PrivacyRegulations

一、Brief Introduction

Xiamen Retone Hearing Technology Co., Ltd and the related Global companies(Hereinafter referred to as “RUITING”，“RETONE”, “WE”and “OUR” ) deeply know the importance of privacy to you and will respect your privacy. Please read and understand this 《Privacy Policy》(hereinafter referred to as “this policy”) before you submit your personal data to RETONE.

This policy is applicable to the product and service on RETONE website which indicate this privacy policy or link to this privacy policy. Hope you have already read carefully and fully understand the contents of this privacy policy before you use our product and service, and you can make the suitable choice which you think by following the guide of this privacy policy. For related terminology mentioned in this privacy policy, we try our best to express simply and provide the further illustration link so that you can understand better. You can use the contact information at clause 9 to contact with us.

This policy illustrates how to handle your personal data, but this policy may not involve with all possible data handling situation. The information of specific data of product or service collected will be released at the supplementary policy in RETONE or notice provided when collecting the data.

We will strictly abide by this privacy policy and applicable law to handle your personal data, especially 《General Data Protection Regulation》（hereinafter referred to as“GDPR”） and your residence’s other applicable law.

二、The Legislative authority of the purpose and handle of our data collection

◆ Personal information is various information about natural person which already be recognized or recognizable record by electrical or other method, not including the information after anonymized handle. Sensitive personal information is that can cause hurt of human dignity or harm to the personal and finance safety once the personal information leaked or be used illegally, including biology recognition, religious belief, special identity, medical health, financial account, whereabouts track and so on, and the personal information of teenagers under the year 14.

◆ For the following purpose described by this policy, we will adhere to legitimate, legal and necessary principal to collect and use your personal information using the product and/or service, or generated by when you use product and/or service or from the third party. If we will use your personal information to other usage which is illustrated in this policy or use the information collected for special goal to other purpose, we will inform you by reasonable way and will obtain your consent again before using it.

1.Technical parameters collected by App programme

（1）Account registration,log on and verification

◆ When you register account of RETONE, you should at least provide us your RETONE account name, password, cell phone number, email address(is used for email verification) which you prepare to use. We will verify whether or not your identification is effective by the way of sending you message verification code or email. It will recognize and display corresponding operator carrier through SIM card information. Your account name is your default nick name. You can alter and supplement your nick name, gender, birth day, interest, hobby and the relative information of real name authentication. Those information all belong to your “account information”. You supplementary account information will help us to provide recommendation of personalized commodity and better product and/or service experience. If you don’t provide those supplementary information, it will affect basic function of your internet purchase.

◆ After you successfully register RETONE account, you can use RETONE account to log in “RETONE APP”. Please provide your RETONE account information when you log in. If you do not provide this kind of information, you can not log in “RETONE APP” and use our product and/or service on “RETONE APP”, at this moment, you can use browse and search function, we will not collect your personal information mentioned above.

（2）Merchandise/Service information reveal and search

◆ In order to let you fast find your needed product or service, we may collect the information of your device using our product and/or service (including device name, device type, MAC address and IMEI, device recognized code, mobile application list form, software and hardware characteristic information and so on, operating system and application programme version, language set, resolution, service provider internet ID(PLMN)), device positioning related information(including GPS positioning information which you authorize and WLAN connecting in point, Bluetooth and base station sensor information),browser type to provide best revealed way of merchandise information to you. We will also use your above personal information to continuously improve and optimize the above function. If you don’t want to see the information of recommended merchandise or service, you can select to shield the category of relative merchandise or service according to pop-up window through long press the photos of recommended product or service.

◆ You can also precisely find your needed product or service by searching. We will keep your searching contents so that you can input it repeatedly or reveal the product or service related to your search contents.

◆ Please Note that: As to independent device information, browser type or only searching key word, those information can not independently recognize your identification, which does not belong to your personal information. We have right to use them with any purpose. Only when those above information is used by mutual combination with your other information which can recognize your identification, then during the combination use, we will handle and protect those above information as your personal information according this privacy policy.

◆ In order to reveal the information of commodity or service which you are interested in to you, or reveal the commodity which you hope to find to you when you are searching, we may collect your order information, browsing information, your interest and hobby(you can select in account set) to do data analysis and form an user diagram. For reasonable need of providing service or improving its quality, we may gain your other information, including the related information of contact between you and our customer service, your questionnaire reply information, and the related information gained from interaction between you and our partner, related party. We may combine the information from some service with information from other service so that we can provide you service, personalized content and suggestions. If you don’t want to be affected by personalized content, you can choose to browse and search commodity and service according to classification at commodity exhibition page. We provide you the options for none personal characteristic following the sorts of price and sales volume at the results of search. Without your consents, we will not provide your personal related information to the third party.

◆ For Purchase and Warranty data, which means the data (including personal data) you provide to us when you buy RETONE product and service, including the related data about rights under your product warranty. The data of purchase and warranty may include your financial data, contact data(such as your name, mail and bill address, telephone No. and email address), product recognized data ( such as serial No. of hearing aid), and health data such as your hearing diagram or your ear pressure module(mould).

◆ For hearing device and App using data, this means the data generated when you provide or you use our hearing aid or App programme or both, including personal data(hearing device and App using data including: the data input into hearing aid or App function by you which includes your name, address, birth date, gender, height, weight and hearing record, and the related data about your hearing aid programmable, any third party contact person recognized by you and any other data which is related to App, you submitted and the hearing device you used. )

◆ About the data of App using situation and function, for example, when you activate and use some specific function and using degree or lasting time. This will help RETONE to provide best function and whole user experience.

◆ RETONE also will record some technical data (including internet protocol related data) and device affairs data such as system collapse, system activity, hardware set and date, time which you ask for.

◆ For the category of using time and environment for hearing aid, this is necessary for RETONE to provide our product and some special characteristic and function. You can turn off this data collection function, but this may limit the function of our product and service.

◆ If your mobile device has already activated and operated the geographic positioning function( also called “positioning service” or “GPS tracking” or other terminology), RETONE may collect positioning data (if you are using one of our Apps)。You can turn off geographic positioning function on your mobile device to stop collecting those data.

◆ For health and patients’ data, this means the data collected from when you ask for appointment, including your name and contact data such as telephone number or email address, and the data related to your hearing healthcare needs which includes health data and the preference how we contact with you.

◆ For telecommunication data, this means the data provided at any method, any reason, including personal information when you have communication with RETONE. The telecommunication data includes data provided by your phone, therein may include your name, telephone number, address, email address, device series number and any phone communication contents between you and us.

◆ For the data which you authorize the third party be shared, this means the third party that you authorize can share your personal data from us. For example, you may authorize your hearing healthcare expert to share the information, therein may includes your contact data, financial data and health data. We also can collect your personal data through website managed by the third party (such as third party hearing healthcare expert).

◆ For anonymous data, this means the data can not recognize you or let you be recognized by other ways. For example, We may collect the general data related with operation system type and interacted mobile device about our product and service which you visit, and the general data related to your hearing device such as brand, type and firmware used by hearing aid. At some situation, RETONE can polymerize and de-identify all data which is used for recognize your identification so that make them into anonymous data. In this privacy policy or applicable law, anonymous data is not deemed as personal data.

◆ Other data: or the personal data you provide to us.

2.The purpose of App’s collecting the data

（1）According to the interaction between you and RETONE and using situation of our product and service, RETONE may collect your personal data due to following reasons:

◆ Provide the rights of using our product and service, whatever you visit and use by yourself or under the help of healthcare provider.

◆ Manage, maintain and improve our product and service.

◆ Signing with you for, implementing and terminating the contract.

◆ Do communication with you by schedule of appointment.

◆ Sending the important notice or confirmation to you, and the technical notice about update and safety warning and so on.

◆ Reply your opinion and questions and provide user support to you.

◆ Prevent abusing our product and service, and investigate or accuse any potential threat or abuse.

◆ Protect, investigate and restrain fraud, illegal, none-authorized activity.

◆ Protect RETONE and its customers’ rights and property, including under the situation of law judicial action.

◆ Track and analyze our advertisement and promotion activity.

◆ Sending the marketing or promotion information to you according to your behavior and personal data, according to your set may including social interaction notice , investigation or other news release.

（2）Fulfill any purpose which you agree with us

◆ Some functions of our website allow you use online form to communicate with us. If your communication need our reply, we may reply you by email. Email reply or confirmation may include your personal data, including your name or contact method. We guarantee that the email we send to you may be intercepted without authorization.

◆ Under the situation of law requirements, we need to gain your consents before we send you some marketing data. You can contact with our data protection officer to revoke consents anytime. You also can choose not to receive future marketing data( such as marketing email) at any time by using the instruction provided when using marketing data.

◆ We will gain your consents before using the data about your hearing and position. You can revoke your consents anytime. You can prohibit the positioning tracking by setting your device, or under some possible situation, you can use the function in our product and service to turn off the geographic positioning information tracking or terminate the visit to your account from RETONE(Such as deleting mobile App).

（3）Data for R&D

◆ After obtaining your consents, we will handle your personal data including your health data to help us to make better hearing aid including new algorithm and service.

◆ If you has already agree that RETONE uses your personal data to do R&D before when you consult with hearing healthcare expert. RETONE will collect this kind of your personal data and above mentioned data to assembly them together into a file document and are used for above described purpose.

◆ Shared data with your hearing healthcare expert.

◆ Those data may be the country/territory where you use this App and frequency which you use specific function. We will assembly those data, but not be used to recognize your identification, because our purpose to assembly them is know about the using situation of those application function.

◆ We may use the data collected by this App and other data, including personal data provided when you use our any service ( such as RetoneFit, myRetoneFit cell phone App programme or myRetoneFit.com) .

◆ If you have and doubt how healthcare expert use our personal data, you should contact with this expert. This is consents agreement of sharing data with your hearing healthcare expert. This privacy declaration dose not cover the real usage to data from hearing healthcare expert.

◆ If you do not agree that we share your personal data with your hearing healthcare expert, The information will much less for improvement of your hearing aid fitting situation when they do fitting in the future.

◆ Please note: Don’t use App replace professional doctor’s order from hearing healthcare professional staff.

◆ The collected App using data play a very important role, they can ensure that we can always provide ,keep, protect and improve RETONE’ service. In addition, they also can make us recognize the needs of improvement of current function so that we develop new App. Before obtaining your consents, the data collected by RETONE App will not be sued for other purposes.

◆ As discussed previously, the behavior of collecting data is just for all user of mobile App, therefore, we will not tract personal user.

◆ In addition, application data will be kept secret, which means only the product development department staff can see the detailed data.

◆ RETONE store application data in our own server. Those data may be stored in international server out of your country. We have adopted very safe measure to protect app data’s storage. Under some situation, RETONE may use outside data to collect service, this means we may use None-RETONE’s all servers to store the application data. Those data will be kept secret.

◆ Necessarily, we will be reasonable to use your personal data under legal commercial purpose or we think that we obey the law and regulation when necessary.

◆ The above mentioned personal data related to health information will not be shared based on the purpose of obtaining economic benefits, and will charge any extra cost based on improvement of fitting of hearing aid. If the personal information which we want to use exceed the above mentioned purposes scope, we will not use them before informing you and obtaining the consents from you.

3.Your consents is the legal ground of our sharing your personal data ( No. 6(1) (a) and 9（2）（a） clauses GDPR).

三、How to collect your personal data

1.You can directly provide data to RETONE.

2.We will collect the data provided by you when you buy and use our product and service. For example, when you download RETONE app, for creating a user account, matching this App with your hearing aid, then activating and using the function of App, you need to provide data to RETONE. The data which you provide to us including personal data, such as your name, address, birth data, gender, height, weight, hearing sensitive degree diagram and the data related to hearing aid programmable, the third party contact person and the other data provided by you about using our product and service.

3.The data we collect depends on the method of interaction between you and our RETONE, such as the visited website or the product and service be used, including name ,gender, company name, position, address, email, phone No., logging information (account name and password), photos, credentials information and so on. We also collecting the information provided by you and the messages you send to us. Such as inquiry information when you input or the questions or information provided by you for gaining customer service support. At some situation, you can choose not to provide personal data to REONTE, But if you choose not to provide, RETONE may not provide related product and service to you , and also respond or solve the issues which you encounter.

4.You indirectly provide data to RETONE (using cookie technology and so on to collect).

◆ To ensure the normal operation of App/website, we sometimes store the data on computer or mobile device into a small data file named “Cookie”. Cookie is a kind pure text file which is stored in computer or mobile device by a kind of internet server. The contents of Cookie only can be read or retrieval by the server which create them. Each Cookie is unique one for your website browser or mobile app. Cookie normally includes identifier, site name and some numbers and characters. The website can store the data such as user preference or commodity in purchase basket by using Cookie.

◆ We use Cookie, etc. tracking technology to collect the data how you use our product and service, and will provide you the basic service, function and personalization of our product and service. The purpose of this section is providing you the necessary data related to our use of Cookie and the data stored in this kind of cookie at your device when you visit our website so that you can choose whether or not allow to put cookie on your device.

◆ RETONE will not take Cookie to use for any usage out of the purposed mentioned by this policy. You manage or delete Cookie according to your own preference.Please check AboutCookies.org to see more details. You can also remove all Cookie stored in this computer, most net browser does not have the function to stop Cookie. But if you do like this, then you need to modify user set by yourself when you visit our website every time. If need to know more details how modify browser set, please visit following links: ：Internet Explorer Google Chrome Mozilla Firefox Safari Opera。

◆ If you are located at European Economic Zone, please check our Cookie policy and know how we use other related types tracking technology and Cookie.

◆ Cookie is some small text file stored in your computer when you visit the website, Cookie is widely be used for website operation, or better efficiency operation , and providing web service and function for user.

◆ Web beacon is may be downloaded to our web, App and some small text file on tools (also called “pixel”, “image lable” or “script label” ), those files may coordinate with cookie to work so that they recognize our user and provide anonymous data about their activity.

◆ For privacy law regulation of some jurisdiction, we must obtain your consents before you store or visit cookie on your device. But for the necessary cookie which we provide you our product and service, we do not need any consents from you.

◆ Necessary cookie is providing you the needed cookie for core website function, personalized and browsing history . For example,you need a preference cookie to save the record that you agree or not agree preference, so we can abide by them in our future visit. They can prohibit it only by modifying browser first choice item. RETONOE does not share those data with the third party.

◆ Function cookie can help us to customize the web contents according to your preference and can provide personalized experience on our website. The data collected by those cookie may be anonymized, and not including browser activity of the third party website.

◆ Analysis cookie is used for collecting the data of our web flow and user activity. Those data is polymeric and anonymous, which will recognize the identification of any individual visitor. It includes numbers of visitors who visit our website, pages visited and other similar data. We use those data to help operate, maintain and improve our website.

◆ Prohibition cookie: most web browser allow to control cookie through browser set. You can avoid receiving cookie by adjusting your web browser. However, this may lead to bad operation of website. The methods used for impeding cookie depends on web browser which you use. Please gain the relative illustration by referring to “help” in browser or corresponding menu.

◆ For more details about cookie data, including how to check cookie set, how to manage and delete them, please visit www.allaboutcookies.org, If you want to choose to prohibit being tracked by Google analytics, please visit: http://tools.google.com/dlpage/gaoptout. Currently we don’t respond to browser of “prohibiting track” signal sending.

5.You authorize the third party to provide your data to RETONE

◆ You may authorize the third party (such as your hearing healthcare expert) to provide the data about you to RETONE. For example, you may authorize your hearing healthcare expert to provide your personal data to RETONE, therein may including your contact data, financial data and health data. We also collect your personal data through the website managed by us for the third party(such as hearing healthcare expert).

四、Throw daylight on your personal data

1.The third party you designated

◆ If you agree, we may share your personal data with the third party. For example, If you add the third party contact persons in our product and remote service function, meanwhile, those contact persons have already agree to receive notice, then they may receive some personal data about you.

◆ Under the situation of requirement of applicable law or responding law procedure , RETONE may reveal your personal data to the related law enforcement agency or other government agency. In some jurisdictions, if RETONE is involved with restructuring, merger or bankrupt and cleaning lawsuit, then your personal data may be revealed to trade party. RETONE also will your data under the situation of reasonable needs. For example, for carrying out the contract and we think it is necessary to reveal your data for prevent body damage or financial loss or investigation possibility or real illegal behaviour and the reveal is suitable .

2.Outside handle

◆ We may share your personal data with the third party provider which provide data analysis, payment handle, information technology, related infrastructure, email delivery and other similar service, such as IT provider. To ensure those data handle parties as described by this deceleration, we require that the third party provider can only use your personal data when they provide our required service according to our instructions, and should abide by our privacy policy and any other necessary secrecy and safety measures.

3.For reason of law

◆ We will share your personal data by the following necessary or applicable situation which we think：

（a）Abide by applicable law.

（b）Following the reasonable requirement by law enforcement or monitor office, agency or department.

（c）During the lawsuit or law defend.

（d）It is thought that meet the legal rights for management our business when obtaining professional suggestions (including law suggestions) about audit and business.

（e）Implementing our agreement.

（f）Protect our or your or other person’s rights, privacy, safety or finance. We will not delete and investigate the personal data about dispute. We will store the related data before fully solve those issues.

五、Sending your personal data to the third country

◆ Under the permit of applicable law, RETONE’s product and service can be applicable for the server in each country/territory including USA and other technical resources deliver. Therefore, your personal data may be transferred to other place outside your country. We will adopt the measures to protect and maintain your personal data (normally, transfer them according to standard contract clause approved by EU committee) to ensure handling your data by safe method and based on the regulation of this privacy policy . If need more details, please contact with our data protection officer.

六、Your Rights

◆ Under specific situation , if it is applicable to the jurisdiction of your residence, you will have one or more rights:

a.You have rights to ask for visiting your personal data and supplementary information. This can let you receive transcript of your personal data which we hold and confirm whether or not we are legal to handle those data (NO. 15 clause in GDPR).

b.You have right to may ask for modifying your personal data which we hold. This can let you correct your any incomplete and incorrect information which we hold.

c.You have right to ask for deleting or removing your personal data. This can let you require us to delete or remove your personal data when we are urgent to handle your data without reasonable reason. If it is unnecessary that we continue to handle your personal data such as obeying lay obligation or setting up, implementation or maintenance of law requirement, then we do not need to delete your personal data(No. 17 clause in GDPR).

d.If this is our legal right(or the third party legal right), But your specific situation make you want to refuse us to handle your data, then you have right to refuse us to handle your personal data (No. 21 clause in GDPR).

e.You may have right to ask for limiting handle your personal data. This can let you require us to stop to handle your personal data, for example, you doubt the correction of personal data (No. 18 clause in GDPR).

f.You may have rights to ask for transferring your personal data to other parties(this also called data portability )(No. 20 clause in GDPR). This right can let you move, copy or transfer your personal data from RETONE to another server by safe, reliable and easy way, and will not affect the usage.

g.You have right to revoke consents anytime (No. 7(3) clause in GGPR).

h.You may have right to ask for obtaining the information of public or private entity who shared the data with us together.

i.You have rights to require that we provide the information whether or not the results about disagree and refuse. RETONE will seriously treat this privacy obligation. If you submit complain that we violate the applicable law, then will give you reply soon and the reply time limit will not exceed 30 days.

j.If there are some problems which can not be solved, you also have the rights to complain to the Ministry of industry and information technology of the people’s Republic of China or your residence or data protection agency in the country/territory where the violation behavior for data protection law.

◆ If you want to use those rights, please contact with by follow method：

Retone Hearing Technologies

Receiver: data protection officer

Address: 209, 2nd Floor, No. 999 Tianma Road, Jimei District, Xiamen City

Post address: 361021

Telephone number: (+86)0592-5777665

Email address: cd@retone-hearing.com

◆ In your request, please specify it is concerned about which personal data and what rights you hope to use mentioned above. To protect your benefits, we may need to verify your identification before implementing your request. It needs about one month to carry out your request. We will tell whether or not need extra time.

◆ Please note that those rights may be limited according to applicable law. For example, your data is used for lawsuits. To store in file or finish any trade before you ask for modification or delete, we may need to keep some data, unless the law require or allow longer retention period ( such as for purpose of supervise).

◆ You can cancel subscription or quit the subscription by click the link provided in the email when you receive our promotion email. You can’t choose not to receive administration corresponding email( Such as the communication about the using our product an service, or the communication about the hearing healthcare which we provide).

◆ If you thought that exist the situation of invasion of privacy, you also can complain to the suitable privacy expertise at your juridical place.

七、Data Retention

1.Your personal data shared with RETONE or your hearing healthcare expert. We will keep your personal data within the time needed by the purpose illustrated in fulfilling this privacy policy during the time you have relationship with RETONE. When you choose to delete the App, your personal data also will be deleted, unless the retention time is required to extend or contract by law or regulation. The personal data which you require us to share with your hearing healthcare expert is stored by RETONE until your hearing aid is checked by your hearing healthcare expert next time. During the time when your hearing healthcare expert check your hearing aid next time, we will share your personal data with your hearing healthcare expert. After that, those data will be deleted. If you do not consult with your hearing healthcare expert and accept the check to your hearing aid withing 5 years, then those personal data will be deleted automatically.

2.If you require RETONE to delete your personal data, RETONE will keep your request record so that can satisfy your future request. RETONE will delete your required personal data after, but it must satisfy any law retention request or law exceptional situation for delete request.

3.Technical parameters collected by App will be delete after two years.

Note: When you cancel the account, we will keep your related information according to the regulation about the law and statute of 《internet safety law of the people Republic’s of China》. If exceed the statutory storage timing, we will delete for anonymize your personal information.

八、Data Safety

◆ We adopt the safety measures which meet the industrial standard to prevent your personal data loss, being used or visited or modified or revealed without authorization. RETONE use acceptable method(including encrypt) on commerce to protect your personal data, but we can not guarantee its absolute safety.

◆ If you firmly believe that your personal data or any of our product and service are unsafe or visited without authorization, please immediately contact with our data protection officer. If you receive doubted corresponding from RETONE, please do not open or reply it and contact with our data protection officer. American Federal Trade commission provide more details about how to avoid identification being theft : https://www.consumer.ftc.gov/topics/online-security.

◆ In addition, we do the limit for your personal data visit by staff and fitting expert. They need to visit your personal data to carry out their work, but the have already make the promise to keep secret and be responsible for applicable statutory obligation for keeping secret.

九、Contact information

◆ Thanks you for using our product ans service and thanks for reading this privacy policy. You are welcome to submit suggestions or questions. If you have any feedback or suggestions, we advice that you can contact with our data protection officer through under any contact method：

Retone Hearing Technologies

Receiver：Data protection officer

Address: 209, 2nd Floor, No. 999 Tianma Road, Jimei District, Xiamen City

Post address: 361021

Telephone number: (+86)0592-5777665

Email address: cd@retone-hearing.com

十、For residence in California

◆ 《Act of consumer privacy in California》（CCPA）requires us provide to California residence how we handle their personal data’s specific information.

1.Classification of CCPA personal data.

Retone collect the personal data according to the following classification assured by CCPA:

1)Identifier

2)Customer record

3)Biology statics information

4)Internet or net activity

5)Geographic Location

6)Sensor information

7)Occupation or employment

8)Inference

◆ As further detailed described in this privacy policy, RETONE will collect those data when you visit our website or purchase and use our product and service. We collect your personal data, because they are necessity for providing, operating, maintaining and supporting our product and service, as well as managing and promoting our business. Please refer to and read other parts of our privacy policy, including “the purpose of collecting data by App” and “how to collect your personal data”.

2.Exert your rights

◆ California Residence has right to submit the following requirements(at most twice each year)：

1)Has the rights to ask for obtaining your specific personal data collected by RETONE.

2)Has the rights to require that RETONE reveal what personal data is collected, used, revealed or sold by us.

3)Has the rights require RETONE to delete personal data about you which has been collected (Except some exceptional situation)

4)Has the rights to choose not to sell your personal data.

◆ You can exert the rights of visiting and deleting data by the following ways:Send email to us, or give a call to us to contact with our data protection officer. This section does not involve or be applicable to the handle of protected health data by constraint of HIPAA or 《Act of Medical information in California》， including any data collected from your hearing device or RETONE app by us or any other personal data which obtained exemption according to No.1798.145(c)-(f) clause in CCPA.

◆ We will not share any data which RETONE collect or transfer by App with attached or none-attached third party who need those information for direct marketing purpose. If you are residence in California,then you can require us to gain the related information about revealed personal data to third party for direct marketing purpose. If you want to submit those request, please use the above mentioned data listed by “contact data” to contact with us. You must write “your privacy rights of California state” in the subject field. For the notice letter with incorrect stick label, incorrect sending or incomplete data, we will not be responsible for it.

十一、For France residence

◆ You have the rights at any time to release the relative instruction how do handle your personal data after you die.

十二、Children Privacy

◆ Our product, website and service are mainly for adults. If there is no consents by parents or guardian, child is not allowed to create own user account. For the situation of collecting children’s personal data by consents of parents, we only will use or reveal those data under the permit of law, explicit consents by parents or guardian or necessity situation for protecting children. If RETONE found that its collected the children’s personal data without consents verification by parents, then RETONE will delete the relative data as soon as possible.

◆ RETONE’s product and service does not aim at and not be provided to children under 13 year old. According to American law, specially 《Act of privacy protection for online children》(COPPA) in 1998, we will not collect personal data from the children under 13 year old without consents of parents or legal guardian on purpose.

◆ At EEA, we will not collect personal data from the children under 16 year old without consents of parents or legal guardian on purpose. If you consider that we obtain the personal data of children without consents from parents or legal guardian, then please contact with our data protection officer.

十三、Product, service and website of third party

◆ To ensure fluent browsing experience, You may receive the contents or web link from the third party outside of RETONE AND ITS cooperator (hereinafter to be referred as “the third party “) . RETONE has no control right to those third parties. You can choose whether or not visit the link, contents, product and service provided by the third party.

◆ Please notice that the visit to any third party website,software app or other product or service through RETONE’s website, product or service link are all restrained by the using terms and privacy policy of the third party. You should check carefully the using terms and privacy policy of the third party before you use the third product or service.

◆ Umeng Statistics SDK

Usage purpose: Collects statistics on user usage habits

Data type: Device information, location information, network information

◆ Umeng Message Push SDK

Usage purpose: Online and offline message push

Data type: Device information(IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM卡IMSI/ICCID), location information, network information

◆ Agora SDK

Purpose: Enables real-time video and voice calls

Data type: Recording permission, camera permission, read phone status permission, Bluetooth connection permission

In order to enhance the service provided by the RetoneFit App, we will utilize the Agora SDK for voice calls. The Agora open platform's SDK may require permissions such as external storage write and read permissions, recording permissions, and camera permissions to ensure smooth voice call functionality.

◆ Gauder Autonavi positioning SDK

Purpose of use: For accurate positioning and obtaining store locations

Data type: Device identification information, geographic location information

When utilizing gauder map, we commit to the following obligations: In order to provide better service and store information for RetoneFit App, we will use the gauder map sdk from Gauder Autonavi Software Co., Ltd. to locate your location information,which includes gauder autonavi open platform positioning SDK and gauder autonavi open platform map SDK. Your location information (latitude and longitude, precise or approximate location), device details (such as IP address, GNSS information, WiFi status, WiFi parameters, WiFi list, SSID, BSSID, base station information, WiFi signal strength information), Bluetooth data and sensor data (vector data, acceleration data, pressure data), external storage directory], device identification details (IDFA，OAID), current application details (application name，application version number)，device parameters and system details(system properties，device model，operating system，operator information) may be collected to ensure smooth utilization of the mapping function.

◆ Iflytek Voice SDK

Purpose: Voice service

Data type: Device details , write permission for external storage , read permission for external storage

When employing IflyVoice's SDK ，we strictly adhere to user privacy protection. In this case ，the third party IflyVoice may collect your device details ，device identification details(IDFA,OIAD)，current application details(application name,application version number) in order to obtain write permission for external storage ，read permission for external storage 、recording permissions etc.

十四、Modification of this privacy declaration

◆ In Max. Scope of law permit, RETONE keep the rights to update or modify this policy from time to time. If our privacy policy has any change, we will release our latest version here. If our privacy policy has significant modification, then we will send your modification notice by different channels. For example, we will release notice on website or send you notice along.

◆ The latest update data of this privacy declaration is 8th Jan., 2024.