Latest Date: November 10, 2023
Effective Date: February 8, 2023
This Privacy Policy explains how Colorlight Cloud Tech Ltd (with its registered office at Room 3801, Building 8, Zone A, Vanke Cloud City, Xili Community, Xili Street, Nanshan District, Shenzhen, China (Room 37F-39F), hereinafter referred to as "Colorlight", "we ") how we collect, use, share, disclose, protect and safeguard your Personal Data through the LED Assistant Mobile Software (hereinafter referred to as the Software). Please read and fully understand our Privacy Policy and data handling rules before using our software services or providing your Personal Data. If you choose to continue using the LED Assistant Mobile Software, you are deemed to agree to this Privacy Policy and accept our collection and use of your Personal Data in accordance with this Policy, and if you do not agree to any of the terms in this Policy, you should immediately stop accessing and using the LED Assistant Mobile Software.
We want you to be aware of the following through this Privacy Policy.：
We use the following definitions in this Privacy Policy:
means the mobile application known as the "Led Assistant App" consisting of the Colorlight software, and which is available for download from selected App stores.
means Colorlight Cloud Tech Ltd, and its affiliates.
means any data which relates to a living individual who can be identified from that data or from that data and other data which is in the possession of, or is likely to come into the possession of, Colorlight (or its representatives or service providers). In addition to factual data, it includes any expression of opinion about an individual and any indication of the intentions of Colorlight or any other person in respect of an individual. If the definition of "Personal Data" under local law includes other data in addition to the aforesaid, this definition also includes such additional scope of data.
means this Privacy Policy.
(A)The types of Personal Data we may process, for the purposes described below, include:
| Collected Types | Purposes |
| Login account, initial password, verification email | Reset password and login |
| Feedback and problem solvin | |
| Product software version, device IP, product configuration data. | Product Functionality |
| Data on mobile device parameters, such as phone brand, model. | Product Functionality |
| The IP address of the network when using the App. | Product Functionality |
| Location data (not precise positioning data) agreed to be provided when using the App. | Product Functionality |
| Shooting with mobile phone camera. | Product Functionality |
| Data on uploaded pictures and videos. | Product Functionality, Product Optimization |
| LED display screenshots | Product Functionality |
(B)In addition to the data described above, we may obtain data from other sources, including the Personal Data provided to us by third-party service providers, agencies or other publicly available sources where applicable.
(C) In order to ensure the use of the core features of the Software, you are required to open the following privacy permissions in the course of using the Software:
We will not obtain or disclose your Personal Data through your opening of the above permissions. You can also choose to close the above permissions in the setting function of your device, but it may affect the use of the core functions of the software and cannot achieve the expected effect of the relevant services.
We process your Personal Data in the following ways and use it for the following purposes:
(A)performing old account logins for the software.
(B)processing data about hardware products, cell phone mobile devices, uploaded data, etc. for the purpose of implementing the software's remote data delivery function.
(C)to understand your feedback on the use of the software, to provide more data to enable you to use the products and services quickly and easily, to communicate and deal with your questions about the use of the products and to listen to your suggestions for product improvement.
(D)when we use your Personal Data, we will strictly abide by the terms of this Privacy Policy and any updates thereto. Your Personal Data will only be used for the purposes identified at the time of collection.
(E)when we wish to use data for purposes other than those covered by this Privacy Policy, we will notify you and ensure that we comply with the relevant legal requirements.
We ensure that our usage of the Personal Data we collect from you complies with the applicable law. However, we may use your Personal Data as permitted by law for a number of reasons. These include without limitation:
We will take steps to ensure that Personal Data is only accessible by our employees and that those employees need to have access in accordance with the purposes described in this Privacy Policy.
We will not view the content of your videos, photos that are stored in the App cache.
You understand and agree that we may technically de-identify your Personal Data and that the de-identified data will not identify you. In this case, we may use the de-identified data to analyze and exploit it, subject to the relevant laws and regulations and regulatory policies.
We will not transfer your Personal Data to third parties except as specified below, or where you consent to such transfer.
Only where necessary will we share your information with selected recipients, including:
(A)with third party agents and contractors for the purposes of providing services to us (for example, Colorlight's accountants, professional advisors, lT and communications providers and debt collectors). These third parties will be subject to appropriate data protection obligations and they will only use your Personal Data as described in this Privacy Policy;
(B)to the extent required by law, for example if we are under a duty to disclose your Personal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights;
(C)if we sell our business or assets, in which case, we may need to disclose your Personal Data to prospective buyer for due diligence purposes;
(D)if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party.
We have extensive controls in place to maintain the security of our data and data systems. Client files are protected with safeguards according to the sensitivity of the relevant data. Appropriate controls (such as restricted access) are placed on our computer systems.
Physical access to areas where Personal Data is gathered, processed or stored is limited authorised employees
As a condition of employment, Colorlight employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who need it to perform their roles. Unauthorised use or disclosure of confidential client data by a Colorlight employee is prohibited and may result in disciplinary measures.
When you contact a Colorlight employee about your file, you may be asked for some Personal Data. This type of safeguard is designed to ensure that only you, or someone authorised by you, has access to your file.
How long we will hold your Personal Data for will vary and will be determined by the following cumulative criteria:
(A)the purpose for which we are using it - Colorlight will need to keep your Personal Data for the period which is necessary for that purpose; and
(B)legal obligations - laws or regulation may set a minimum period for which Colorlight has to keep your Personal Data.
We determine the storage period of Personal Data by referring to the following criteria and whichever is longer.
After a reasonable storage period, we will delete or anonymize your Personal Data as required by applicable laws and regulations.
Where the applicable law requires so, in the cases where we collect, use or store your Personal Data, you may have the following rights, and, in most cases, you can exercise them free of charge.
These rights include:
(A)the right to obtain data regarding the processing of your Personal Data and access to the Personal Data which we hold about you;
(B)the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. If you have a relevant request to withdraw your consent, you can contact us directly at support.colorlightcloud@lednets.com. we will process your request as soon as possible after receiving the e-mail;
(C)in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Colorlight;
(D)the right to request that we rectify your Personal Data if it is inaccurate or incomplete;
(E)the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it;
(F)the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and
(G)the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
You can exercise your rights by submitting a request to support.colorlightcloud@lednets.com. In principle, we will not charge any fees for your reasonable requests. However, for multiple and repeated requests that exceed reasonable limits, we may charge a reasonable fee to cover damages, depending on the nature of your request. We may deny requests that are clearly unfounded, unreasonably repetitive, or require disproportionate technical effort (e.g., the need to develop new systems). In addition, we may not respond to requests that directly involve issues of significant public interest or that could cause serious harm to your or other individuals' or entities' legitimate interests.
If we deny a request by an individual to exercise his or her rights, you may file a lawsuit with the people's court in our location in accordance with the law.
The Software is primarily intended for adults. If you are a minor under the age of 18, we ask you to have your parents or other guardians to read this Policy carefully before using our Services or provide us with information with the consent of your parents or other guardians. We respect and protect the Personal Data of minors (especially children under the age of 14), and we will only process Personal Data of minors as permitted by law, with the express consent of a parent or guardian, or as necessary to protect the minor.
If we discover that we have collected Personal Data from a minor without prior verifiable parental or guardian consent, we will attempt to delete it completely as soon as possible.
The Personal Data we collect and process in the People's Republic of China and the Personal Data of natural persons in the People's Republic of China are kept in the People's Republic of China, and we will not transfer your Personal Data to other countries or regions outside of China.
We reserve the right to revise this Privacy Policy from time to time. We will update the revised version along with the "Latest Date" at the top of the revised Privacy Policy. If there are changes to this Privacy Policy regarding the purpose, manner, or type of Personal Data collected, the period of time for which Personal Data is stored, or the manner or process by which you may exercise your rights as an individual, we will notify you by push notification, pop-up window, or other means, as appropriate, so that you are aware of the changes to this Privacy Policy.
If you find that the Personal Data protection work of our LED Assistant Mobile Software may cause the risk of data leakage, you can contact us directly at support.colorlightcloud@lednets.com. We will actively identify the risk and take effective measures according to your suggestions.
In the event of or possible leakage, destruction or loss of Personal Data, we will take remedial measures, promptly inform you of the data leakage and report to the competent authorities.
The user rights and data security measures specified in the LED Assistant Mobile Software User Agreement are applicable to LED Assistant Mobile Software users. If there is any inconsistency or contradiction between the User Agreement and this Policy, please refer to this Policy.
The copyright of this Policy is owned by Colorlight Cloud Tech Ltd.
If you have any questions or complaints regarding this Privacy Policy or your Personal Data by Colorlight, please contact us via email at support.colorlightcloud@lednets.com.