Privacy Policy
This privacy policy was updated and became effective on November 5th, 2021. Please read the following to learn more about this "Privacy Policy" and let us know if you have any questions.
Shenzhen Conex Intelligent Technology Co., Ltd. (Registered address at 11th Floor, Block B, Tsinghua Info Port, No. 1 Xindong Road, Songpingshan, Songpingshan Community, Xili Street, Nanshan District, Shenzhen, Guangdong) and/or its affiliates (collectively as "Conex", "we", "us", and "our") understand the importance of privacy and respect your privacy. Please read the following to get to know this "Privacy Policy" (hereinafter referred to as the "Policy") before submitting personal data to Conex. This policy applies to Conex websites, products and services that display or provide links to this Policy.
The "smart device(s)" mentioned in this policy refers to: smart door locks and/or other related smart devices that can be paired with Philips EasyKey .
This Policy describes how Conex processes your personal data, but it may not address all possible data processing scenarios. Conex may inform you of product- or service-specific data collection through supplementary policies or notices provided before collection.
The purpose of this policy is to help you understand the following:
1. How we collect, use and store your personal data
2. Cookies and similar technologies
3. Third-party SDK
4. How we disclose personal data
5. How we access and control your personal data
6. How we protect and retain your personal data
7. How we process children's personal data
8. Account cancellation
9. Third-party providers and their services
10. International transfers of your personal data
11. Updates to this Policy
12. Contact us
1. How we collect, use and store your personal data
1.1 Personal data
Personal data means any data that, either on its own or jointly with other data, can be used to identify a natural person. You directly provide us with such data when you use our websites, products, or services, or interact with us by, for example, creating an account or contacting us for support. We may also obtain such data by recording how you interact with our websites, products, or services. For example, we may use technologies like cookies or receive use data from software running on your device. As permitted by law, we may also obtain data from public and commercial third-party sources, for example, purchasing statistics from other companies to support our services. The personal data we collect includes name, gender, addresses, phone number, login information (account and password), photos, and credentials information, etc., depending on how you interact with us, for example, the website you visit or the products and services that you use. We also collect the information you provide to us and the content of messages you send to us, such as the query information you provide, or the questions or information you provide for customer service support. We also collect information from the handheld terminal that runs the APP, such as IMEI number, IMSI number, system version, manufacturer information, model name, and network operator. We may also collect related device information bound to your account, such as MAC address, DID, device network status (IP/network signal), firmware version.
Before using our products or services, you may need to provide personal data. In some cases you may be able to opt not to disclose your personal data, but the non-provision of certain personal data will cause the inability to provide you with some related products or services, nor can it respond to or solve the problems you encountered.
We may process your personal data for the following purposes:
(a) Create an account.
(b) Fulfilling your transaction or service request, including fulfilling orders, delivering, activating, or verifying products or services; providing training and certification; managing and processing training and certification exams; participating in onsite or virtual activities; fulfilling your request to change or providing you with the requested information (such as marketing materials for products or services, and white papers); and providing technical support.
(c) To send you important notices, such as installation of and updates to operating system or application.
(d) Qualifying and managing suppliers and business partners, and communicating or working with suppliers and business partners.
(e) Improving our products and services through internal audits, data analysis, and research.
(f) Analyzing the efficiency of our business operations and evaluating market share.
(g) Troubleshooting when you send us the detailed error reports.
(h) Synchronizing, sharing, and storing the data you upload or download and the data needed for the uploading and downloading.
(i) Ensuring the security of our products, services and customers or users, executing and improving our loss prevention and anti-fraud programs.
(j) Complying with and enforcing applicable legal requirements, industry standards and our policies.
(k) Access to Microphone permission: after turning on permission in Microphone settings, you can use the phone¡¯s microphone to realize the video intercom between the mobile App and the smart device.
(l) Access to Contacts permission: after tuning on permission in Contacts settings, when you are setting the PIN code on the smart device, you could bind a designated contact to the PIN code, and set this PIN code as a duress PIN code on the App. Once the PIN code is used, the App will send a push notification to the designated contact.
(m) Access to Call permission: after the call permission is turned on, users in mainland China can get in touch with us through the [Contact us] page on the Philips EasyKey (Note: users in Hong Kong, Macau, Taiwan and overseas markets please email philips.ddl.cn@cone -x.com to get support).
(n) Access to camera permission: after enabling the camera permission, you can use the photo/video function by scanning the QR code on the smart device's label, and bind the device to the APP; at the same time, you can change personal avatar by taking a new photo.
(o) Access to gallery (photos) permission: after enabling the permission of the gallery (photos), after you click on "Feedback", you can upload the abnormal photo(s) of the smart device in the gallery to reflect the related issues of the smart device; by uploading the photo(s) in the gallery, you can change the personal avatar on the APP; to access to the gallery permission, you can save the content captured by the video door lock to the gallery; to access to the gallery, you can obtain the QR code of the device in the phone¡¯s gallery when the smart device is connected to the Internet to perform the networking pairing.
(p) Access to storage permission: after turning on the storage permission, you are allowing to save the pictures/videos in the smart device(s) to the phone¡¯s gallery. When the permission is denied, related pictures/videos will not be saved to the phone¡¯s gallery.
(q) Access to notification permission: after turning on the notification permission, you can search for the smart devices¡¯ daily operation logs, alert information, access logs, version update notification, etc. When the permission is denied, you will not be able to receive the related information.
(r) Access to face ID/fingerprint permission: after enabling the permission to obtain face ID and fingerprint(s), you can log in by face ID or fingerprint. For fingerprints and face ID(s) , they are only used to verify the user's identity and we do not collect your fingerprints or facial features. When the permission is denied, the shortcut login method by face ID or fingerprint will not be available.
(s) Access to location services: after turning on location services, when the malfunction occurs in a smart device, we can reach you by obtaining your current location information; further, when the APP fails to work, by obtaining your current area and country code, latitude and longitude information, we can better figure out the source of the fault.
(t) Access to login information permission: after turning on the permission of login information, when you are binding the smart device to the App, you can pair your current account with the smart device you have purchased; when the smart device fails to work, we can use account data to unbind the account, deploy and upgrade services only after with your consent. At the same time, by viewing the current account system crash logs, we can trace the source of the problem faster. If this access is denied, your account will not be able to be used normally.
(u) Access to the list of applications installed: It is necessary to check whether your mobile phone has installed "WeChat" to provide you with the "WeChat" sharing. At the same time, we only detect "WeChat", and do not detect/obtain information about other applications on your mobile phone [Note: The permission of WeChat is only for users in the People's Republic of China].
Please be noted that the above permissions are disabled by default, and only with your explicit authorization can they be used when using specific functions or services, and you can also withdraw the authorization. In particular, even with your authorization, we will not collect your information when the relevant functions or services are not needed after we have obtained the permissions of these sensitive data. You can set related permissions on Philips EasyKey according to your needs, turn off or turn on the corresponding permissions.
1.2 Non-personally identifiable information
Conex may also collect and use non-personally identifiable information (Non-PII). Non-PII is information that cannot be used to identify a particular individual. For example, Conex will collect statistical data, such as the numbers of visits to its website. We collect this data to understand how users use our websites, products, and services so that we can improve our services and better satisfy your needs. Conex may collect, use, process, transfer, or disclose non-PII for other purposes at its own discretion. We will endeavor to isolate your personal data from non-PII and ensure that the two types of data are used separately. If personal data is combined with non-PII, it will still be treated as personal data during processing.
Conex will process your personal data following the requirements of applicable laws on an appropriate legal basis, including:
l Processing your personal data to fulfill the contract when responding to a transaction or service request;
l lProcessing your personal data with your consent;
Processing based on the legitimate interests of Conex or a third party when we use your personal data to contact you, conduct marketing or market surveys, improve our products and services, execute and improve our loss prevention and anti-fraud programs, and other purposes. 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; internal management, complying with internal policies and processes; and other legitimate interests described in this policy;
We may also process your personal data as necessary to comply with and fulfill legal obligations.
1.3 Information storage and exchange
(a) The personal information we collect and generate within the territory of the People's Republic of China will be stored in the storage space of the mobile phone and/or on the servers of Conex¡¯s affiliates. At the same time, the information will be stored in the territory of the People's Republic of China and does not involve cross-border transmission.
(b) Mobile phones and personal information generated in overseas regions will be stored in the storage space of the mobile phone and/or on the servers of Conex¡¯s affiliates, and the information will be stored in Singapore.
(c) We only store your personal information within the time limit necessary to achieve the purpose or within the time limit required by laws and regulations. After you stop using this product, we will immediately stop collecting and processing your personal information. When the above period is exceeded, we will delete or anonymize the personal information you have provided.
(d) If we stop operating the related products or services, we will promptly stop collecting your personal information. The stop-to-operation notice will push to you in an announcement or other appropriate form, and the personal information we have stored will be deleted or anonymized.
2. Cookies and similar technologies
To ensure our website works correctly, we may at times place a small piece of data known as a cookie on your computer or mobile device. A cookie is a text file stored by a web server on a computer or mobile device. The content of a cookie can be retrieved or read only by the server that creates the cookie. The text in a cookie often consists of identifiers, site names, and some numbers and characters. Cookies are unique to the browsers or mobile applications you use, and enable websites to store data such as your preferences or items in your shopping cart.
Like many other websites or Internet service providers, Conex uses cookies to improve user experience. Session cookies are deleted after each visit, while persistent cookies remain in place across multiple visits. Cookies allow websites to remember your settings such as language, font size on your computer or mobile device, or other browser preferences. This means that a user does not need to reset preferences for every visit. On the contrary, if cookies are not used, websites will treat you as a new visitor every time you load a web page. For example, if you are redirected to another web page from a website you are already logged in to and then return to the original website, it will not recognize you and you must log in again.
Conex will not use cookies for any purposes not stated in this policy. You can manage or delete cookies based on your own preferences. For details, visit AboutCookies.org. You can clear all the cookies stored on your computer, and most web browsers provide the option of blocking cookies. However, by doing so, you have to change the user settings every time you visit our website. Find out how to manage cookie settings from the user guides of the corresponding browsers.
2.2 Web beacons and pixel tags
In addition to cookies, we may also use other similar technologies on our websites such as web beacons and pixel tags. For example, when you receive an email from Conex, it may contain a click-through URL that links to a Conex web page. If you click the link, Conex will track your visit to help us learn about your preferences for products and services and improve our customer service. A web beacon is a transparent graphic image embedded in a website or in an email. We use pixel tags in emails to find out whether an email has been opened. You can unsubscribe from the Conex mailing list at any time if you do not want to be tracked in this manner.
Your use of our website means that you agree to the use of cookies, web beacons and pixel tags as described above.
3. Third-party SDK
We will conduct strict inspections on the access to the third-party SDK, and promptly publicly explain the latest status of the access to the SDK. For details, please refer to the official privacy policy of the third-party SDK.
(a) Bugly SDK
Purposes: Provide exception reporting and operation statistics, and follow up user feedback in a timely manner
Types of personal information collected: networking, network status changes, WiFi status changes, phone status, logs
(b) WeChat SDK
Purposes: WeChat login, sharing, etc.
Types of personal information collected: device information, network information
(c) Xiaomi
Purposes: Provide message push service for Xiaomi devices
Types of personal information collected: networking, accessing network status, reading and writing external storage, WiFi status
(d) Huawei
Purposes: Provide message push service for Huawei devices
Types of personal information collected: networking, accessing network status, reading and writing external storage, WiFi status, application installation permissions
(e) Customized push notification
Purposes: to provide a push notification service
The type of personal information collected: device information, device platform, manufacturer, device brand, network information, location, application information and other related information
(f) Mob SDK
Purposes: Provide social sharing, third-party login social sharing, third-party login
Types of personal information collected: personal sensitive information, geographic location, application list information, social platform OpenID
We will not sell any personal data to any third party.
Conex shares your personal data with other partners, as described in this Policy, when services are provided by partners authorized by Conex. For example, when you make an online purchase from Conex, we must share your personal data with the logistics provider to arrange shipment or a partner to provide services. In addition, we may share personal data with Conex affiliates and subsidiaries.
To comply with applicable laws or respond to valid legal procedures, Conex may also disclose your personal data to law enforcement or other government agencies. If Conex is involved in a restructuring, merger & acquisition, or a bankruptcy or liquidation lawsuit in a given jurisdiction, your personal data may be disclosed in connection with the transaction. Conex may also disclose your data when appropriate, for example, to execute Terms and Conditions, when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or when it is in connection with an investigation of suspected or actual illegal activity.
We will take appropriate steps to protect your privacy. Whenever you provide us with sensitive information, we will take reasonable steps to protect your sensitive information, and we will also take reasonable security measures to protect the stored personal information. Unless under the laws or mandatory regulations of the government, we will not provide any of your personal information to unrelated third parties (including companies or individuals) without your consent.
We may disclose personal information due to legal requirements, or we are convinced in good faith that such practices are necessary for the following: compliance with legal notices or compliance with legal procedures applicable to our site; protection of the rights or property of our users; under an emergency situation, to protect the personal or public safety of our company and its users.
If you think that we have not complied with these principles at any time, please email philips.ddl.cn@cone-x.com to notify us. We will make every effort to improve this issue immediately within a reasonable and appropriate range.
5. How we access and control your personal data
You should ensure that all personal data submitted is accurate. Conex will try its best to maintain the accuracy and completeness of personal data and update these data in a timely manner.
When required by applicable laws, you may:
l have the right to access the specific personal data we hold about you;
l ask us to fulfill, update or correct your inaccurate personal data;
l reject or restrict our use of your personal data;
l Have the right to inquire or request to view your specific personal data;
l have the right to request a copy of your personal data;
l have the right to request to stop the collection, processing and/or use of your specific personal data;
l ask us to delete your personal data. If you want to exercise the relevant rights, please email Philips.ddl.cn@cone-x.com for support. To ensure data safety, you may need to provide a written request. If we have a reasonable basis to believe that these requests are deceptive, unfulfillable or harm the privacy of others, we will refuse to process the request.
Required by applicable laws, when Conex processes your personal data with your consent, you also have the right to withdraw your consent at any time. However, the withdrawal of consent will not affect the legality and effectiveness of our processing of your personal data based on your consent before the withdrawal, nor will it affect our processing of your personal data according to other appropriate legitimate foundations.
If you believe that our processing of your personal information does not comply with applicable data protection laws, you can contact a statutory data protection agency. Please refer to the contact information of EU data protection agencies:
http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
6. How we protect and retain your personal data
The security of your personal data is important to us. We use appropriate physical, management, and technical measures to protect your personal data from unauthorized access, disclosure, use, modification, damage, or loss. For example, we use cryptographic technologies for data confidentiality, protection mechanisms to prevent attacks, and access control mechanisms to permit only authorized access to your personal data. We also provide training on security and privacy protection for employees to raise their awareness of personal data protection. Conex is committed to protecting your personal data; however, please note that no security measure is perfect.
We will retain your personal information for no longer than is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. The data storage period may vary with scenario, product, and service. The standards we use to determine the retention period are as follows: the time required to retain personal data to fulfill business purposes, including providing products and services; maintaining corresponding transaction and business records; controlling and improving the performance and quality of products and services; ensuring the security of systems, products, and services; handling possible user queries or complaints and locating problems; whether the user agrees to a longer retention period; and whether the laws, contracts, and other equivalencies have special requirements for data retention; etc. We will maintain your registration information as long as your account is necessary for service provision. You can choose to cancel your account. After you cancel your account, we will stop providing you with products and services through your account and delete your relevant personal data, provided that deletion is not otherwise stipulated by special legal requirements.
Our websites, products and services are primarily intended for adults. A child must not create a Philips account without the consent of a parent or guardian. If a child's personal data is collected with prior parental consent, we will only use or disclose the data as permitted by law, with the explicit consent of the child's parents or guardians, or when necessary for the protection of the child. If we accidentally collect a child's personal data without verified prior consent from the child's parents, we will attempt to delete the data as soon as possible.
8. Account cancellation
You can cancel/sign off your current account at any time. After you cancel your account, we will stop providing you with related products or services. To sign off your account, please follow below steps after log in the Philips EasyKey :
Click on "Me"-"Contact us" .
Users in mainland China can cancel their personal accounts by calling our after-sales service hotline 400-8828-236; users in Hong Kong, Macau, Taiwan and overseas regions can contact us by email Philips.ddl.cn@cone-x.com to submit a request for personal account cancellation. We will delete or anonymize your personal information within 15 working days after receiving your request.
9. Third-party providers and their services
To ensure a positive user experience, you may receive content or web links from third parties other than Conex and its partners ("third parties"). Conex does not have the right to control such third parties, but you can choose whether to use the links, view the content and/or access the products or services provided by third parties.
Conex cannot control the privacy practices and data protection policies of third parties that are not subject to this Policy. When you submit personal information to such a third party, please read and refer to the privacy policy of the third party.
10. International transfers of your personal data
Your personal data collected by Conex may be processed or accessed in the country/region where you use our products and services or in other countries/regions where Conex or its affiliates, subsidiaries, service providers or business partners have a presence. These jurisdictions may have different data protection laws. In such circumstances, Conex will take measures to ensure that data is processed as required by this Policy and applicable laws, which includes when transferring the data subject¡¯s personal data from the EU to a country or region which has not yet been acknowledged by the EU Commission as having an adequate level of data protection, we may use a variety of legal mechanisms, such as signing standard contractual clauses approved by the EU Commission, obtaining the consent to the cross-border transfer of a data subject in the EU, or implementing security measures like anonymizing personal data before cross-border data transfer. When Conex and the third parties (which may or may not be Conex entity companies outside the European Economic Area) share personal data originating from the European Economic Area, we will be based on EU standard contractual clauses or other protection measures stipulated in any GDPR, to share information with the third parties.
11. Updates to this Policy
Conex reserves the right to update or modify this policy at any time. We will release the latest Privacy Policy on this page for any changes. If major changes are made to the Privacy Policy, we may notify you through different channels, for example, posting a notice on our website or sending you direct notification.
12. Contact us
If you have any questions, comments, or suggestions, or if you have any privacy complaints or questions, please email Philips.ddl.cn@cone-x.com.
When we process your personal data following this policy, we may respond to your request, contact you, provide you with products or services, or enter into a contract with you to be the controller of the relevant personal data.
Philips and the Philips Shield Emblem are registered trademarks of Koninklijke Philips N.V. and are used under license. This product has been manufactured by and is sold under the responsibility of Shenzhen Conex Intelligent Technology Co., Ltd., and Shenzhen Conex Intelligent Technology Co., Ltd. is the warrantor in relation to this product.