Foreword

HONOR CHOICE Rethguado Pawphone (hereinafter collectively referred to as "the Product" or "the Service") is a smart device designed specifically for pet-owning households for precise positioning, integrating real-time pet location tracking, electronic fence alert, pet health status monitoring and abnormal situation alarm. The Product needs to be paired with the PawGlow application (hereinafter referred to as "the App") on your mobile device (Android system or iOS system). PawGlow is provided by Anhui Xinshiyun Technology Co., Ltd. (hereinafter referred to as "we", "our Company" or "the Company"). We respect your privacy and value the trust you place in us when providing your personal information.

You hereby declare and warrant that you are an adult when you start using the Product (or Service). If you are a minor, you may only use the Product (or Service) and agree to the relevant terms with the consent of your legal guardian.

Through this Privacy Policy, we hope to explain to you how we collect, use, store, share and transfer your personal information when you use the Product and the supporting App, as well as how you can access, update, delete and protect such information. Before using the Product and the supporting App, please read and fully understand all contents of this Privacy Policy carefully, and ensure that you use our products or services only after you fully understand and agree to them. Once you start using the Product and the supporting App, it means that you have fully understood and agreed to this Privacy Policy, and consent to our collection, use, storage and sharing of your relevant information in accordance with the terms of this Privacy Policy.
Table of Contents:
1. Information We Collect and How We Use It
2. Legal Basis
3. Storage Location and Retention Period of Information
4. Methods of Sharing, Transfer and Disclosure of Personal Information
5. Personal Information Protection Measures
6. Ways to Exercise Your Rights
7. Special Provisions on Children's Personal Information
8. Changes and Revisions to the Privacy Policy

If you have any questions, comments or suggestions about this Privacy Policy, you can contact our customer service via email: nvc@ahnvccn.com. We have appointed a Data Protection Officer (DPO) in accordance with EU laws and regulations. If you have any questions or needs, you can contact us at: nvc@ahnvccn.com.

1. Information We Collect and How We Use It
(1) Core Functions Requiring Your Authorization for Us to Collect and Use Personal Information
(a) Registration and Login
In accordance with regulatory requirements and contract performance needs, you need to provide your mobile phone number/email address, username and password for account creation, login verification and security protection; refusal to provide will make it impossible for you to register an account.
With your explicit consent, the login function will obtain the mobile phone number through the local operator, only for convenient login. Refusal of authorization allows you to choose other login methods without affecting the use of the Product.
You may voluntarily provide your nickname, avatar, as well as your pet's name, gender, weight, type, breed, birthday and other information for personalized services. Refusal to provide will not affect the use of basic functions.
When redeeming physical prizes in operational activities, we will only provide the necessary contact information to the logistics service provider for prize delivery.
You can modify your account information and cancel your account through the App "My -> Avatar"; after account cancellation, we will immediately stop using and delete relevant information or anonymize it, except as otherwise required by law.
(b) Device Binding
After logging into the App, you can complete device binding by scanning the QR code. To achieve binding for some models, we will collect location information (only used to obtain the WiFi list), WiFi network information, on/off/network connection status of the device and mobile phone, device/mobile phone model, system version, and local storage space of the mobile phone. The above information is only uploaded to compliant servers to prevent unauthorized access and ensure the security of device use.
You can unbind the device through "Device -> Device Information -> Unbind Device", and synchronously delete all personal information associated with the device.
(c) Making Phone Calls
After the device is bound, you can add family sharing members to the Product through the App, and the family sharing members can make calls to the device to realize two-way calls between the mobile phone and the device. For this purpose, we request access to your contact list permission. Apart from this, we will not obtain your contact list without permission.
(d) Use of Location Services
Location information services include the following functions:
(1) View Location and Track: When you click the location button on the map page of the App, the company's server will send a location command to the Product. After the Product obtains the location through GPS, base station or Wi-Fi positioning, it will report the location information to the company's server. You can enter the track map to view the track of the Product on the day, and you can also switch by date to view past historical tracks. In order to show you the location and movement track of the locator, the App stores the historical track information of the locator on the server, which is saved on the company's server and can only be viewed by you through the App.
(2) Add Safe Zone: You can specify the corresponding location as the center of the safe zone of the Product through search, and set the scope of the safe zone; to facilitate your setting of the safe zone, you can also set it according to your current location. For this purpose, we need to obtain the location information of you and/or the Product at that time. Before that, we will prompt you through a pop-up window and obtain your consent, and display it as a recommended item for the safe zone you want to add; you can mark and name the safe zone, such as home, park, etc.
(e) Audio Playback Function
To realize the function of the App remotely playing audio files to the Product (such as for remotely calling the pet/playing music to the pet), we will collect the following information:
- The audio data itself (i.e., the prompt tone file/music file for playback);
- The device identifier of the Product (such as IMEI, device ID, etc.), to ensure that the audio file is accurately transmitted to the corresponding device.
- The above information is only used to realize the functions of remote calling and playing music to pets, and will not collect any personal identity information, location track records or other sensitive data related to user privacy. We use encrypted transmission technology to ensure the transmission security of audio data between the App and the locator, and will not use such data for other scenarios outside the function, nor share it with third parties.
(f) Sports and Health Monitoring Function
- To realize the sports and health monitoring function, we will collect the following information:
- Data collected by the device (such as activity level, sleep duration, etc.);
- The device identifier of the Product (such as IMEI, device ID, etc.), to ensure that the data is accurately associated with the corresponding device.
- The above information is only used to analyze and display the pet's health status and activity rules, and will not collect any personal identity information, location track records or other sensitive data related to user privacy. We use encrypted transmission technology to ensure the transmission security of data between the App and the Product, and will not use such data for other scenarios outside the function, nor share it with third parties.
(g) Family Sharing
- If you choose the family sharing function, we will collect your user information (binding relationship) and your device information (binding relationship) to display and manage the currently bound users on the family sharing page of the PawGlow App, and support sharing the device with new users. We will encrypt and upload the mobile phone number of the family member or friend you share to the server to realize the sharing of the locator device with friends, and will not use such data for other scenarios outside the function, nor share it with third parties.
(h) Pet Finding Contact Code
When the pet owner sets the phone information in the pet finding contact code, we will collect the pet's nickname/breed of the bound device and the phone information you set. When the pet is lost, other people scanning the QR code will display the phone information you filled in, so as to contact you in a timely manner. Because the collection of the above information is necessary to realize this function, refusal to provide the information will only make you unable to use the above function, but will not affect your normal use of other functions.
(i) Normal Use, System Failure Analysis and Security Protection
To ensure the normal use of the Product, timely resolve faults occurring during use, and protect transaction security and system operation security, we need to carry out necessary firmware upgrades. With your authorization, we may collect log information used by the Product (operation logs, service fault information, crash log information), hardware version model, operating system version number, unique device identifier (IMEI), network connection status (SIM card/WIFI).
To improve the security of your use of the services of us, our affiliated companies and partners, protect the personal and property safety of you, others or the public from infringement, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, cyber attacks, cyber intrusions and other security risks, and more accurately identify violations of laws and regulations, we may use or integrate your hardware information, App usage information, and information shared by our affiliated companies and partners with your authorization or in accordance with the law, for identity verification, detection and prevention of security incidents, and take necessary recording, auditing, analysis and disposal measures in accordance with the law.

2. Legal Basis
2.1 We process your data in accordance with the following regulations:
(a) General Data Protection Regulation (GDPR);
(b) Other national laws where applicable, which may include the laws of the country or region where you reside.

2.2 Data Categories
In accordance with the provisions of the GDPR, we process the above categories of data as follows:

(a) Registration data and account information: in accordance with Article 6(1)(a) of the GDPR (i.e., data you have consented to be processed) and Article 6(1)(b) of the GDPR (data necessary for the performance of our contractual obligations);

(b) Other information: in accordance with Article 6(1)(a) of the GDPR (i.e., data you have consented to be processed), Article 6(1)(b) of the GDPR (data necessary for the performance of our contractual obligations) and Article 6(1)(f) of the GDPR (processing necessary for the purposes of the legitimate interests pursued by us or a third party);

(c) If the processing of your data is to comply with our legal obligations, we will process your data in accordance with Article 6(1)(c) of the GDPR.

3. Storage Location and Retention Period of Information
Cross-border Transfer of Personal Information
Within the scope permitted by law, personal information will only be stored locally, and will not be transferred across borders without your explicit consent or authorization.
Please note that the privacy laws of some countries may differ from those of your country of residence. In such cases, the Company will still process information in accordance with the data and privacy laws and regulations of your local area and the manner described in this Privacy Policy, and take necessary measures (such as high-level encryption measures) to ensure compliance with applicable data protection legal requirements when transferring and processing your information.
Retention Period of Personal Information
We will ensure that your personal information is fully protected through anonymization, encrypted storage and other methods.
We will only retain your personal information for the period necessary to achieve the purposes described in this Privacy Policy, as well as within the time limit prescribed by the laws and regulations of various countries and regions. Even if there are other contrary agreements in this Agreement, we may retain other information related to you within the period necessary to achieve the purposes described in this Privacy Policy, which may include retaining your other information for the necessary period after you cancel your account, to maintain our legitimate business interests, conduct audits, perform and prove compliance with legal obligations, resolve disputes and enforce our agreements.
If we cease the operation of relevant products or services, we will immediately stop collecting your personal information, inform you of the cessation of operation through individual notice or announcement, and delete or anonymize the stored personal information.

4. Methods of Sharing, Transfer and Disclosure of Personal Information
(1) Information Sharing
Except for the following circumstances, we will not share your personal information with any company, organization or individual:
a) In accordance with the provisions of laws and regulations, or for the needs of resolving litigation, disputes, etc., or in response to the legitimate requirements of administrative or judicial authorities, we may share your personal information externally.
b) With your explicit consent, we may share your personal information with other parties.
c) If an affiliated party provides services to you or us, we will share your personal information with the affiliated company after obtaining your consent in accordance with legal requirements. However, we will only share necessary personal information, and the processing of your information by the affiliated party must comply with the terms of this Privacy Policy. If the affiliated party intends to change the purpose of processing personal information, it must obtain your authorization and consent again.
d) Without your explicit authorization and consent, we will not share your personal information with third-party advertisers, application developers, open platforms or other partners. We may provide aggregated information, anonymized information or other information that cannot identify your personal identity to these partners. For example, we may inform the application developer of the number of installations of the application it developed.
e) To achieve the purposes described in this Privacy Policy, we may share your personal information with suppliers, service providers, consultants or agents to provide better customer service and user experience. These partners may provide us with technical infrastructure services, analysis of service usage, evaluation of advertising and service effects, customer service and payment services, academic research and surveys, or legal, financial and technical consulting services. For example, we may invite registered users to participate in lottery activities from time to time. If you win the prize, we need to provide your personal information to the logistics service provider to deliver the prize to you.
f) For companies, organizations or individuals with whom we share personal information, we will sign a strict data protection agreement with them (such as SCCs clauses, standard contract clauses, etc.), requiring them to process personal information in compliance with laws and regulations in accordance with the terms of the contract, this Privacy Policy and other relevant confidentiality and security measures.
(2) Information Transfer
Except for the following circumstances, we will not transfer your personal information to any company, organization or individual:
a) With the development of the company's business, we and our affiliated companies may undergo mergers, acquisitions, asset transfers or other similar transactions. If the relevant transaction involves the transfer of your personal information, we will require the company, organization or individual that newly holds your personal information to comply with the terms of this Privacy Policy; if the other party intends to change the processing purpose, it must obtain your authorization and consent again.
b) With your explicit consent, we will transfer the collected personal information to other parties.
(3) Information Disclosure
We will only publicly disclose your personal information under the following circumstances:
a) With your explicit consent.
b) Under the mandatory requirements of laws, litigation or government authorities, we may publicly disclose your personal information.
c) Other circumstances stipulated by laws and regulations.

5. Personal Information Protection Measures
In the process of transmitting the information of the company's products to the server, storing data and sharing information with third parties, we all adopt international standard or prevailing technical and management measures. For example, when transmitting sensitive information, we will use encryption technology to ensure information security; when sharing information with third parties, we will take reasonable and appropriate measures to ensure that the partner responsibly protects and uses your information.

However, please note that no product, software or data transmission process can guarantee 100% security. In the unfortunate event that the physical, technical or management security protection measures are damaged, we will immediately launch an emergency plan to prevent the expansion of the security incident, and report to the relevant national competent authorities within the time limit required by laws and regulations. At the same time, we will timely inform you of the basic situation of the security incident, the possible impact, and the response measures we have taken or plan to take through reasonable and effective methods such as push notifications and announcements.

Although we have taken corresponding measures to protect the security of your products and information, the company cannot guarantee the absolute security of any information you use the company's products or provide to us. Your use of the company's products also requires you to bear the corresponding risks.

6. Ways to Exercise Your Rights
During the use of the Product, you can access and manage your personal information in the following ways:

(1) Access, Copy and Update Personal Information
You can log in to the user center through the company's official website to query and modify your account information and relevant information you have submitted, including password, gender, age, date of birth, hobbies, marital status, etc.
If you need to copy your personal information, you need to contact us in accordance with Article [6] of this document, and we will reply within 30 working days.
(2) Delete Personal Information
In the following circumstances, you have the right to request the company to delete your personal information:
a) We collected personal information without your explicit consent;
b) We processed personal information in violation of laws and regulations;
c) We used and processed personal information in violation of our agreement with you;
d) You have cancelled the enterprise account, uninstalled or stopped using our products (or services);
e) We have terminated the provision of services to you.
You can contact us via email nvc@ahnvccn.com to apply for the deletion of personal information, and we will reply within 30 working days. When we delete your personal information from the server, we may not immediately delete the corresponding data in the backup system, but will complete the deletion operation when the backup is updated.
(3) Cancel Personal Account
You can log in to the company's user center at any time to complete the enterprise account cancellation procedures. Please note that once you choose to cancel the enterprise account, the account will no longer be available, and the relevant account information will be deleted. You will no longer be able to log in to the company's various services through this account (but it will not affect the services and functions you can use without logging in to the account).
After the account is cancelled, except for the relevant information we are required to retain by laws and regulations, we will stop providing the corresponding products (or services) to you, and delete or anonymize your personal information within 10 working days.
(4) Withdraw Consent or Authorization
You can withdraw your consent to the collection and use of personal information by turning off device functions. For example, for this Product, you can turn off the GPS location information collection permission through the setting function of your mobile phone.
Please understand that the realization of each business function depends on some basic personal information (see Article 1 of this Privacy Policy for details). When you withdraw your consent or authorization, we will no longer be able to provide you with the services corresponding to the withdrawn consent or authorization, and will no longer process the relevant personal information. However, your decision to withdraw consent will not affect the personal information processing activities completed before based on your authorization.

6. Special Provisions on Children's Personal Information
The company's products are intended for adults or persons defined as minors or children in the relevant jurisdiction who have obtained permission from their parents or legal guardians. Minors and children may not create an account independently without the consent of their parents or guardians. Unless otherwise explicitly stated, this Service is intended for the general user group and is not specifically designed for minors and children. In the process of providing services, we will not intentionally solicit or collect personal information from minors and children without parental consent. If we find that we have collected children's personal information without parental consent, we will either seek retroactive consent from the parents or immediately delete the relevant information. If you believe that a child has provided us with personal information without parental consent, please contact us via email: nvc@ahnvccn.com.

7. Changes and Revisions to the Privacy Policy
This Privacy Policy may be adjusted according to the actual situation. We will not limit your rights under this Privacy Policy without your explicit consent.
If there are material changes to this Privacy Policy, we will notify you in a prominent manner (for example, through a pop-up prompt when the App is updated or upgraded, or when you log in again).
Material changes referred to in this Policy include but are not limited to:
a) Major changes in our service model, such as changes in the purpose of processing personal information, types of processing, usage methods, etc.;
b) Major changes in control rights, such as ownership changes due to mergers, acquisitions, reorganizations, etc.;
c) Changes in the main objects of personal information sharing, transfer or public disclosure;
d) Major changes in your rights to participate in personal information processing and the ways to exercise them;
e) Changes in the department responsible for personal information security, contact information and complaint channels;
f) A personal information security impact assessment report shows that there is a high risk.

List of Personal Information Shared with Third Parties: