About
this privacy policy
This Privacy Policy
explains how kipyego collects, uses, discloses, processes and protects any
personal information that you give us or that we collect from you. Should we
ask you to provide certain information by which you can be identified when you
use the services on our platform, it will only be used in accordance with this
Privacy Policy and/or our terms and conditions for users. Under this Privacy
Policy, “personal information” means information that can be used to directly
or indirectly identify an individual, either from that information alone or
from that information combined with other information kipyego has access to
about that individual, except as otherwise specifically provided by applicable
laws in your region. We will use your personal information strictly in
accordance with this Privacy Policy.
How we
can help you
Ultimately, what we want is
the best for all our users. Should you have any questions with our data
handling practices as summarized in this Privacy Policy, please contact us
at https://privacy.mi.com/support to address
your specific concerns. We will be happy to hear from you. If you have an
unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request .
1 What
information is collected by us and how do we use it?
1.1 What
information is collected by us
In order to provide our
services to you, we will ask you to provide personal information that is
necessary to provide those services to you. We will only collect the
information that is necessary for its specified, concrete, explicit and
legitimate purposes and not further processed in a manner that is incompatible
with those purposes. You have the right to choose whether or not to provide the
information we have requested, but in most cases, if you do not provide your
personal information, we may not be able to provide you with our services or
respond to your queries. Depending on the service you choose, we may collect
the following types of information:
1.1.1 Information you provide to us
We may collect any personal
information you provide to us, which is necessary for the service you choose.
For example, you may provide your Mi Account information when you log in; you
may provide us your email address if you wish to receive news or updates from
us.
1.1.2 Information that we collect in your use of
services
We may collect log
information related to your use, such as cookies, IP addresses. Log information
is information related to your use of certain features of the websites.
For example, cookies and IP addresses, network request information, standard
system logs, crash information, log information generated by using the services
(such as access time, activity time, etc.). We use such information in
aggregated form to improve your experience while using our apps and websites.
We collect information such
as information about your activities on our websites. We use such information
in aggregated form to provide you with more useful information and to
understand which parts of our websites, products and services you are most interested
in. In its aggregated form, data is not personal information and cannot be used
to identify you. However, if we combine non-personal information with personal
information, such information will be treated as personal information.
1.1.3 Non-personally identifiable information
We may also collect other
types of information which are not directly or indirectly linked to an
individual and which may not be defined as personal information according to
applicable local laws. Such information may include statistical data generated
when you use a specific service (e.g. user clicks, browsing behaviors, page
access events). The purpose for such collecting is to improve the services we
provide to you. The type and amount of information collected depends on how you
use our services.
In its aggregated form,
such data is not personal information as it cannot be used to identify you.
However, if we combine non-personal information with personal information, such
information will be treated as personal information.
1.2 How
we use the personal information that we collect
The purpose of collecting
personal information is to provide you with services, and to ensure that we
comply with applicable laws, regulations and other regulatory requirements.
This involves:
• Providing,
processing, maintaining, improving and developing our services to you.
• Handling your questions
or requests about our services, such as sending notifications.
• Conducting relevant
promotional activities, such as providing marketing and promotional
materials and updates. If you no longer wish to receive certain types of
promotional materials, you may opt-out by the method provided in the message
(such as the unsubscribe link at the bottom of the message) unless otherwise
specified under applicable laws. Please also see “Your rights” below.
• Internal purposes such
as data analysis, research, and development of statistical information related
to the use of our services for improvement.
• Storing and
maintaining information related to you for our business operations (such
as business statistics) or for fulfilling our legal obligations.
• Other purposes
with your consent.
We may combine this
information with other information (including information across different
services or devices such as computers, mobile phones and other connected
devices) to provide and improve our services and content. For example, we may
use your Mi Account details in all services you use that require a Mi Account.
2
Cookies and other technologies
Technologies such as
cookies, tags, and scripts are used by kipyego and our third party service
providers and business partners (for more information see “How we
share, transfer, and publicly disclose your personal information” below).
These technologies are used in analyzing trends, administering the site,
tracking users’ movements around the website and to gather demographic
information about our user base as a whole. We may receive reports based on the
use of these technologies by these companies on an individual as well as
aggregated basis. These technologies help us better understand users’ behavior,
tell us which parts of our websites people have visited, as well as facilitate
and measure the effectiveness of web searches. We treat information collected
by cookies and other technologies as non‑personal information, except where
Internet Protocol (IP) addresses or similar identifiers are considered personal
information by local laws.
• Log files: As
true of most websites, we gather certain information and store it in log files.
This information may include Internet Protocol (IP) addresses, browser type,
Internet service provider (ISP), referring/exit pages, operating system,
date/time stamp, and/or clickstream data. We do not link this automatically
collected data to other information we gather about you.
• Local storage –
HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or
Flash to store content and preferences. Third parties with whom we partner to
provide certain features on our sites also use HTML5 or Flash cookies to
collect and store information. Various browsers may offer their own management
tool for removing HTML5 LSOs. To manage flash cookies, please click here: .
3 How we
share, transfer, and publicly disclose your personal information
3.1
Sharing
We do not sell any personal
information to third parties.
We may sometimes share your personal information with third parties (as
described below) in order to provide or improve our services, including
offering services based on your requirements. If you no longer wish to allow us
sharing this information, please contact us at https://privacy.mi.com/support.
3.1.1 Sharing that you actively choose or request
With your explicit consent
or at your request, we will share your personal information within the scope of
your consent/request with specific third parties designated by you.
3.1.2 Sharing information with our group
In order to successfully
conduct business operations and to provide you with all the functions of our
services, we may share your personal information from time to time to other kipyego
affiliates.
3.1.3 Sharing with our group’s ecosystem companies
Kipyego works together with
a group of companies forming the Mi Ecosystem. The Mi Ecosystem companies are
independent entities, invested and incubated by kipyego, and are experts in
their fields. kipyego may disclose your personal information to the Mi
Ecosystem companies to provide you with and improve the existing products and
services (both hardware and software) from the Mi Ecosystem companies. Some of
these products or services will still be under the kipyego brand, while others
may use their own brand. The Mi Ecosystem companies may share information with kipyego
from time to time in relation to products or services under the kipyego brand
with kipyego to provide hardware and software services, bringing better
features and user experience. kipyego will take appropriate management and
technical measures to ensure the security of your personal information
processing, including but not limited to the encryption of your personal
information.
3.1.4 Sharing with third party service providers
and business partners
To help us provide you with
services described in this Privacy Policy, we may, where necessary, share your
personal information with our third-party service providers and business
partners. This
includes our data centers, data storage facilities and other business partners.
These third parties may process your personal information on kipyego behalf or
for one or more of the purposes of this Privacy Policy. We guarantee
that the sharing of personal information necessary for providing services to
you is solely for legitimate, legal, necessary, specific, and explicit
purposes. Kipyego will conduct due diligence and have contracts in
place to ensure that third-party service providers comply with the applicable
privacy laws in your jurisdiction. There may be occasions that third-party
service providers have their sub-processors.
To provide performance
measurement, analysis, and other business services, we may also share
information (non-personal information) with third parties in aggregated form.
We use the information we have to help our business partners evaluate the
effectiveness and coverage of their services, and understand the types of
people who use their services and how people interact with their websites,
apps, and services. We may also share general usage trends of our services with
them, such as the number of customers in a particular group of people who
purchase certain products or engage in certain transactions.
3.1.5 Other
In accordance with legal
requirements, legal procedures, litigation and/or requests from public agencies
and government agencies, Kipyego may need to disclose your personal
information. If the disclosure is necessary or appropriate for national
security, law enforcement, or other matters of public importance, we may also
disclose information about you.
In order to enforce our
terms or protect our business, rights, assets or services, or to protect users,
or if the disclosure is reasonably necessary for the following purposes
(detecting, preventing and resolving fraud, unauthorized use of the service, violations
of our terms or policies, or other harmful or illegal activities), we may also
disclose information about you. (There may be occasions when Kipyego may
collect, use or disclose your personal information without your consent if it
is and only to the extent it is permitted under applicable data protection
laws). This may include providing your personal information to public or
government agencies; communicating with third-party partners about the
reliability of your account to prevent fraud, violations, and other harmful
behaviors.
In addition, we may share
your personal information with:
• our accountants,
auditors, lawyers, or similar advisers when we ask them to provide us with
professional advice; and
• investors and other
relevant third parties in the event of an actual or potential sale or other
corporate transaction related to an entity in the Xiaomi Group; and
• any other third parties,
if authorized by you to do so in relation to a specific disclosure.
3.2
Transfer
kipyego will not transfer
your information to any subject except in the following cases:
• Where we have obtained
your explicit consent;
• If kipyego is involved in
the merger, acquisition, or sale of all or part of its assets, we will notify
you of any changes in the ownership, use, and any choice of your personal
information you possibly possess by email and/or by posting a prominent notice
on our websites.
3.3
Public disclosure
Xiaomi will only publicly
disclose your personal information under the following circumstances:
• Where we have obtained
your explicit consent;
• Public disclosure based
on law or reasonable grounds: including laws and regulations, legal procedures,
litigation, or at the request of the competent government departments.
4 How we
store and protect your personal information
4.1 a security safeguards
We are committed to keeping
your personal information secure. In order to prevent unauthorized access,
disclosure or other similar risks, we have put in place all legally required
physical, electronic and managerial procedures to safeguard and secure the
information we collect from you. We will ensure that we safeguard your personal
information in accordance with applicable law.
For example, when you
access your Mi Account, you can choose to use our two-step verification program
for better security. When you send or receive data from your kipyego device to
our servers, we make sure they are encrypted using Transport Layer Security
(“TLS”) and other algorithms.
All your personal
information is stored on secure servers and protected in controlled facilities.
We classify your information based on importance and sensitivity and ensure
that your personal information has the required level of security. We have
special access controls for cloud-based data storage, and we regularly review
our information collection, storage and processing practices, including
physical security measures, to guard against any unauthorized access and use.
We conduct due diligence on
business partners and third party service providers to make sure that they are
able to protect your personal information. We also check that appropriate
security standards are maintained by these third parties by putting in place
appropriate contractual restrictions, and where necessary, carrying out audits
and assessments. In addition, our employees and those of our business partners
and third party service providers who access your personal information are
subject to enforceable contractual obligations of confidentiality.
We conduct security and
privacy protection training courses and tests to enhance our employees'
awareness of the importance of protecting personal information. We will take
all practicable and legally required steps to safeguard your personal
information. However, you should be aware that the use of the Internet is not
entirely secure, and for this reason we cannot guarantee the security or
integrity of any personal information when transferred from you or to you via
the Internet.
We handle personal data
breaches as required by applicable data protection law which includes, where
required, notifying the breach to the relevant data protection supervisory
authority and data subjects.
4.2 What
you can do
You can set a unique
password for kipyego by not disclosing your sign-in password or account
information to anybody (unless such person is duly authorized by you) to avoid
password leaks to other websites which may harm your account security at kipyego.
Whenever possible, please do not disclose the verification code you received to
anyone (including those who claim to be Xiaomi customer service). Whenever you
sign in as a Mi Account user on Xiaomi websites, particularly on somebody
else's computer or on public Internet terminals, you should always sign out at
the end of your session.
Xiaomi cannot be held
responsible for lapses in security caused by a third party accessing your
personal information as a result of your failure to keep your personal
information private. Notwithstanding the foregoing, you must notify us
immediately if there is any unauthorized use of your account by any other
Internet user or any other breach of security. Your assistance will help us
protect the privacy of your personal information.
4.3
Retention policy
We retain personal
information for the period necessary for the purpose of the information
collection described in this Privacy Policy, or as required by applicable laws.
We will cease to retain and delete or anonymize personal information once the
purpose of collection is fulfilled, or after we confirm your request for
erasure, or after we terminate the operation of the corresponding service. An
exception to this is personal information that we are processing for public
interest, scientific, historical research, or statistical purposes. Xiaomi will
continue to retain this type of information for longer than its standard
retention period, where permitted based on applicable laws or your request,
even if further data processing is not related to the original purpose of
collection.
5 Your
rights
Controlling your personal
information
5.1
Controlling settings
Xiaomi recognizes that
privacy concerns differ from person to person. Therefore, we provide examples
of ways Xiaomi makes available to you to restrict the collection, use,
disclosure or processing of your personal information and control your privacy
settings, such as sign in or out of the Mi Account.
If you have previously
agreed to us using your personal information for the aforementioned purposes,
you may change your mind at any time by contacting us at https://privacy.mi.com/support
5.2 Your
rights to your personal information
Depending on applicable
laws and regulations, you have the right to access, rectification, and erasure
of any other personal information that we hold about you (hereinafter referred
to as the request).
You may also access and
update the details relating to the personal information in your Mi Account
at https://account.xiaomi.com or by logging
into your account on your device. For additional information, please write to
us or contact us at https://privacy.mi.com/support.
This Privacy Policy
requires that your request satisfy applicable laws and regulations and the
following conditions:
(1) Through Xiaomi's
particular request submission channels listed below, and your request should be
in writing (unless the local law explicitly recognizes the oral request), for
the protection of your information security;
(2) Provide sufficient
information to enable Xiaomi to verify your identity and ensure that you are
the subject of the requested information or a personal legally authorized to
act on the subject’s behalf.
Once we obtain sufficient
information to confirm that your request can be processed, we shall proceed to
respond to your request within any timeframe set out under your applicable data
protection laws.
In detail:
• You have the right to be
provided with clear, transparent and easily understandable information about
how we use your personal information and your rights. This is why we are
providing you with the information in this Privacy Policy.
• Based on the requirements
of applicable laws, a copy of your personal data collected and processed by us
will be provided to you upon your request free of charge. For any extra
requests for relevant information, we may charge a reasonable fee based on actual
administrative costs according to the applicable laws.
• If any information we are
holding on you is incorrect or incomplete, you are entitled to have your
personal information corrected or completed.
• Based on the requirements
of applicable laws, you have the right to request the deletion or removal of
your personal information where there is no compelling reason for us to keep
using it. We shall consider the grounds regarding your erasure request and take
reasonable steps, including technical measures. If the right is upheld,
we may not be able to immediately remove the information from the backup system
due to applicable law and/or technology limitations. If this is the case, we
will securely store your personal information and isolate it from any further
processing until the backup can be cleared or be made anonymous.
• You have the right to
object to certain types of processing, and under certain circumstances where
the legal basis for processing is our legitimate interests.
Particularly under the laws
of some jurisdictions:
• You have the right to
obtain from us the restriction of processing your personal information. We
shall consider the grounds regarding your restriction request. If the grounds
apply to GDPR, we shall only process your personal information under applicable
circumstances in GDPR and inform you before the restriction of processing is
lifted.
• You have the right not to
be subject to a decision based solely on automated processing, which produces
legal effects concerning you or similarly significantly affects you.
• You have the right to
apply for your personal information in a structured, commonly used format and
transmit the information to another data controller.
We have the right to refuse
to process requests that are frivolous requests that damage others' right of
privacy, extremely unrealistic requests, requests that require disproportionate
technical work, and requests not required under local law, information that
have been made public, information given under confidential conditions. If we
believe that certain aspects of the request to delete or access the information
may result in our inability to legally use the information for the
aforementioned anti-fraud and security purposes, it may also be rejected.
5.3
Withdrawal of consent
You may withdraw your
consent previously provided to us for a particular purpose by submitting a
request, including collecting, using, and/or disclosing your personal
information in our possession or control. Based on the specific service you are
using, you can visit the Mi Account management center at https://account.xiaomi.com/pass/del or
contact us at https://privacy.mi.com/support. We will process
your request within a reasonable time from when the request was made, and
thereafter not collect, use and/or disclose your personal information as per
your request.
Depending on the extent of
your withdrawal of consent, please note that you may not be able to continue
receiving the full benefit of Xiaomi’s products and services. The withdrawal of
your consent or authorization will not affect the validity of our processing
carried out on the basis of the consent up until the point of withdrawal.
5.4
Cancelling a service or account
If you wish to cancel a
specific product or service, you can contact us at https://privacy.mi.com/support for
logout service.
If you wish to cancel the
Mi Account, please note that the cancellation will prevent you from using the
full range of Xiaomi products and services. Cancellation may be prevented or
delayed in certain circumstances.
6 How
your personal information is transferred globally
Xiaomi processes and backs
up personal information through a global operating and control infrastructure.
Currently, Xiaomi has data centers in the United States, Germany and Singapore.
For the purposes described in the Privacy Policy, your information may be
transferred to these data centers in accordance with applicable law.
We may also transfer your
personal information to third-party service providers and business partners and
your data may therefore also be transmitted to other countries or regions. The
jurisdiction in which these global facilities are located may or may not
protect personal information to the same standards as in your jurisdiction.
There are different risks under different data protection laws. However, this
does not change our commitment to comply with this Privacy Policy and to
protect your personal information.
If we need to transfer
personal information outside of your jurisdiction, whether to our affiliates or
third-party service providers, we will comply with related applicable laws. We
ensure that all such transfers meet the requirements of applicable local data
protection laws by implementing uniform safeguards. You can find out about the
safeguards that we have in place by contacting us at https://privacy.mi.com/support.
If you use our services in
the area of the European Economic Area (EEA), Xiaomi Technology Netherlands
B.V. will act as the data controller and Xiaomi Singapore Pte. Ltd. will be
responsible for the data processing. Contact details can be found in the "Contact
us" section.
If Xiaomi shares personal
data originating by you in the EEA to a Xiaomi Group entity or a third party
service provider outside the EEA, we will do so on the basis of EU standard
contractual clauses or any other safeguards provided for in the GDPR.
7
Protection of minors
We consider it the
responsibility of the parent or guardian to supervise the child's use of our
services. However, we do not offer services directly to a child or use personal
data of children for the purposes of marketing.
If you are a parent or
guardian and you believe that the minor has provided Xiaomi with personal
information, please contact us at https://privacy.mi.com/support to
ensure that the personal information is removed immediately and that the minor
is unsubscribed from any of the applicable Xiaomi services.
8 Do i
have to agree to any third party terms and conditions?
Our Privacy Policy does not
apply to products or services offered by a third party. Depending on the
service you use, it may incorporate a third parties’ products or services. Some
of these will be provided in the form of links to third parties’ websites. Your
information may also be collected when you use these services. For this reason,
we strongly suggest that you take the time to read the third party’s privacy
policy just like you read ours. We are not responsible for and cannot control
how third parties use personal information which they collect from you. Our
Privacy Policy does not apply to other sites linked from our services.
9 How we
update this privacy policy
We review the Privacy
Policy periodically based on changes in business and technology, and we may
update this Privacy Policy. If we make a material change to this Privacy
Policy, we will notify you via your registered contact information such as
email (sent to the email address specified in your account) or publish on
Xiaomi websites or notify you via mobile devices so that you can learn about
the information we collect and how we use it. Such changes to Privacy Policy
will apply from the effective date specified in the notice or website. We
encourage you to check this page regularly for the latest information on our
privacy practices. Your continued use of the services on the website, mobile
and/or any other device will be deemed acknowledgement of the updated Privacy
Policy. We will ask for your explicit consent when we collect additional
personal information from you or when we use or disclose your personal
information for new purposes.
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