1. Introduction

We, (hereinafter referred to as “Smartlink”, “we”, “us”, or “our”), believe your privacy is very important.

To fulfill our commitment to respecting and protecting your privacy, we will adhere to our basic principles as explained in detail below, and crafted this Privacy Policy in accordance with these basic principles:

  1. We will inform you of any collection of your personal information, and seek your consent to collect, use or disclose your personal information.
  2. We will identify the purposes of use for collecting your personal information.
  3. We will only collect information that is necessary to carry out the identified purposes of use.
  4. We will use or disclose your personal information only for the purposes for which it is collected, except with your consent or as required or permitted by law, and we will only keep your information necessary to fulfill those purposes.
  5. We endeavor to make sure that your personal information is accurate, complete, and up-to-date.
  6. We will protect your personal information through appropriate security measures.
  7. We will make our policies and practices for the handling of your personal information as transparent as possible.
  8. You will have access to your personal information and will be able to correct your personal information as appropriate.
  9. We will be accountable to you. We are always interested in hearing your opinion regarding our compliance with these principles, this Privacy Policy and applicable law.

2. Scope of This Privacy Policy

a. Purpose of This Privacy Policy

This Privacy Policy explains how Smartlink will process and safeguard your personal information, and the rights and choices you have with respect to your personal information. This Privacy Policy applies to: personal information you provide us when you use the Smartlink App; personal information we collect when you visit websites maintained by us relating to our Apps (hereinafter referred to as “Websites”; Apps and Websites are collectively referred to as “Services”); and personal information about you provided by other users of the Service.

b. What Privacy Policy Applies to Other Smartlink Services?

Certain users may utilize the Backstage Management System Service to perform user accounts’ authorization, deletion and management for the lock, such service is identical to the App, thus the same Privacy Policy Applies.

3. Types of Personal Information We Collect

a. What Personal Information Does Smartlink Collect?

To provide you the Service, Smartlink collects and uses the following types of information:

i. Information Concerning Your Account

When you register with us and create an account to use the Smartlink Application, Smartlink will ask you to provide your e-mail address. This information is necessary as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of or abuse of the Service. We may use your registered e-mail address to provide you with important information regarding the Service. For example, if you forget your login password the system will send the new password to your registered e-mail address.

When you register or log in, we will use your device’s camera to build your facial recognition and use its biometric database (fingerprint, iris, face, etc). These are indispensable information to increase the App’s security. Beware, the facial recognition and biometric database will only be retrieved and used on the device end, we will not upload or collect such database.

ii. Device information and access logs when you use our Service

When you use the Service or the Backstage Management System, we may obtain and maintain certain electronic identification or log data from your mobile device such as: OS type, IP address, browser information including type and language settings, device identifier or mobile application identifier.

This information is necessary as part of our ongoing efforts to detect and deter unauthorized or fraudulent use of or abuse of the Service, as well as to provide you and optimize the Service for your environment.

iii. Location function (for Android OS)

If you are using an a device with Android 6.0 or higher, when adding/deleting a lock or when unlocking the lock(hereinafter referred to as “connecting with the lock”), the system will ask you to enable the location function; do not worry, Smartlink will not track your location. This is due to Google modifying permission usage after Android OS 6.0. Therefore, location tracking must be allowed when you connect with the lock, during this period the location function may track your location without previously asking for your permission. However, Smartlink will not track or record your location information.

b. What other information might be collected?

To improve your experience when using the Service, we provide additional functionalities to help you enjoy the Service more. If you choose to use such functionalities, we may ask you to provide following types of information:

i. Contact information for customer support [OPTIONAL]

There may be occasions where you wish to contact us to seek customer support service. If you contact us via our Contact Form or by other means, we may obtain and maintain any information you choose to provide, including your name or contact information of any kind such as your email address. We will use this information to address and investigate the issues you have forwarded to us, to provide you support, and to improve our customer support service.

4. How we use and handle your information

a. How is my information being used?

To provide the Service, as a data controller or joint data controller, we will use your information for the following purposes:

• to verify your identity;

• to detect and deter unauthorized or fraudulent use of or abuse of the Service;

• to improve and/or optimize the Service;

• to enable us to provide customer support, and to respond effectively to your inquiries and claims;

• to conduct user satisfaction surveys;

• to provide you with information regarding the Service;

• to notify users of any other important information regarding the Service, if necessary; and

• to comply with applicable laws or legal obligations.

If, however, we provide you with more specific purpose(s) of use either at the time we ask you to provide your personal information or through another means, then such notice will take precedence over the general purposes of use stated in Section 4 of this Privacy Policy.

b. How is my information protected?

To fulfill our commitment to respecting and protecting your privacy and the confidentiality of your information, we have implemented industry-standard safeguards to prevent unauthorized access or disclosure, misuse, alternation, or destruction of your information.

Because no method of electronic transmission or method of data storage is perfect or impenetrable, we cannot guarantee that your information will be absolutely safe from intrusion during transmission or while stored in our systems.

To help protect your privacy and confidentiality of your information, we also need to ask for your cooperation regarding the following: Please do not share your password with others or use the same passwords you use for other services. Also, please notify us in the event you suspect any unauthorized use of your account or any other breach of security via our Contact Form.

c. Where Is My Personal Information Transmitted and Stored?

The information collected by Smartlink will be stored in your device or in our server. To provide Services in a reliable and responsible manner, Smartlink processes and stores your information on secure servers. All such transfers are performed in accordance with the requirements of applicable law.

d. How Long Does Smartlink Keep My Information?

Smartlink retains the personal information you provide while:

• your Account is active;

• for the length of time needed to fulfill any of the applicable purposes of use Described in this Privacy Policy; or

• to comply with applicable laws and regulations.

When you log out or the App is removed from your device, your Facial recognition database will be erased.

We may retain your personal information following the closure or termination of your Account if retention is reasonably necessary:

• to comply with applicable laws, regulations or legal obligations;

• to provide and complete customer support service;

• to resolve disputes between or with Smartlink users, for the duration of the applicable limitation period; or

• to detect and deter unauthorized or fraudulent use of, or abuse of, Services.

e. Does Smartlink use outside service providers or agents?

To facilitate and provide you with the Service, sometimes it is necessary for Smartlink to request third party partner service providers or agents to help us process and/or store your personal information. We strictly evaluate the partner service providers and agents, and we make every effort to ensure that they have established appropriate and secure information administration and organizational control systems, and we strictly require that they comply with applicable laws and regulations. We also require that they access your personal information only the extent necessary to perform tasks on our behalf.

f. Does Smartlink Give My Information to Third Parties?

Other than as described in this Privacy Policy and other applicable privacy policies or addendums, Smartlink will not provide your information to any third parties without your consent, unless we believe in good faith that we are required or permitted to do so under applicable laws.

g. Cookies (only for Backstage Management System)

A cookie is a small text file that is stored on your computer when visiting a website. This text file stores information that can be read by the website when visiting it again at a later date. Other cookies are convenient for the visitor: they remember your username in a secure way as well as your language preferences, for example. Cookies mean that you do not need to fill out the same information each time you visit a website.

5. Your rights

It is possible that Smartlink obtains personal information relating to individuals who are currently not users of the Service. Please note that, regardless of whether or not you are a user of the Service, you have the choices and rights under this section if we hold your personal information.

a. How do I control my information?

Smartlink has tried to make it as easy as possible for you to have control over your personal information. You can confirm and revise most of your personal information directly within the Smartlink Application or the Backstage Management System at any time. For example:

• In the App, the following can be modified within the Settings menu:

– modify your user name and profile picture;

– modify your Facial recognition database or disable such function;

– disable biometric identification function; or

– select Log out to delete your Facial recognition database from your device.

• In the Backstage Management System, select “My account” to modify your user name and profile picture.

If you no longer wish to use the Service or if you no longer wish to consent to Smartlink collection and use of your personal information, you may choose to delete Smartlink. We will take reasonable measures to delete your information in accordance with Section 4.d.

b. What If I Change My Mind?

If you change your mind regarding how much information you wish to continue to share or disclose on Services going forward, you can always change the settings in the Smartlink App relating to, for example:

• whether you want to use your biometric database to open the lock;

• whether you want to use fingerprint identification to open the lock;

• modify your user name and profile picture;

• log out and delete all Facial recognition database; or

• delete the Smartlink App. We will delete your personal information base on section 4.d.

6. Other Important Information for You

a. I have Questions/Comments/Concerns

If you have any questions, comments, or concerns about this Privacy Policy or our other privacy policies or practices, please contact us via the APP’s “Feedback” option.

b. Changes to This Privacy Policy

We may modify our Privacy Policy from time to time for various reasons including to improve our privacy practices, to reflect changes to our Service, and to comply with relevant law. This Privacy Policy was first released on 14th of December, 2017.

When we make any major changes to our Privacy Policy, we will provide notice to you on our Service, or by other reasonable means. We encourage you to review changes carefully. If you agree to the changes, then please continue to use our Service. If you, however, do not agree to any of the changes and you no longer wish to use our Service, you may choose to delete Smartlink. Continuing to use our Service after a notice of changes has been communicated to you or published on our Service constitutes your acceptance of changes and consent to the modified Privacy Policy.

The following terms and conditions of use (hereinafter referred to as the “Terms and Conditions”) set forth the terms between I-TEK Metal Manufacturing Co., Ltd. (hereinafter referred to as the “Company”) and the User (hereinafter referred to as the “User” or “Users”) of any services or features of Smartlink (hereinafter referred to as the “Service”), which is provided by the Company.

1. Definitions

The following words and terms shall have the meanings set forth below when they are used in the Terms and Conditions.

1.1. “Content(s)” refers to information such as text, audio files, music, images, videos, software, programs, computer codes, facial recognition or other information of any kind.

1.2. “Separate Terms and Conditions” means documents released or uploaded by the Company that pertain to the Service, under the title “agreement”, “guideline”, “policy”, etc.

2. Agreement to Terms and Conditions

2.1. All Users shall use the Service in accordance with the terms stated in the Terms and Conditions. Users may not use the Service unless they agree to the Terms and Conditions. Such agreement is valid and irrevocable.

2.2. Minors may use the Service only with consent from their parents or legal guardian. Furthermore, if the Users use the Service on behalf of, or for the purposes of a business enterprise, then that business enterprise shall also be deemed to have agreed to the Terms and Conditions. Such agreement is valid and irrevocable.

2.3. By using the Service, Users are deemed to have agreed to the Terms and Conditions. Such agreement is valid and irrevocable.

2.4. There are Separate Terms and Conditions for the Service; Users shall also comply with such Separate Terms and Conditions as well as the Terms and Conditions.

3. Modification of the Terms and Conditions

The Company may modify the Terms and Conditions or Separate Terms and Conditions when the Company deems necessary, without providing prior notice to the Users. The modification will become effective once the modified Terms and Conditions or Separate Terms and Conditions are posted on an appropriate location within the website operated by the Company. Users shall be deemed to have granted valid and irrevocable consent to the modified Terms and Conditions or Separate Terms and Conditions by continuing to use the Service. Users shall refer to the Terms and Conditions on a regular basis when using the Service, since a separate notification regarding the modification to Terms and Conditions may not be provided.

4. Account

4.1. Users, when providing information about him/herself to the Company, shall provide genuine, accurate, and complete information while using the Service, and keep such information up-to-date at all times.

4.2. If User registers a password while using the Service, he/she shall exercise due care and responsibility in order for the password not to be used in an unlawful manner. The Company may treat all activities conducted with the password as activities that have been conducted by the holder of the password him/herself.

4.3. Users having registered to the Service can modify the account password, unlocking passcode, face profile and account name within the settings from the Smartlink App. Make sure the registered email address is correct and valid as once registered it cannot be changed or deleted.


5. Backstage Management System

5.1. Users that have the Backstage Management System service can use its web portal to access such system.

5.2. The Backstage Management System service not only provides the management and authorization functions from the Smartlink App, a “Management Delegation” function is also available, which allows other premium Users to be delegated with management and authorization functions.

5.3. The use of the Backstage Management System must follow the same regulations and policies as the Service.

5.4. Personal users, companies, organizations may be charged for maintaining database management system in the future.

6. Privacy

6.1. The Company places its highest priority on the privacy of its Users.

6.2. The Company promises to protect the privacy and personal information of its Users in accordance with the Smartlink Privacy Policy.

6.3. The Company promises to exercise the utmost care and attention regarding its security measures for the continued security of any and all User information.

6.4. Company will not share any users’ personal information to any third party for any reason.

7. Provision of the Service

7.1. Users shall supply the mobile phone device, communication device and data connection necessary for using the Service under the Users’ own responsibility and at the Users’ own expense.

7.2. The Company reserves the right to modify or cease, at the Company’s own discretion, the whole or part of the Service at any time without any prior notice to the Users.

7.3. Users’ rights to use the Service shall expire when the Service has been deleted for any reason.

8. Business Partners’ Services

Contents or other services offered by other business partners cooperating with the Company may be included within the Service. The business partners bear all responsibility regarding such contents and/or services offered. Furthermore, such contents and services may be governed by the explicit terms and conditions etc., which are set accordingly by the business partners.

9. Content

9.1. The Company grants Users the non-transferable, non-re-licensable, non-exclusive license to use the contents provided by the Company, only for the purpose of using the Service.

9.2. Users shall not use the contents beyond the scope of the intended use of the contents in the Service (including but not limited to copying, transmission, reproduction, modification).

10. Restrictions (Refer to section 14)

Users shall not engage in the following when using the Service.

10.1. Activities that violate the law, court verdicts, resolutions or orders, or administrative measures that are legally binding.

10.2. Activities that infringe intellectual property rights, such as copyrights, trademarks and patents, fame, privacy, and all other rights of the Company and/or a third party granted by the law or contract.

10.3. Activities that interfere with the servers and/or network systems of the Service; that abuse the Service by means of BOTs, cheat tools, or other technical measures; that deliberately use defects of the Service; that make unreasonable inquires and/or undue claims such as repeatedly asking the same question beyond the necessity, and that interfere with the Company’s operation of the Service or Users’ use of the Service.

10.4. Activities that aid or encourage any activity stated in clauses 1 to 3 above.

10.5. Other activities that are deemed by the Company to be inappropriate.

11. User Responsibility

11.1. Users shall use this Service at his/her own risk, and shall bear all responsibility for actions carried out and their results upon this Service.

11.2. The Company may take measures that the Company considers necessary and appropriate, if the Company acknowledges that a User is using the service in a way which violates the Terms and Conditions. However, the Company shall not be responsible for correcting or preventing such violation towards Users or others.

11.3. In the case where the Company has suffered loss/damage or has been charged an expense (including but not limited to lawyer’s fees) directly or indirectly (including but not limited to cases where the Company has been sued for damages by a third party) due to the User violating applicable laws or the Terms and Conditions while using the Service, the User shall immediately compensate the Company upon its request.


12. The Company’s Exemption of Liability

12.1. The Company does not expressly or impliedly guarantee that the Service (including the contents) are free from de facto or legal flaws (including but not limited to stability, reliability, accuracy, integrity, effectiveness, fitness for certain purposes, security-related faults, errors, bugs, or infringements of rights). The Company shall not be responsible for providing the Service without such defects.

12.2. The Company shall not be responsible for any damages inflicted upon Users in relation to the use of the Service. However, if the agreement (including but not limited to the Terms and Conditions) between the Company and Users regarding the Service shall be deemed as a consumer contract under the Consumer Protection Act in the Republic of China, then this exemption clause shall not be applied.

12.3. Notwithstanding the condition stated in clause 12.2 above, the Company shall not be responsible for any indirect, special, incidental, consequential or punitive damages (including but not limited to such damages that the Company or Users predicted or could have predicted) with respect to the Company’s contractual default or act of tort due to the Company’s negligence (except for gross negligence). The compensation for ordinary damages in respect to the Company’s contractual default or act of tort due to the Company’s negligence (except for gross negligence) shall be limited to the total amount of received fees from the User in the particular calendar month in which such damages occurred.


13. Notification and Contact

13.1. When the Company notifies or contacts Users regarding the Service, the Company may use a method that the Company considers appropriate, such as posting on the website operated by the Company.

13.2. When Users notifies or contacts the Company in regard to the Service, Users shall use the user feedback form available on the APP’s “Feedback” option.

14. Governing Law and Jurisdiction

Where the Company has provided Users with a translation of the Traditional Chinese language version of the Terms and Conditions, the traditional version will govern the relationship between Users and the Company. These Terms and Conditions traditional Chinese language version will be governed by the laws of the Republic of China. Conflicts that arise from the Service or conflicts between Users and the Company related to the Service will be governed primarily under the exclusive jurisdiction of the District Court of Tainan.

Dated: December 14th, 2017.