Shenzhen CYLAN Technology Co., Ltd. PRIVACY POLICY

Last Updated: August 10, 2018

This Privacy Policy explains how Shenzhen CYLAN Technology Co., Ltd. and products Clever dog ( “CYLAN”, “AIface”“we”, “our”, “us”) as data controller handles personal information about you that we collect when you use our CYLAN Services over the Internet and mobile applications, including, the “CYLAN Services”). This Privacy Policy also applies to any personal data we collect from the operation and use of products we sell while connected to the CYLAN Services (the “Products”), and any other CYLAN Services that link to this Privacy Policy. We may modify this Privacy Policy at any time, provided certain provisions of this Privacy Policy prove to be incomplete or outdated and further provided that these changes are reasonable for you, taking into account your interests. If we makematerial changes to this Privacy Policy, we will notify you by the email address specified in your account or by means of notice on、、 apps of any such changes. You can determine when this Privacy Policy was last revised by referring to the date it was “Last Updated” above.

1. What Information We Collect

In order to provide CYLAN services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.
“Personal information” shall have the same meaning as “personal data” and shall include any information relating to an identified or identifiable natural person ('data subject'); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Examples of personal information include your name, telephone number, email address, physical address, and payment information.
Personal information also includes information that alone cannot directly identify you, but with other information we have access to can identify you, such as product serial numbers, log data that automatically records information about your visit, such as your browser type, domains, page views, the URL of the page that referred you, the URL of the page you next visit, your IP address, and page navigation, unique device ID collected from Products and your mobile devices, data from cookies, pixel tags, and web beacons, video content files that do not contain personal visual identity information, the country and time zone of the connected Product, geo-location, mobile phone carrier identification, and device software platform and firmware information.

2. How We Collect and Use Your Information

Here are some examples of the personal information we may collect and how we may use it:
2.1 When you create your account to use Clever dog Services (“Account”), we will collect information including your name, phone number and email address. In addition, when you install and activate Products, we will collect certain basic information via our Clever dog Services, such as your product name, the product’s verification code, and serial number, which are unique to the Product connected to the Clever dog Services and associated with your Account.
2.2 When you subscribe to online data storage services, we will collect your payment information, such as a credit card number, account security code, and any other information necessary to complete the transaction and further facilitate and fulfill your subscription of storage services. Your personal information will be saved as your user profile in your Account, including payment information for recurring charges.
2.3 When you save and share content through CYLAN Services, like face detection,face recognition, live video streams, images, captions, and comments (“Your Content”), for other individuals to access, we will collect information to allow you to save and share Your Content, such as your email address and email address of the person you elect to share your content with.
2.4 Through our Clever dog Services, you may be able to invite other people such as friends or family to use Clever dog Services and download our mobile app. We collect that person's email address to automatically send an email invitation on your behalf. We collect this information to send this email, to register your friend or family member if your invitation is accepted, and to track the success of our invitation services. In order to refer a friend, you must first obtain the consent from the person being referred to provide information on their behalf and inform them that they will be receiving a communication from Clever dog.
2.5 When you connect or link to our Clever dog Services via social networking sites, including by sharing Your Content with friends via your social networking account, such as Facebook, we collect your profile information from your social networking account. For information on what information is shared with us, please review the privacy settings in your social media account or the permission screen presented at the time of connection.
2.6 When you respond to our e-mails, contact our customer service, or use other customer support tools, we collect your information to provide you with support, verify your identity with your Account profile information, and confirm your Product.
2.7 When you access our CYLAN Services, we will collect information to provide you with a more relevant experience, to prevent misuse, and to ensure that our CYLAN Services are working properly. We may also record adjustments you make to our Products through the CYLAN Services. We store this information along with data collected directly by your Product. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
2.8 When you save and share Your Content through Clever dog Services for other individuals to access, we will collect information to allow you to save and share Your Content.
2.9 Our Clever dog Services may also contain links to other websites operated by third parties and may include social media features such as Facebook and Twitter buttons (such as “Like,” “Tweet” or “Pin”). We record your interaction with these links.
2.10 When you use the Product’s recording or streaming features, we may record and process video and/or audio content from the Product. This may include capturing and emailing to you portions of this data as part of a notification or analyzing the data to identify motion or other events. We may process information from your Product so that we can send you alerts when something happens. In addition, if you have the recording features enabled, we will capture, process and retain video and audio data recordings from your device for the duration of your recording subscription period.
We may also use the information we collect for the following purpose:
2.11 send you reminders, technical notices, updates, alerts, support and administrative messages, service bulletins, and requested information; and
2.12 pursuant to our legitimate business interests:
• operate, maintain, improve, and develop our CYLAN Services and Products;
• personalize your experience with our CYLAN Services and Products;
• increase the safety of our CYLAN Services and Products – for example, for user authentication, security protection, fraud detection, filing, and backups;
• perform analytics and conduct customer research;
• communicate and provide to existing customers additional information that may be of interest to you about our products and services;
• manage our everyday business needs, such as auditing, administration of our CYLAN Services, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Service;
• enhance other information we have about you to help us better understand you and determine your interests; and
• in the context of a corporate transaction (e.g., corporate restructuring, sale or assignment of assets, merger) and to protect our rights or property, to enforce our Terms of Service and legal notices and for the establishment, exercise and defense of legal claims;
2.13 with your express consent to
• send you electronic communications in order to inform you about new products and services, unless you choose to unsubscribe;
• use certain non-essential cookies to better understand user behavior, in order to optimize user experience, perfect function design and offers for products and services from us or to provide better services;
2.14 meet a legal obligation, a court order or other binding decision(s); and
2.15 accomplish a purpose unrelated to those described in this Privacy Policy by first notifying you and, where required, offering you a choice as to whether or not we may use your Personal Information in this different manner.

3. Cookies and Other Technologies

We also use cookies, web beacons, pixel tags, and other technologies to keep records, store your preferences, improve our advertising, and collect information such as log data and device data. This allows us to better understand how you use our CYLAN Services and Products, diagnose and troubleshoot any problems your having, and otherwise administer and improve our CYLAN Services and Products. For more information about cookies, please refer to our Use of Cookies.
We may also engage one or more third party service providers to serve online advertisements on our behalf via CYLAN Services. They may use a pixel tag or other similar technology to collect information about your visits to sites, and they may use that information to target advertisements for our Products and CYLAN Services.

4. How We Share Your Information

CYLAN may disclose personal information to cloud service provider, network service provider and other service providers on the basis of non-disclosure agreements. The following are the limited situations where we may share personal information:
4.1 We share your personal information with CYLAN affiliates, who are required to use that information in accordance with the purposes described in this Privacy Policy.
4.2 We use service providers, vendors, technicians and other third-parties to help us process, store, and protect some of your data and otherwise help us administer our Products and CYLAN Services effectively, provide a better user experience, process your purchases, and increase the quality of our Products and CYLAN Services. These third-parties are forbidden from using your personal information for non-CYLAN purposes and are required to protect your information in accordance with this Privacy Policy and applicable laws.
4.3 We may provide information to third-parties if we believe in good faith that we are required by mandatory law to do so. For example, to comply with legal orders and government requests; response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts; to protect the interests of our customers and users of the CYLAN Service; to respond to claims that any content posted or displayed using the CYLAN Service violates the rights of third parties; in an emergency protect the health and safety of users of the CYLAN Service or the general public; or to enforce compliance with our Terms of Service.
4.4 If CYLAN and/or all or part of our assets are ever sold or transferred, your personal information may be among the items sold or transferred. Under such circumstance, we will notify you by the email address specified in your account or by means of notice on of (i) the identity and contact information of the purchaser or transferee, (ii) your right to revoke your consent to the provision of personal information, and (iii) the means by which you may revoke such consent.
4.5 We share information to protect our own legitimate business interests when we believe in good faith that we are required or permitted by law to do so. For example, we may share your personal information as needed to support auditing, compliance, and corporate governance functions; to combat fraud or criminal activity; to protect our rights or those of our affiliates and users; or as part of legal proceedings affecting CYLAN.
We may also disclose non-personal information (for example, aggregated or anonymized data) publicly or with third-parties, provided those data have been rendered anonymous in such a way that the data subject is no longer identifiable. For example, we may share non-personal information:
•for the same reasons we might share Personal information;
•to better understand how our customers interact with our CYLAN Services and Products, in order to optimize your experience, improve our products, or provide better services;
•for our own research and data analytics; or
•to our vendors for their own analysis and research.

5. Securing Your Personal Information

CYLAN has implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We also conduct periodic reviews and assessments of the effectiveness of our security controls.
Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, CYLAN cannot guarantee that your personal information is under absolute security with the existing security technology. If you have any questions about the security of our CYLAN Services, you can contact us by phone at +86-755-83185921 or email at

6. Accessing, Correcting and Retention Your Personal Information

CYLAN generally stores your personal information on CYLAN’s servers which is established upon Amazon Servers until you delete or edit it, or for as long as you remain a CYLAN customer in order to provide you with the most relevant offers.
Keeping your personal information current helps ensure that we provide you with the most relevant offers. You can access, update or delete your personal information via your Account profile. We are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile and data. Your personal information might not be immediately deleted, as we are required to retain records relating to previous purchases through our CYLAN Services for financial reporting and compliance reasons pursuant to applicable laws. In addition, because of the way we maintain certain services, after you delete certain information, we may temporarily retain backup copies of such information before it is permanently deleted.
We will retain your personal information for the period necessary to fulfill the purpose outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law.
If you are located in the European Union, subject to limitations in applicable law, you have certain rights in respect to your personal information, such as a right of access, rectification, restriction, opposition, and portability. In order to exercise your rights please contact us at the contact information below. You also have the right to withdraw your consent at all times, free of charge. You can do this by opting out from direct marketing and by rejecting the use of cookies through your browser settings. If you have concerns about how we handle your personal information, you have the right to lodge a complaint with the data protection authority in your country of residence.

7. Social Community Features and Social Networks

Social Community Features
Our CYLAN Services may allow you to publicly post or share information, communicate with others, or otherwise make information accessible to others. Prior to doing so, please read our Terms of Service carefully. All the information you post, share, or communicate may be accessible to anyone with Internet access, and any personal information you include may be read, collected, and used by others.
Social Networks
You have the option to link social networks, such as Facebook, to your Account. You will be able to post CYLAN activity to your social network. By proceeding through any of the above steps, you grant CYLAN permission to access elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Policy.
Links to other websites
We may permit others to link to the CYLAN services or to post a link to their website. We do not endorse these websites and are not responsible for other websites or their privacy practices. Please read their privacy policies before submitting information.

8. Your Choices

We think that you benefit from a more personalized experience when we know more about you and your preferences. However, you can limit the information you provide to CYLAN as well as the communications you receive from CYLAN through your Account preferences.

Commercial E-mails

You will only receive commercial e-mails from us if you have granted prior express consent or if sending those e-mails is otherwise permitted, in accordance with applicable laws.
You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send or by logging into your Account and adjusting your e-mailsreferences. Please note that even if you unsubscribe from commercial email messages, we may still e-mail you non-commercial e-mails related to your Account and your transactions on the CYLAN Services.

Device Data

You may manage how your mobile device and mobile browser share certain device data with CYLAN by adjusting the privacy and security settings on your mobile device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

9. Children’s Privacy

CYLAN does not intend that any portion of its CYLAN Services will be accessed or used by children under the age of 18, or equivalent minimum age in the relevant jurisdiction and such use is prohibited. Our CYLAN Services are designed and intended for adults. By using the CYLAN Services, you represent that you are at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction and understand that you must be at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction in order to create an account and purchase the goods or services advertised through our CYLAN Services. If we obtain actual knowledge that an account is associated with a registered user who is under the age of 18 years old, or equivalent minimum age in the relevant jurisdiction, we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us please contact us by phone at +86-755-83185921 or email parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction may review and request deletion of such child’s personal information as well as prohibit the use thereof.

10. Global Operations

We transfer and process your information globally both in our own facilities and with service providers, or partners, regardless of where you use our Services. The laws, regulations, and standards of the country in which your information is stored or processed may be different from those of your own country. In the European Union (EU), we will store and keep Your Content inside the EU in encrypted form including when we utilize a third party for storage. In exceptional circumstances CYLAN in the US and China may have access to this content in order to provide product support services. Your registration data will be collected and used or stored by CYLAN, currently in the U.S., Singapore, Brazil and Ireland. CYLAN put in place contractual protections, approved by the European Commission, to secure your information. A copy of those contracts can be obtained by contacting us at the address below.

11. Contact Us

Please contact us if you have any questions or comments about our privacy practices or this Privacy Policy. You can always reach us by phone at +86-755-83185921 or email at Please provide: (i) your name (or nickname) and preferred method of contact; and (ii) the details of your request or comment along with any corresponding website links.
Copyright@2018 Shenzhen CYLAN Technology Co., Ltd. ALL RIGHTS RESERVED.