Privacy Policy for UBTECH Delivery Robot

Robot Updated: December 28th, 2023

Effective Date: January 3rd, 2024

Definition:

Delivery Robot: UBTECH Delivery Robot (hereinafter referred to as "this product") is an intelligent commercial delivery service robot that can provide multiple functions, including delivery, greeting and customer service, advertising display etc. The application software includes robot body terminal system, WEB web service and mobile APP.

Enterprise Customer: Refers to individuals or organizations that register, log in, and use the delivery robot and obtain management permissions, including but not limited to government agencies and enterprises. Enterprise customers can control the delivery, greeting and customer service, advertising display and other functions of the robot through the management end of the delivery robot.

Personal User: Refers to the administrator or delivery personnel who have been designated by enterprise clients and have operational permissions in the enterprise client management backend system. Administrators and delivery personnel can be one or more people, hereinafter referred to as "you" or "personal users". When the enterprise client or enterprise administrator adds you as a personal user to the delivery robot, you will usually receive a notification and can choose whether to use this product. The notification and authorization agreement are the responsibility of the enterprise client or enterprise administrator where the personal user is located.

1.What types of information do we collect?

Please note that our product is mainly aimed at enterprise clients. If you are a personal user of an enterprise client, the enterprise client is the controller of your personal data, and has the right to decide which personal users can use our product. We are entrusted by the enterprise client to process your data. The enterprise client should ensure that they have obtained the explicit consent of the personal user in advance in accordance with relevant laws and regulations, and have fully informed the personal user of the purpose, scope, use methods, protection measures, and the situation of entrusting us to process the relevant data. We will collect and process your personal information according to the enterprise client's decision and our relevant agreements with the enterprise client, in accordance with this policy.

The enterprise client entrusts us to process the information and data submitted or generated by personal users during their use of this platform, including the information submitted or required by the enterprise client, the information assigned to personal users by the enterprise client, and the information submitted by personal users to the enterprise client to complete the corresponding functional requirements of the delivery robot (hereinafter referred to as "entrusted personal information"). The enterprise client is the controller of such personal information. We accept the commission of the enterprise client and process such personal information based on the enterprise client's instructions (including the operations carried out by the enterprise client and enterprise client administrators through the management backend), as well as the agreements between us and the enterprise client, or based on the purpose of providing office management and communication services, etc. The entrusted personal information includes:

(1)User account information

After you purchase our robot, we will provide you with an enterprise account and password to help you use the robot and its web.

(2)management and map building information

In order to achieve the management of the robot through the web, as well as to more conveniently and efficiently solve your problems in the process of using the product, maintain the normal operation of our products, improve and optimize the functional experience of our products, and protect the safety of your account or based on the need to comply with laws and regulations, we need to collect your robot work data, robot details, building map information, task information, account role Permission information, delivery personnel information, etc.

(3)Voice Information

In order to realize voice interaction between the robot and you, we need to collect your voice information. We are commissioned by companies to process this information.

(4)Log Information

In order to facilitate a more convenient and efficient solution to your problems in the process of product use, maintain the normal operation of our products, improve and optimize the functional experience of our products as well as to protect the security of your account or based on the need to comply with laws and regulations, we will collect log information on your use of the product.

(5)Communication Information

You feedback to us through our customer service phone, email or other means, we may need you to provide the necessary personal information for identity verification, may also save your contact information (you use or actively provide the cell phone number), your call with us and the content of the record, as well as other necessary information, in order to provide and record customer service services.

(6)Terminal data exposed to the operation and maintenance process

In addition, with your authorization and consent, our staff may access the data stored on your robot during this period for the purpose of remote operation and commissioning. We are not actively accessing the data on your robot for remote commissioning purposes only. You can also ensure your privacy by deleting the data from the robot in advance.

2.How do we use this information?

The personal information that we collect during your use of this product or through our enterprise clients' commissioning is for the purpose of providing better services to users of this product (including enterprise clients and their individual users). We use the collected information for the following purposes:

(1)To assist you in registering as a user of the delivery robot and to ensure the security of your personal information;

(2)To assist you in operating the machine through the software and to provide services for you;

(3)To efficiently and conveniently resolve any problems you may encounter while using the product;

(4)Collecting and using robot information and log information for safe operation and maintenance;

(5)In order to comply with relevant laws, regulations, and governmental directives.

(6)For entrusted processing of personal information, we will process it in accordance with the decisions made by the enterprise client, the relevant agreements between us and the enterprise client, or their backend operations in accordance with the law. For example, enterprise clients have the right to decide which individual users use this product and which and how personal user information is displayed within this product.

3.How do we provide, transfer, and disclose your personal information to third parties?

(1) Disclosure to Third Parties:

Currently, we do not disclose any personal information we collect to any other controllers or processors of personal information. If necessary, we will inform you of the name, contact information, purpose, method, and types of personal information of the information recipient and obtain your authorization and consent.

(2)Transfer:

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

a.with your explicit consent or authorization in advance;

b.as required by laws, regulations, legal procedures, mandatory administrative or judicial requests;

c.provided in accordance with the relevant agreements you have signed with us (including electronically signed agreements and corresponding product rules) or other legal documents;

d.in the event of the continued development of our business, such as mergers, acquisitions, or asset transfers, we will inform you of the relevant situation (including the name or contact information of the recipient), and continue to protect or require the new recipient to protect your personal information in accordance with the standards required by laws, regulations, and not lower than this policy.

(3)Disclosure:

We will only disclose your personal information in the following cases, and only when security protection measures that meet industry standards are taken:

a.disclose the personal information you specified in the disclosure method that you explicitly agreed upon upon your request;

b.in accordance with laws, regulations, mandatory administrative enforcement, or judicial requirements, we may publicly disclose your personal information according to the types of personal information requested and the disclosure methods required.

4.How we protect your personal information

(1)Information Storage Period

We will store your personal information in a secure manner, including local storage (such as using machine devices for data caching). In general, we will only store your personal information for the time necessary to provide services or under conditions prescribed by laws, regulations, and regulatory requirements. Upon expiration of the storage period, we will delete or anonymize your personal information. For enterprise customers, they can independently set the retention period for entrusted processed personal information, and we will not view or use the entrusted processed personal information retained by enterprise customers.

In the event that our products or services cease operation, we will notify you through push notifications, announcements, etc., and delete your personal information or anonymize it within a reasonable period of time, immediately stop collecting personal information, and close third-party application service interfaces to avoid third-party services from collecting and continuing to use personal information.

(2)Information Storage Location

We process and backup personal information through global operation and control facilities. Currently, we have servers in China, Germany, Singapore, the United States, and other countries according to business expansion. If we need to transfer personal information to jurisdictions outside your jurisdiction, whether to our affiliates or third-party service providers, we will comply with applicable laws and regulations. Before providing your personal information to overseas partners, we will obtain your express consent in accordance with legal requirements and inform you of the detailed rules for cross-border provision of personal information. We ensure that all such transfers meet the requirements of local applicable data protection laws by implementing unified security measures. The specific data storage locations are shown below:
Operating country/region Data storage location
Mainland China Mainland China
European Union (EU) Germany
Canada, Mexico, the United States and other American countries and regions The United States
Japan, South Korea, and other countries and regions Singapore

(3)Technical Security Measures

We have classified and graded personal information based on its type and sensitivity, and have implemented corresponding technical protection measures, including but not limited to access control, de-identification, irreversible encrypted storage, and isolated storage. We have also adopted technologies such as desensitization display and encrypted transmission for information display and transmission to ensure the security of your personal information.

(4)Organizational Security Measures

We have established a data compliance joint working group and formulated management systems and process standards related to personal information protection. We conduct personal information protection impact assessments for data processing activities that involve sensitive personal information processing and external sharing that have a significant impact on personal rights. At the same time, we organize security and privacy protection training courses to enhance employees' awareness of the importance of personal information protection, strictly control the scope of personnel who access personal information, require them to comply with confidentiality obligations, and conduct audits. Personnel who violate their obligations will be punished in accordance with regulations.

(5)Security Incident Response

We recommend that you fully pay attention to the protection of personal information, especially the protection of login accounts, passwords, and other important personal information when using our products or services. We will also do our best to ensure the security of your personal information. In the event of a personal information security incident, we will activate the emergency plan to prevent the expansion of the security incident and proactively report the handling of the personal information security incident in accordance with relevant laws, regulations, and regulatory requirements. We will also notify you of the basic situation of the security incident, the remedial measures we have taken or will take through methods such as push notifications, email/SMS, telephone, etc. in accordance with relevant laws and regulations. If it is difficult to notify you one by one, we will issue a warning through announcements and other means.

5.How we protect the personal information of minors

Our product is not aimed at minors, including children. If we discover that we have collected personal information of minors without knowing it, we will make every effort to delete the relevant data as soon as possible.

6.How we ensure you exercise your personal rights

(1)Your rights to your personal information

As an enterprise client, we have an obligation to respond to your requests for exercising your personal information rights. We accept the commission of enterprise clients to cooperate with responding to your requests for exercising your personal information rights. You have the right to request access, correction, deletion of any personal information related to you that we hold, or obtain a copy of your personal information (hereinafter referred to as "requests"):

a.Right to access and correction

You have the right to access and modify your name information through the background management system.

b.Right to deletion

You can delete your name information autonomously on the delivery robot and background management system. In the following circumstances, you can make a request to us to delete personal information by calling customer service: 1) If our processing of personal information violates laws and regulations; 2) If we collect and use your personal information without your consent; 3) If our processing of personal information violates the agreement with you; 4) If you no longer use our products or services, or you cancel your account; 5) If we terminate our services and operations.

We will evaluate your deletion request and take corresponding steps, including technical measures if applicable, to process it. After you or we assist you in deleting relevant information, due to applicable laws and security technologies, we may not be able to immediately delete the corresponding information from the backup system. We will securely store your personal information and isolate it from any further processing until the backup can be cleared or anonymized.

c.Other rights

If you wish to withdraw your consent or restrict the processing of your personal information, or exercise related rights to personal information other than name information, you can contact your enterprise client or enterprise administrator to exercise such rights.

7.How this policy is updated

The purpose of this policy is to provide you with a detailed description of the personal information handling rules and activities of the delivery robot. We reserve the right to update or modify this policy in a timely manner as product features, services, or organizational environments change. If such modifications result in a substantial reduction of your rights under this policy ("significant changes"), we will send you a notification of the changes through different channels, including but not limited to announcement pop-ups, website announcements, private messages, etc.

Significant changes referred to in this policy include but are not limited to:

(1) Significant changes in our product features or services, such as the purpose of personal information processing, types of personal information processed, and ways of using personal information;

(2) Significant changes in the main object(s) of personal information sharing, transfer, or public disclosure;

(3)Significant changes in your rights and the ways of exercising your rights regarding personal information processing;

(4)Changes in the department responsible for personal information protection, contact methods, and complaint channels;

(5)Significant changes in ownership structure, organizational structure, etc., such as changes in ownership resulting from business adjustments, bankruptcy mergers, etc.;

(6)When a personal information security impact assessment report indicates high risks.

When our products or services cease operation, we will announce or push notifications to you in accordance with relevant laws and regulations, and protect your legal rights and interests in accordance with the law. Unless otherwise required by laws, regulations, or regulatory requirements, we will promptly stop collecting your personal information and delete or anonymize relevant personal information.

8.How to contact us

We have appointed a Data Protection Officer. If you have any questions about this privacy policy, or any complaints or comments regarding the processing of your personal information, you can provide feedback to us through the "Feedback" option in the "Settings" section of the delivery robot's "Personal Center." You can also contact us through the following channels:

Phone: +86-400-6666-700 (Monday to Friday, 9:00-18:30 Beijing time)

Email: ucare@ubtrobot.com

Office address: 22/F, Building C1, Nanshan Intelligence Park, No. 1001 Xueyuan Avenue, Nanshan District, Shenzhen City

We will reply within 15 working days.