Software License and Service Agreement

Important Notice

Beijing HHCC Plant Technology Co., Ltd.(hereinafter referred to as "HHCC") hereby reminds all users to carefully read and fully understand the Software License and Service Agreement (hereinafter referred to as "the Agreement"). Users should carefully read and fully understand the terms of the Agreement, particularly those pertaining to the exemption or limitation of HHCC's liability, dispute resolution, and applicable laws. Terms associated with the exemption or limitation of liability are indicated by bold text; please read them carefully. After reading the Agreement carefully, please decide whether you are willing to accept the terms listed herein (minors should read the Agreement together with a legal guardian). By downloading, installing, and using the Software or by opening and logging in to your account, you accept the terms of this Agreement and are legally bound by them.

HHCC reserves the right to modify this Agreement. Any amended terms shall be announced on the official website or included with the Software, and the new terms shall take effect on the date of publication. Users may download and reinstall the Software or browse the amended terms on the website. If you do not accept the amended terms of this Agreement, please immediately discontinue your use of the "HHCC" software and services provided by HHCC. By continuing to use the "HHCC" software and services provided by HHCC, users accept the amended terms of this Agreement.

I. General Provisions

1.1. This Agreement is the agreement entered into by and between you (hereinafter referred to as the "User") and HHCC and its operating partner (hereinafter referred to as the "Partner") concerning the download, installation, and use of the "HHCC" software (hereinafter referred to as the "Software") by the User, as well as the terms related to the use of HHCC's services.

1.2. The Software and services are provided by HHCC for installation on (including but not limited to) smart mobile devices, to provide services such as device pairing and operating smart products for the User who uses the said smart device.

1.3. The rights of ownership and operation of the Software and services are vested in HHCC.

II. Scope of Software Licensing

2.1. HHCC grants the User a personal, non-transferable, and non-exclusive license to use the Software without the right to sublicense.

2.2. The User may install, use, display, and run the Software on a single mobile terminal device for non-commercial purposes. However, the User shall not install, use, or run the Software for the purpose of any commercial operation. The User shall not copy, alter or modify any data stored within the Software, any data released to the memory of any terminal device during execution of the Software or any data generated during the interaction between the client and the server during execution of the Software. The User shall not operate the Software through other software or create any derivative of the Software in any form, including but not limited to plug-ins, bots or accessing the Software and related systems through unauthorized third party tools/services. If you must sell, copy or distribute the Software commercially, such as for software pre-installation and bundling, a written authorization and permission from HHCC must be obtained in advance.

2.3. Without the permission of HHCC, the User shall not install the Software on other terminal devices that are not expressly permitted by HHCC, including but not limited to set-top boxes, game consoles, televisions, and DVD players.

2.4. The User may make a copy of the Software for the purpose of using the said Software and services, which shall be used only as a backup. All backup copies shall include the copyright information provided with the original software.

2.5. Except as expressly authorized by this Agreement, HHCC does not grant other rights to the User. If the User intends to exercise any other right, the written consent from HHCC shall be obtained in advance.

III. Software Acquisition, Installation, and Upgrades

3.1. The User shall download and install the Software from the website or in the manner designated by HHCC. Be careful not to download the Software from undesignated websites, so as to prevent mobile devices from being infected by malicious programs that can destroy user data and acquire confidential user information. If you acquired the Software or an installation program with the same name as the Software from a third party that has not been authorized by HHCC, HHCC is unable to guarantee the normal functionality of such software and will not be liable for any losses you sustain from using such software.

3.2. The User must select the Software version that matches the terminal device it is to be installed on. Otherwise, any software problems, device problems or damages resulting from using an incompatible software version on the device model shall be solely assumed by the User.

3.3. In order to improve User experience and optimize service content, HHCC reserves the right to provide replacement, modified, and upgraded versions of the Software, as well as the right to charge for these replacements, modifications, or upgrades. However, your consent is required before such charges can be collected. The Software will enable the "upgrade prompt" feature by default for the User. Depending on the software version installed by the User, HHCC will provide the User with the decision whether to enable the said feature. After the new version of the Software is released, HHCC does not guarantee that older versions of the Software will continue to be usable.

IV. Usage Specifications

4.1. The User may use the Software and services in accordance with this Agreement and relevant laws. The User shall not commit the following acts:

• 4.1.1. Delete any copyright information from the Software and other duplicate copies, or modify, delete, or circumvent the technical measures set by the Software for the protection of intellectual property rights;
• 4.1.2. Perform reverse engineering of the Software, such as disassembly, decompilation or other attempts to obtain the source code of the Software;
• 4.1.3. Add, remove or change the features or running effects of the Software by modifying or forging the instructions and data during the running of the Software, or otherwise operate or disseminate to the public the software or methods used for the purposes described above, regardless of whether or not such actions are performed for commercial purposes;
• 4.1.4. Use the Software to commit any acts detrimental to network security, including but not limited to: using unauthorized data or access to unauthorized servers/accounts; unauthorized access to public networks or the operating system of others, and delete, modify or add any saved data; unauthorized attempts to detect, scan, or test the Software system or network weaknesses, or perform other actions to disrupt network security; attempt to interfere with or destruct the normal operation of the Software system or website, deliberately spread malicious programs or viruses, or carry out other acts that disrupt or interfere with normal network information services; forge the names or partial names of TCP/IP data packets;
• 4.1.5. The User logs into or uses the Software and services through a third party compatible software or system which was not developed, authorized, or approved by HHCC, or makes, publishes, or disseminates the tools described above;
• 4.1.6 Without the written consent of HHCC, the User performs action on the Software or the data contained therein including but not limited to the following: using, leasing, copying, modifying, linking to, reproducing, compiling, releasing, publishing or establishing a mirror site for or using the Software without authorization to develop related derivative products, works, services, plug-ins, bots, compatibility or interconnection;
• 4.1.7. Using the Software to publish, transmit, broadcast, or store content which violates local laws and regulations;
• 4.1.8. Use the Software to publish, transmit, disseminate or store any content that infringes on the legitimate rights and interests of others, such as intellectual property rights and trade secrets;
• 4.1.9. Use the Software to publish, transmit or disseminate advertising information or spam in bulk;
• 4.1.10. Use the Software and other services provided by HHCC in any unlawful manner, for any unlawful purpose or in any manner inconsistent with the use licensed under this Agreement;

4.2. Information Publication Specifications

• 4.2.1. You may use the Software to publish content originally created by you or that you have the right to publish such as opinions, data, text, information, user names, images, photos, personal data, audio/video files and links. You must guarantee that you own the intellectual property rights for or have obtained legal authorization to use the information you upload and that your use of the Software and services does not infringe any legitimate rights or interests of any third party.
• 4.2.2. When using the Software, the User shall comply with local laws and regulations. ​+ 4.2.3. You shall not use the Software to commit the following acts, including but not limited to:
4.2.3.1. Produce, reproduce, publish, disseminate or store any content that violates local laws and regulations;
4.2.3.2. Publish, transmit, disseminate or store any content that infringes on the legitimate rights and interests of others, such as their right to reputation, personality rights, intellectual property rights, and trade secrets;
4.2.3.3. Make up fictitious facts or conceal the truth to mislead or deceive others;
4.2.3.4. Publish, transmit or disseminate advertising information or spam;
4.2.3.5. Engage in any other behavior that violates local laws and regulations.
• 4.2.4. Without the permission of HHCC, you shall not carry out any commercial activities inside the Software, such as advertising and selling merchandise.

4.3. You understand and agree that:

• 4.3.1. HHCC will determine whether the User is suspected of violating the above-mentioned usage specifications and, based on the result of such determination, suspend or terminate the use license granted to you or take other restrictive measures that may be taken in accordance with this Agreement;
• 4.3.2. HHCC will directly delete any information suspected of being unlawful or infringing the legitimate rights of others or violating this Agreement, which is published by the User during his/her use of the licensed Software;
• 4.3.3. If you violate the above-mentioned usage specifications and thereby cause damages to a third party, you need to assume the liability in your own name and shall hold HHCC harmless from and against any losses or expenses arising therefrom;
• 4.3.4. The User shall indemnify and hold harmless HHCC from and against any and all losses, third-party claims, administrative penalties and damages and/or expenses, including reasonable attorney fees and investigation and evidence collection costs, incurred or suffered by HHCC resulting from the User's violation of relevant laws or breach of this Agreement.

V. Service Risks and Disclaimers

5.1. The User must procure the device required for Internet access and the usage of telecom value-added services by the mobile terminal device, and bear the telecommunication fees, data fees, and related costs incurred by accessing the Internet or charged by third parties (including but not limited to telecommunications and mobile communication providers). If any telecom value-added services are needed, you are advised to confirm the costs with your telecom value-added service provider.

5.2. Neither HHCC nor its Partner is liable for any loss suffered by the User due to reasons attributable to third parties such as communication line failures, technical problems, network or mobile terminal device failures, system instability issues, and other force majeure factors.

5.3. The Software, like most other Internet software, may be affected by differences in factors including but not limited to the user, network service quality and social environment, and may also be subject to intrusion from various security problems, such as the usage of User data by others that creates a disturbance in real life; other software downloaded and installed by the User or other websites visited by the User contain "Trojan horses" and other viruses that threaten the security of the User's terminal device information and data and then affect the normal use of the Software. The User shall strengthen data security and consciousness of protecting user information and must strengthen password protection to prevent losses and disturbance.

5.4. When the User uses the Software or requests HHCC to provide specific services, the Software may call upon a third party system or software to support the User's use or access. The results of the use or access will be provided by the third party. HHCC does not guarantee the safety, accuracy and effectiveness of the results achieved through the support of the said system or software, nor does HHCC assume any other uncertain risks; HHCC assumes no liability in the event that any dispute arises therefrom or damage is caused thereby.

5.5. HHCC specifically brings to the User's attention that, in order to protect the company's business development and right to make adjustments, HHCC has the right to modify or suspend the services at any time without notice to the User and without any liability to the User or any third party.

5.6. Except as expressly specified in laws and regulations, we will do our utmost to ensure that the Software and the technology and information involved are safe, effective, accurate and reliable; however, due to limitations in current technology, the User understands that HHCC cannot provide any guarantee.

5.7. The User shall be solely liable for compensation for any personal injury or incidental or indirect economic losses, including but not limited to compensation for profit loss, data loss and losses from interruption of business or any other commercial loss or compensation claim arising out of or in connection with any of the following circumstances:

• 5.7.1. The use of or failure to use the licensed software;
• 5.7.2. The unauthorized use of the Software or modification of the User's data by a third party;
• 5.7.3. Costs and losses incurred by the User during the use of the Software;
• 5.7.4. Misunderstanding by the User of the Software;
• 5.7.5. Other losses in connection with the Software for reasons not attributable to HHCC.

5.8. For acts carried out through the Software between the User and other users of the Software, the liability for any personal injury or economic damages or losses that arise or may arise from the User having been misled or deceived shall be borne according to the law by the party at fault.

VI. Statement on Intellectual Property Rights

6.1. HHCC is the intellectual property right holder of the Software. All intellectual property rights such as copyright, trademark, patent, trade secret, etc. relating to the Software, and all information related to the Software (including but not limited to text, pictures, audio, video, graphics, interface design, layout, data or electronic documents, etc.) are protected by the laws and regulations of the region you are currently living in and corresponding international treaties. HHCC enjoys the intellectual property rights described above.

6.2. Without the prior written consent of HHCC, the User shall not independently use or transfer any of the above intellectual property rights for any commercial or non-commercial purposes, or permit any third party to do so. HHCC reserves the right to pursue legal liability for such acts.

VII. Amendment

7.1. HHCC has the right to amend the terms of this Agreement when necessary, and any such amended terms will be published on relevant web pages. If the User does not agree with the amended terms, the User shall cancel the service. The User's continuing to use the service constitutes acceptance of the amended terms of the Agreement.

7.2. HHCC and the Partner have the right to modify or change the paid services provided, the charging criteria, charging method, service charges and service terms according to their needs. When providing services, HHCC may start to charge some users certain fees either now or in the future. If the User refuses to pay such fees, the User will be unable to continue using relevant services after the new charge begins. HHCC and its Partner will do their utmost to notify the User of any amendments or changes by email or other means.

VIII. Applicable Law and Dispute Resolution

8.1. The validity and interpretation of this Agreement shall be governed by the laws of the Mainland of the People's Republic of China. In the absence of relevant legal provisions, international business practices and/or business practices may be used as references.

8.2. This Agreement is signed in Haidian District, Beijing.

8.3. Both the User and HHCC agree that any dispute arising from the services shall first be settled through consultations by the Parties. If no settlement can be reached through such consultations, either Party may submit the dispute to the court of competent jurisdiction over the district where this Agreement is signed.

IX. Other

9.1. For a specific service of the Software, there may be a separate agreement and related business rules, etc. (hereinafter collectively referred to as the "separate agreement"), so please read and agree to relevant separate agreement before using such specific service.

9.2. This Agreement shall enter into force on March 13, 2018.

9.3. The headings to all the terms of this Agreement are for ease of reference only and themselves contain no practical significance; they cannot be used in interpreting the meaning of this Agreement.

9.4. If any provision of this Agreement is or becomes invalid or unenforceable for any reason, the remaining provisions hereof shall remain in full force and effect and binding upon both Parties hereto.

Privacy Policy

Our Privacy Policy was updated on 25 April 2018 and will take effect on 25 May 2018. If you do not agree with these changes and no longer wish to use our services, you may cancel your account by emailing us at privacy@xiaomi.com. We have revamped the Privacy Policy front and back so that from this date onwards, this Privacy Policy can provide privacy details on how we manage your personal information for all Xiaomi products and services, unless a separate privacy policy is provided for a specific Xiaomi product or service.

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

Our commitment to you

This Privacy Policy sets out how Xiaomi Inc. and its affiliated companies within the Xiaomi Group (“Xiaomi”, “we”, “our” or “us”) collect, use, disclose, process and protect any information that you give us when you use our products and services located at www.mi.com, en.miui.com, account.xiaomi.com, MIUI and our Suite of applications that we offer on our mobile devices, for a list of these applications, please click here. Should we ask you to provide certain information by which you can be identified when using Xiaomi products and services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information provided to Xiaomi.

In 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 Xiaomi has access about that individual. Such personal information may include but not limit to the information you provide to us or upload, the information specific to you that may be assigned by us, your financial information, social information, device or sim-related information, location information, log information.

By using Xiaomi products and services or other acting permitted by the applicable laws, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation (e. g. General Data Protection Regulation in Europe Union), we will specifically seek prior explicit consent to the particular processing (e. g. automated individual decision-making) of special categories of personal data. Furthermore, we are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact privacy@xiaomi.com to address your specific concerns. We will be happy to address them directly.

If you have questions or concerns regarding our Privacy Policy or practices, please contact us at privacy@xiaomi.com. 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 .

What information is collected and how can we use it?

Types of information collected

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. If you do not provide your personal information, we may not be able to provide you with our products or services.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of information (which may or may not be personal information):

• Information you provide to us or upload (including your contact details): we may collect any and all personal information you provide to us, like your name, mobile phone number, email address, delivery address, ID card, driver license, passport details, Mi Account details (e.g. your security related information, name, birthday, gender), order, invoicing details, materials or data you may sync through Mi Cloud or other apps (e.g. photos, contact lists), information in relation to creating an account and participating in the MIUI Forum or other Xiaomi platforms, phone numbers you insert into your contacts or to send a message, feedback, and any other information you provide us.
• Information specific to you that may be assigned by us: we may collect and use information such as your Mi Account ID.
• Information specific to you that may be assigned by Third Party Service Providers: we may collect and use information such as your advertising ID assigned by Third Party Service Providers.
• Financial information: information related to completing purchases. For example, bank account number, account holder name, credit card number etc.
• Social information: information related to your social activities. For example, current employer, current job title, education background, professional training background etc.
• Device or SIM-related information: information related to your device. For example, IMEI number, IMSI number, MAC address, Serial number, MIUI version and type, Android version, Android ID, screen display information, device keypad information, device manufacturer details and model name, network operator, connection type, hardware usage information such as battery usage, device temperature.
• Application information: information related to your software usage. For example, application list, application status record (e.g. downloading, installing, updating, deleting), application ID information, SDK version, system update settings etc.
• Location information (only for specific services/functionalities): various types of information on your location. For example, region, country code, city code, mobile network code, mobile country code, cell identity, longitude and latitude information, time zone settings, language settings.
• Log information: information related to your use of certain functions, apps and websites. For example, cookies and other anonymous identifier technologies, IP addresses, network request information, temporary message history, standard system logs, crash information.
• Other information: environmental characteristics value (ECV) (i.e. value generated from Mi Account ID, phone device ID, connected Wi-Fi ID and location value).

We may also collect other types of information which are not directly or indirectly linked to an individual and which is aggregated, anonymized or de-identified. For example, the device model and system version number of the user’s Xiaomi mobile phone device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you.

How the personal information can be used

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies (which are in the communications, social media, technology and cloud businesses), Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

• Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.
• Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, information about our events, notices.
• Conducting marketing related activities, such as providing marketing and promotional materials and updates. For more information on marketing and promotional activities, please refer to the Direct Marketing section below.
• Allowing you to post comments in public forums.
• Conducting promotional activities, such as sweepstakes and Facebook events.
• Analyzing and developing statistical information on use of our products and services to better improve our products and services.
• Optimizing the performance of your device, such as analyzing the memory usage or CPU utilization of our applications.
• Storing and maintaining information about you for our business operations or legal obligations.
• Providing local services without communicating with our servers.

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

• Setting up your Mi Account. Personal information collected when creating a Mi Account on our web sites or through our mobile devices is used for creating the personal Mi Account and profile page for the user.
• Processing your purchase orders. Information relating to e-commerce orders may be used for processing the purchase order and related after-sales services, including customer support and re-delivery. In addition, the order number is used to cross check the order with the delivery partner as well as the actual delivery of the parcel. The receipt details, including name, address, phone number and postal code are for delivery purposes. The email address is used to send parcel tracking information to the user. The list of purchased item(s) is used for printing the invoice and allowing users to see what is in the parcel.
• Allowing you to participate in MIUI Forum. Personal information in relation to the MIUI Forum or other Xiaomi Internet platforms may be used for profile page display, interaction with other users, participating in the forum.
• Providing Mi Cloud and other MIUI services. Information (device or SIM card-related information including IMEI number, IMSI number, phone number, device ID, device operating system, MAC Address, device type, system and performance information and location information including mobile country code, mobile network code, location area code and cell identity) is collected for activating MIUI services, e.g. Mi Cloud, call log sync, SMS sync, Find Device, for the purposes of user authentication and activation of the services.
• Diagnosing activation failures: Location related information is used for the purpose of assessing SIM card activation failure (i.e. failure of SMS gateway and network) to identify the network operator of that service, and notify the network operator of that failure.
• Providing other MIUI services. Other information collected for each of the MIUI services may be used for performing the functions of that service, and to facilitate the provision of that service for the benefit of the user, e.g. downloading, updating, registering, performing or optimizing activities related to MIUI services. For example, personal information collected by the Theme Store may be used to provide personalized theme recommendation services based on your downloading and browsing history.
• Finding your device: Xiaomi’s Find Device feature helps you find and secure your phone if it is lost or stolen. You can locate your phone on a map using location information provided by your phone, wipe your phone, or lock your phone. We may collect your location data directly from your mobile device, or in some situations, from cell towers or Wi-Fi hotspots.
• Recording location information in photos. You have the ability to record your location information while taking a photo. This information will be visible within your photos folder and the location will be put into the header of your photos. If you do not wish to have your location recording while taking a photo, you may turn this off at any time within the camera settings of the device.
• Providing messaging functions (e.g. Mi Talk, Mi Message). If you download and use Mi Talk, information collected for Mi Talk may be used for activating this service and identifying the user and message recipient. In addition, chat history is stored for the convenience of re-loading historical chats after a user has re-installed apps, or for synchronization across devices. Information (sender’s and recipient's phone numbers and Mi Message IDs) may be used for Mi Message for activating the services and enabling the service to function, including routing of messages.
• Providing location based services. In the course of using MIUI services, location information may also be used by us or Third Party Service Providers to serve you the correct version of the service and provide accurate details about that location for the best possible user experience, e.g. weather details, location access (as part of the Android platform). You may turn this off at any time by going into the device settings or discontinue use of that application.
• Improving user experience. Some opt-in features, such as the User Experience Program, allow Xiaomi to analyze data about how users use the mobile phone and MIUI services, so as to improve the user experience, such as sending crash reports.
• Allowing you to use Security Center. Information collected may be used for security and system up-keeping functionalities in the Security Center, such as advertising blocker, virus scan, power saver, blocklist, cleaner, etc. Some of these functionalities are operated by Third Party Service Providers. Information (which is not personal information like virus definition lists) is used for virus scan functions.
• Providing Push Service. Mi Account ID and IMEI numbers will also be used to provide the Xiaomi push service to evaluate advertising performance and send notifications from MIUI about software updates or new product announcements, including information about sales and promotion. Furthermore, under entrust of selected third party (the data controller of your personal information), the Xiaomi push service may also evaluate advertising performance or send notifications by using your Mi Account ID and IMEI numbers. You consent to our use of your personal information for the purpose of sending you pushing services (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. You may opt out of this at any time through changing your preferences under “Settings”, or through the selected third party you consent.
• Verifying user identity. Xiaomi uses the ECV value to verify the user identity and ensure there is no log-in by hackers or unauthorized persons.
• Collecting user feedback. The feedback you choose to provide is valuable in helping Xiaomi make improvements to our services. In order to follow up on the feedback you have chosen to provide, Xiaomi may correspond with you using the personal information that you have provided and keep records.
• Sending notices. From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies.
• Conducting promotional activities. If you enter into a sweepstake, contest, or similar promotion, e.g. via Xiaomi’s Facebook page or other social media platforms, we may use the personal information you provide to administer those programs.
• Conducting analysis of your device to provide better user experience. Xiaomi may conduct the hardware or software analysis, so as to further improve the performance of your device.

Direct marketing

• We may use your name, phone number, and email address, Mi Account ID and IMEI number to provide marketing materials to you relating to goods and services of Xiaomi companies and our business partners which offer network, mobile applications and cloud products and services. To provide better user experience, we may recommend above-mentioned products, services and activities based on information about your purchase history, website browsing history, birthday, age, gender, and location. We will only so use your personal data after we obtain your prior explicit consent and involve a clear affirmative action or indication of no objection in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of our proposed use of your personal data for direct marketing. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each communication. We will not transfer your personal data to our business partners for use by our business partners in direct marketing.

Cookies and other technologies

• What information is collected and how we can use them: Technologies such as cookies, tags, and scripts are used by Xiaomi and our Third Party Service Providers. 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.
• 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.
• Advertising: We partner with our Third Party Service Providers to either display advertising on our website or to manage our advertising on other sites. Our Third Party Service Provider may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. We will obtain your prior explicit consent and involve a clear affirmative action before providing this advertising service to you. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here http://preferences-mgr.truste.com.
• Mobile Analytics: Within some of our mobile applications we use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where crashes occur within the application. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
• 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 or to display advertising based upon your web browsing activity 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: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html .

With whom we share your information

We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that Xiaomi will only share your personal information in accordance with your consent. Your consent to Xiaomi will engage sub-processors for the processing of your personal information. You should know that when Xiaomi shares your personal information with a Third Party Service Provider under any circumstance described in this section, Xiaomi will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Xiaomi will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

Sharing with our group and third party service providers

From time to time, in order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other Xiaomi affiliated companies (in communications, social media, technology or cloud businesses), or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers, agents acting on behalf of Xiaomi, [related corporations, and/or other third parties] (together “Third Party Service Providers”). Such Third Party Service Providers would be processing your personal information on Xiaomi’s behalf or for one or more of the purposes listed above. We may share your IP address with third parties when using certain mobile applications on our device in order to provide you with some of the services you requested. If you no longer wish to allow us to share this information, please contact us at privacy@xiaomi.com.

Sharing with our group’s ecosystem companies

Xiaomi works together with a cool group of companies, which together form the Mi Ecosystem. The Mi Ecosystem companies are independent entities, invested and incubated by Xiaomi, and are experts in their fields. Xiaomi may disclose your personal data to the Mi Ecosystem companies so as to provide you with and improve the exciting products and services (both hardware and software) from the Mi Ecosystem companies. Some of these products and services will still be under the Xiaomi brand, while others may use their own brand. The Mi Ecosystem companies may also share data with Xiaomi from time to time in relation to products and services under the Xiaomi brand and other brands owned by Xiaomi to provide hardware and software services, and to create better functions and user experience. Xiaomi will take appropriate organizational and technical measures to ensure the security of personal data during the process of sharing of information, including but not limited to the encryption of your personal data. If Xiaomi is involved in a merger, acquisition or asset sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our website, of any changes in ownership, uses of your personal information, and choices you may have regarding your personal information.

Sharing with others

Xiaomi may disclose your personal information without further consent when required under applicable law.

Information not requiring consent

• We may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.
• For the avoidance of doubt, Xiaomi may collect, use or disclose your personal information without your consent if it is and only to the extent it is allowed explicitly under local data protection laws.

Security safeguards

Xiaomi’s security measures

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect on your mobile device and on Xiaomi websites. We will use all reasonable efforts to safeguard your personal information.

For example, when you access your Mi Account, you can choose to use our two-step verification process for better security. When you send or receive data from your Xiaomi device to our servers, we make sure they are encrypted using Secure Sockets Layer (“SSL”) and other algorithms.

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We will take all practicable 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 which is transferred from you or to you via the Internet.

We will take upon the personal data breach, notifying the breach to relevant supervisory authority or under some circumstances, notifying the personal data breach to the data subjects by complying with applicable laws, including your local data protection legislation.

What you can do

• You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you. Whenever you log in as a Mi Account user on Xiaomi websites, particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.
• Xiaomi cannot be held responsible for lapses in security caused by third party accesses to 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.

Retention policy

Personal information will be held for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by Xiaomi even if the further processing is incompatible with original purposes.

Accessing other features on your device

Our applications may need access to certain features on your device such as enabling emails to contacts, SMS storage and Wi-Fi network status, as well as other features. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us at privacy@xiaomi.com.

You have control over your personal information

Controlling settings

Xiaomi recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Xiaomi makes available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

• Toggle on/off for the User Experience Program and Location Access functions;
• Log in and out of the Mi Account;
• Toggle on/off for the Mi Cloud sync functions; and
• Delete any information stored on Mi Cloud through www.mi.com/micloud
• Toggle on/off for other services and functionalities which deal with sensitive or personal information.

You may obtain more details in relation to your device’s security status in the MIUI Security Center as well.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or emailing us at privacy@xiaomi.com.

Access, update, correct, erase or restrict processing your personal information

• You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection 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 of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
• If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible at the email address below. Email: privacy@xiaomi.com
• For details relating to the personal information in your Mi Account, you may also access and change them at http://account.mi.com or by logging into your account on your device.
• If you are Europe Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.
• If you are Europe Union user under GDPR, 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.
• If you are Europe Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• If you are Europe Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

Withdrawal of consent

• You may withdraw your consent for the collection, use and/or disclosure of your personal information in our possession or control by submitting a request. This may be done by accessing your Mi Account management center at account.xiaomi.com/pass/del. 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.
• Please recognize that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy Xiaomi’s products and services.

Transfer of personal information outside of your jurisdiction

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, technology and cloud businesses) or Third Party Service Providers, we shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You will have the right to be informed of the appropriate safeguards taken by Xiaomi for this transfer of your personal information.

Xiaomi is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal data to any subsidiary of the Xiaomi group worldwide when processing that information for the purposes described in this Privacy Policy. We may also transfer your personal data to our third party service providers, who may be located in a country or area outside the area of the European Economic Area (EEA).

Whenever Xiaomi shares personal data originating in the EEA with a third party which may or may not be a Xiaomi entity outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.

Xiaomi may use overseas facilities operated and controlled by Xiaomi to process or back up your personal information. Currently, Xiaomi has data centers in Beijing, United States, Germany, Russia and Singapore. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.

Miscellaneous

Minors

• We consider it the responsibility of parents to monitor their children’s use of our products and services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.
• Xiaomi does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided Xiaomi with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable Xiaomi services.

Order of precedence

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

Updates to the privacy policy

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the Xiaomi websites or through our mobile devices, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

Do I have to agree to any third party terms and conditions?

Our Privacy Policy does not apply to products and services offered by a third party. Xiaomi products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to 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.

Here are third party terms and privacy policies that apply when you use these specific products:

• By using PayPal or other third party check-out services to finalize and pay for your order, you are agreeing to the third party check-out service provider’s privacy policy will apply to the information you provide on their website.
• By using the Virus Scan feature in the MIUI Security Center, you are agreeing to one of the following three terms based on your choice of service.

• Avast Privacy and Information Security Policy: https://www.avast.com/privacy-policy
• License Agreement for AVL SDK for Mobile: http://co.avlsec.com/License.en.html?l=en
• Tencent’s Terms of Service: http://wesecure.qq.com/termsofservice.jsp

• By using the Cleaner feature in MIUI’s Security Center, you are agreeing to one of the following two terms based on your choice of service.

• Cheetah Mobile’s Privacy Policy: http://www.cmcm.com/protocol/cleanmaster/privacy-for-sdk.html
• Tencent’s Terms of Service: http://wesecure.qq.com/termsofservice.jsp

• By using the advertising services in several specific applications in MIUI, you are agreeing to one of the following two terms based on your choice of service.

• Google’s Privacy Policy: https://policies.google.com/
• Facebook’ Privacy Policy: https://www.facebook.com/about/privacy/update?ref=old_policy

• By using the Google Input Method, you are agreeing to Google’s terms: http://www.google.com/policies/privacy
• By using the SwiftKey Input Method, you are agreeing to SwiftKey’s terms: http://swiftkey.com/en/privacy

Social media (features) and widgets

Our websites include social media features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social media features and Widgets are either hosted by a third party or hosted directly on our websites. Your interactions with these Features are governed by the privacy policy of the company providing it.

Single sign-on

Depending on your jurisdiction, you may be able to log in to our website using sign-on services such as Facebook Connect or an Open ID provider. These services will authenticate your identity, provide you the option to share certain personal information (such as your name and email address) with us, and to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this website to your profile page to share with others within your network.

About our systematic approach to manage your personal information

If you are Europe Union user under GDPR, Xiaomi will provide systematic approach to manage personal data deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) Xiaomi set up a Data Protection Officer (DPO) in charge the data protection, and the contact of DPO is dpo@xiaomi.com; (2) procedure like data protection impact assessment (DPIA).

Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to Xiaomi’s collection, use or disclosure of your personal information, please contact our Data Protection Officer at the address below referencing “Privacy Policy”:

Xiaomi Singapore Pte. Ltd. 20 Cross Street, China Court #02-12 Singapore 048422 Email: privacy@xiaomi.com Thank you for taking the time to understand our Privacy Policy!

What’s new to you

We have made several major edits throughout the “Privacy Policy” as follows:

• We updated the types of personal information that we collected and the purposes of collecting such information. For example, we collected hardware usage information to conduct statistical analysis and optimize the performance of your devices.
• By complying with GDPR and providing better data privacy protection, we updated the relevant content about users’ rights under GDPR, and how we process the personal information for our Europe Union users. We also described our data privacy management method additionally.
• We updated the relevant content of third parties’ products and services which may be involved during the use of our products and services.