Our Privacy Policy was updated on July 15, 2022.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

Shenzhen Livenpace Technology Co., Ltd. (hereinafter refer to as "Livenpace", "we", "our" or "us") take your privacy very seriously. This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to Livenpace.

This Privacy Policy explains how Livenpace collects, uses, discloses, processes, and protects any personal information that you give us or that we collect from you, when you use our products and our applications that we offer.

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 Livenpace 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. Where the context requires, personal information shall also include sensitive personal data or information, as may be categorized under applicable law.

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 via support@livenpace.com address your specific concerns. We will be happy to hear from you.

We may not require you to provide any personal information such as your name, email or other information. However in order to provide our service to you, we will collect some information in your use of services. We will only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and shall ensure that the information is 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 products or services or respond to your queries.

A. Information related to your application usage,including unique identifiers for application.

B. Information generated when you use a service

C. Body metrics data: data which correspond to an accurate measurement of your physical features and your body activity. They include, among others and depending on your Product, your ECG and etc.

D. Log information:information related to your use of certain features, apps. For example, devicel model and system, cookies and other identifier technologies, IP addresses, region, network request information, temporary message history, standard system logs, crash information, log information generated by using the services (such as registration time, access time, activity time, etc.).

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 is called non-personally identifiable information. We may collect, use, transfer, and disclose non-personally identifiable information. Here are some examples of information that we collect and how we may use it in a non-personally identifiable aggregated format:

A. We may include statistical data generated when you use our service;

B. Application crash events (e.g. the logging automatically generated after the application crashed etc.).

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 products and/or services.

We aggregate such information to provide you with more useful information, and understand which parts of our products and services you are most interested in. For example, we may only need the number of users who are active in a day; and we don't need to know in that day who is active, so aggregate data is enough for statistical analysis. We will endeavor to isolate your personal data from non-personally identifiable information and ensure that the two types of data are used separately. However, if we combine non-personally identifiable information with personal information, such combined information will be treated as personal information for as long as it remains combined.

The purpose of collecting personal information is to provide you with products and/or services, and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:

A. Providing, processing, maintaining, improving and developing our products and/or services to you.

B. Implementing and maintaining security safeguards for the purpose of preventing loss and fraud, such as assisting in identifying users, verifying user identity. We use your information for anti-fraud purposes only when the following two conditions are met: it is necessary; and the data used for evaluation is in accordance with the legitimate interests of Livenpace to protect users and services.

C. Handling your questions or requests about devices and services, such as answering customer inquiries, sending system and application notifications, managing your activities.

D. Internal purposes, such as data analysis, research, and development of statistical information related to the use of our products or services to improve our products or services. For example, machine learning or model algorithm training is performed after de-identification processing.

E. Storing and maintaining information related to you for our business operations(such as business statistics) or for fulfilling our legal obligations.

F. Processing based on the legitimate interests of Livenpace (in applicable jurisdictions, for example under GDPR). Legitimate interests include enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our businesses, systems, products, services, and customers (including for loss prevention and anti-fraud purposes); internal management; complying with internal policies and processes; and other legitimate interests described in this policy. For example, to ensure the security of our services, and to help us further understand the state of performance of our applications, we may record relevant information, such as the frequency of your usage, crash logs information, overall usage, performance data and source of application; to prevent unauthorized vendors unlocking devices, we may collect Account, serial number and IP address of operated computer, serial number and device info of your phone.

G. Providing services locally on terminal devices that do not require communication with our servers, such as using Notes on your device.

H. Other purposes with your consent.

Here are more detailed examples on how we use your information (which may include personal information):

Activating and registering your purchased Livenpace products or services for you.

Improving user experience through data, hardware, and software analysis.

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 products or services, including offering products or services based on your requirements. Further information about data sharing is set out below.

In accordance with legal requirements, legal procedures, litigation and/or requests from public agencies and government agencies, Livenpace 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 products, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the product, violations of our terms or policies, or other harmful or illegal activities), we may also disclose information about you. (Livenpace may collect, use or disclose your personal information 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:

A. our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice

B. investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to an entity in Livenpace; 

C. And other third parties as detailed in this Privacy Policy or otherwise notified to you, including if authorized by you to do so in relation to a specific disclosure.

Livenpace will not transfer your information to any subject except in the following cases:

A. Where we have obtained your explicit consent;

B. If Livenpace is involved in the merger, acquisition, or sale of all or part of its assets that may affect your personal information, we will notify you of any changes in the ownership, use, and any choice you may have regarding your personal information by APP and/or by posting a prominent notice or other appropriate means;

C. In the circumstances explained in this Privacy Policy or otherwise notified to you.

Livenpace may publicly disclose your personal information under the following circumstances:

A. Where we have obtained your explicit consent, or you have disclosed the information via our services such as on social media pages or public forums; 

B. Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation, or at the request of the competent government departments.

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 on your medical devices. We will ensure that we safeguard your personal information in accordance with applicable law.

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.

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 product or service. Where possible, we have indicated how long we typically retain identified categories, types or items of personal data. When deciding on these retention periods, we took into account the following criteria:

A. the amount, nature, and sensitivity of the personal data;

B. the risk of harm from unauthorized use or disclosure;

C. the purposes for which we process the personal data and how long we need the particular data to achieve these purposes;

D. how long the personal data is likely to remain accurate and up to date;

E. for how long the personal data might be relevant to possible future legal claims;

G. any applicable legal, accounting, reporting or regulatory requirements that specify how long certain records must be kept.

Depending on your jurisdiction, there may be an exception to this for personal information that we are processing for public interest, scientific, historical research, or statistical purposes. Livenpace may continue to retain this type of information for longer than its standard retention period, where necessary and permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

Livenpace processes and backs up personal information through a global operating and control infrastructure. Currently, Livenpace has data centers in the United States. For the purposes described in the Privacy Policy, your information may be transferred to the data center in accordance with applicable law.

We may also transfer your personal information to third-party service providers 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.

In particular.

The personal information that we collect and generate in operations within the territory of Mainland China is stored in data centers located in Mainland China, except for cross-border transmissions as permitted by applicable law.

For any information generated in operations within the territory outside Mainland China, we have entrusted Amazon Web Services to provide services for the storage with a long-term service period in compliance with all related applicable laws. We will properly provide you notification if the storage of the information changed.

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.

We consider it the responsibility of the parent or guardian to supervise the child's use of our products or services and we do not offer services directly to a child.

We review the Privacy Policy periodically based on changes in business, technology and applicable law and good practice, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you via this APP 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. We encourage you to check this page regularly for the latest information on our privacy practices. Your continued use of the products and services on the mobile and/or any other device will be subject to the updated Privacy Policy. Where required by applicable laws, 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.

If you have any comments or questions about this Privacy Policy or any questions relating to Livenpace's collection, use, or disclosure of your personal information, please contact us via support@livenpace.com or at the address below. When we receive privacy or personal information requests about accessing or downloading personal information, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information.

Shenzhen Livenpace Technology Co., Ltd. 402, Floor 4, BLD 9, Baiwangxin High-Tech Industrial Park, Songbai Road, Nanshan District, 518110, Shenzhen, Guangdong，P.R.China

Thank you for taking the time to read our Privacy Policy!