4)Changes to the department responsible for handling personal information security, including updates to contact details or complaint channels.

We prioritize your satisfaction with any modifications to this Policy. We encourage you to review our Privacy Policy regularly when using our services.

If you have any questions, comments, or suggestions regarding this Policy or matters related to your personal information, please contact us via email at privacy@desloc.com. You may also reach us by mail at:

Address: Room 102-2, Building 1, No. 7 South Jianghui Road, Changhe Street, Binjiang District, Hangzhou

Postal Code: 310051

In general, we will respond within fifteen days.

The provisions of this Appendix apply to California residents in accordance with the California Consumer Privacy Act (“CCPA”) and other applicable laws. The CCPA grants California residents certain legal rights, such as the right to opt out of the sale of personal information (“Do Not Sell”). These rights are not absolute and are subject to certain exceptions.

We collect, use, disclose, and retain your personal information in the same manner as described in the main body of this Privacy Policy.

In the past 12 months, we have not sold the personal information of California residents as defined under the CCPA.

The provisions of this Appendix apply to California residents in accordance with the CCPA and other applicable laws. The CCPA grants California residents certain statutory rights, including the right to opt out of the sale of personal information. These rights are not absolute and are subject to certain exceptions.

We collect, use, disclose, and retain your personal information in the same manner as described in the main body of this Privacy Policy.

We have never sold, and will not sell, the personal information of California residents as defined under the CCPA.

If you are a California resident and no exemption under the CCPA applies to you or your personal information, you are entitled to exercise your rights free from unlawful discrimination. This includes being protected from receiving a different level or quality of service or being denied goods or services as a result of exercising your rights under the CCPA, in addition to the rights outlined in the main body of this Privacy Policy.

Our goal is to process all verified requests under the CCPA within 45 days. If an extension is necessary, we may extend the timeframe by an additional 45 days and will provide an explanation for the delay.

If you are a California resident to whom the CCPA applies, you may exercise your rights, if applicable, by contacting us at privacy@desloc.com.

Additionally, if you are a California resident under the age of 18 and a registered user of DESLOC, Inc., you may request the removal of any content you have publicly posted on DESLOC, Inc.’s website. To request the deletion of such content, please send an email to privacy@desloc.com with details of the specific submission.

The concepts and terms referenced in this Policy are defined as follows:

1.DESLOC: Refers to Hangzhou Future Key Technology Co., Ltd.

2.Affiliates: Entities that belong to the same corporate group as DESLOC, have an equity control relationship with DESLOC, or do not have an equity control relationship but adhere to the same management system and security management measures. It should be noted that not all companies using “DESLOC” in their trade name or operating under a commercial mark containing “DESLOC” are affiliated with DESLOC. Users should carefully verify such affiliations or contact us through the designated contact information provided in this application for confirmation.

3.Personal Information: Refers to any information, recorded by electronic or other means, that relates to an identified or identifiable natural person, excluding data that has been anonymized. The scope of personal information described in this Policy is defined in the body of the policy.

4.Sensitive Personal Information: Refers to personal information that, if disclosed or misused, could potentially harm an individual’s dignity or endanger their personal safety, property, or security. This includes, but is not limited to, biometric data, religious beliefs, specific identities, health-related information, financial account details, and location or movement tracking information.

5.Collection: Refers to the act of acquiring control over personal information, which includes direct provision by the data subject, active collection through interaction with or recording the behavior of the data subject, and indirect acquisition through sharing, transferring, or collecting publicly available information. If the provider of a product or service offers tools for use by the data subject but does not access personal information, such actions do not constitute the collection of personal information.

6.Child: A minor under the age of fourteen.

7.Minor: A natural person under the age of eighteen; a minor aged sixteen or above who primarily supports themselves through their own labor income is considered to have full civil capacity.

8.De-identification: Refers to the process of applying technical measures to personal information such that it can no longer be identified or linked to an individual without the use of additional information.

9.Anonymization: Refers to the process of applying technical measures to personal information such that the subject of the information cannot be identified or linked to it, and the processed data cannot be restored. Information obtained through anonymization is no longer considered personal information.

10.Deletion: Refers to the act of removing personal information from systems involved in the execution of daily business functions, ensuring that the information is no longer retrievable or accessible.

11.SDK: Also known as a Software Development Kit, it is a collection of development tools, including specific software packages, software frameworks, hardware platforms, and operating systems, used in the creation of application software.

12.Products: Refers to the intelligent hardware produced by DESLOC that must be linked with the application to enable full or partial functionality and meet usage requirements.

13.Client Terminal Devices: Also referred to as “Terminals” or “Terminal Devices” in this document, these are mobile internet-enabled devices you use to download, install, and operate DESLOC’s business applications. This primarily includes smartphones, tablets, and similar devices.

14.Permissions: Also referred to as “Application Permissions” in this document, this refers to the range of system functionalities on your client terminal device that are granted to the DESLOC business applications. These permissions primarily include access to photo albums, microphone, Bluetooth, location, and other features.