Privacy Policy

X Lights Ltd

Address: 44 Heritage Bay, Heritage Pointe - T1S 4H8, Canada

Contact Email: info@xlightsled.com

Contact Phone: +14038037974

This Privacy Policy respects and protects the personal privacy of all users using our network services. It sets out how we collect, use, disclose, transmit and store your information. We will handle your information with a high standard of care and prudence. This Privacy Policy may be updated periodically. By accepting the App Service User Agreement, you acknowledge and agree to be bound by the full content of this Privacy Policy, which forms an integral part of such Agreement.

You are not obligated to provide the personal information we request. However, in many cases, failure to provide such information may prevent us from delivering our products and services to you or responding to your inquiries.

1. Information We Collect

We collect only information necessary to implement product functions, adhering to the principles of lawfulness, legitimacy and necessity. Personal information we collect mainly comes from three sources: information you provide voluntarily, information obtained when you use our products or services, and information about you shared by third parties.

We collect and use your personal information to enable the product functionalities described below. If you decline to provide relevant information or withhold consent for collection, you may be unable to register as our user, access certain services, or receive optimal service experience.

1.1 Account Registration & Login Information

When registering an account, you provide your mobile phone number and login password. If you choose third-party account login, we may obtain your avatar and nickname associated with such third-party accounts (including QQ, WeChat, Weibo or other supported platforms, subject to actual integration for specific products and services).

Purposes for collecting account information: (1) Account management to deliver better services and support cross-device synchronization of your data after login; (2) Enabling account recovery and password retrieval if you bind valid contact details such as mobile number, QQ ID, WeChat ID or Weibo ID; (3) Conducting de-identified statistical analysis to understand user behaviour, continuously improve our products, service quality and user experience.

1.2 Information You Submit to Customer Service or for Activities

You may provide your contact information when contacting customer service or participating in our campaigns, so we can reach you promptly to address feedback or share event updates.

1.3 Device Information

Device information refers to data from the device you use to access our products and services. To ensure compatibility between our services and your device and deliver security capabilities, we collect: device name, model, device identifier, operating system, application version, language settings, screen resolution, and network operator ID (PLMN).

This data supports bug analysis, stable operation of our services, product optimisation and account security protection. Except as expressly stated in this Policy, we will not share your device information with third parties. We cannot guarantee that unaffiliated third parties will not independently obtain your device information through other channels and combine it with other data to identify you. Any losses arising from such conduct shall be claimed against the relevant third party. Collection of device information is fundamental to service provision; disabling such collection may result in service malfunctions.

1.4 Location Information

Location information is gathered only when you enable device location permissions and use location-dependent services. When location services are activated, we may collect and process your geolocation via GPS, Wi-Fi or other technologies. Precise location data constitutes sensitive personal information; we will only collect such data when required to support specific product features.

Location data also includes geographic information shared by you or other users: location content uploaded by any party showing current or historical whereabouts, and geographic tags embedded within shared photos.

You may disable location access via device settings or within our product, but this may disable location-based functions.

1.5 Log Information

For service security, our system may automatically collect data via Cookies or comparable technologies and store it in server logs, including:

• Your interaction records with our services: search terms, visited page addresses, browsed content and service requests;
• Software and device details: software version, browser type, and installed mobile applications (collected as required to secure your operating environment);
• Device event data: application crashes, system activity logs and other related diagnostics.

1.6 Additional Information Collected with Your Consent

Certain features may require specific sensitive personal information to function. Refusal to provide such data will disable corresponding functions but will not affect your use of other service features. These functions include: (1) Camera access: enables photo capture, video recording, QR code scanning and facial recognition. We may expand facial recognition scenarios in the future and will seek your separate consent before using facial information for new extended functions. (2) Album/photo library access: allows you to view, edit and upload photos and videos. (3) Microphone access: supports audio recording and voice interaction; we collect audio recordings to process voice commands and implement relevant features. (4) Contacts access: lets you conveniently retrieve contact information without manual input. (5) Calendar access (read/write): supports memo creation and reminder functions. (6) Local file access: enables you to open, edit and upload files stored on your mobile device.

You acknowledge and agree that the above functions require permission to access your camera, album, microphone, contacts and calendar on your device. We will obtain your explicit consent via pop-up notices or equivalent prominent prompts prior to collecting sensitive personal information. By voluntarily supplying sensitive personal information, you consent to our processing in accordance with the purposes and methods outlined in this Policy.

1.7 Information About You Shared by Third Parties

This covers two scenarios: (1) Content posted by other users which may contain your personal information; (2) Data generated or shared when you use third-party partner services. When logging in via Weibo, QQ or other third-party accounts, we verify your identity and link the third-party account to our services upon your authorisation.

2. How We Use Collected Information

We process your information in compliance with applicable laws and our agreements with users. We will seek additional consent if we intend to use your data for purposes outside those listed below:

1. Cater to personalised preferences, including language settings, location configurations and tailored support services;
2. Deliver services, develop products and optimise performance (e.g. analysing crash logs to resolve system faults);
3. Provide security safeguards: identity verification, fraud prevention, data backup and account protection;
4. Recommend advertisements and content that may interest you;
5. Measure and improve the effectiveness of our advertising and marketing campaigns;
6. Manage software: certification, version upgrades and maintenance;
7. Invite you to participate in user experience surveys;
8. Collect and use your information without requiring your authorisation where permitted by applicable laws, including:

• Matters related to national security and national defence;
• Matters involving public safety, public health and major public interests;
• Criminal investigation, prosecution, trial and enforcement of judgments;
• Protecting vital legitimate interests (life, property safety etc.) of you or other individuals where consent cannot be reasonably obtained;
• Ensuring stable and secure operation of our products/services, including troubleshooting failures;
• Legitimate news reporting;
• Statistical or academic research undertaken by research institutions for public benefit, provided published results contain de-identified data;
• Other circumstances stipulated by law.

1. Other purposes authorised by you.

Subject to legal requirements and your consent, we may use data collected from one service to enhance other services, such as displaying personalised content or advertisements within different products, and conducting user research and statistical analysis.

To maintain service stability and analyse application performance, we may record metrics such as usage frequency, crash data, overall performance and installation sources. We will not combine anonymised analytics data with personally identifiable information you submit within the application.

3. Sharing, Transfer and Public Disclosure of Your Personal Information

We recognise our legal liabilities arising from unauthorised sharing, transfer or public disclosure of personal information. All relevant activities shall comply with the following provisions:

3.1 Sharing

We will not share your personal information with any company, organisation or individual except under the circumstances below:

1. Sharing authorised by your explicit consent;
2. Sharing required by judicial or administrative authorities;
3. Sharing with our affiliates: only necessary personal information will be shared, bound by the purposes stated in this Policy. Affiliates shall obtain fresh consent if they intend to change processing purposes;
4. Sharing with authorised partners: to deliver services specified in this Policy. We share only information essential for service provision for lawful, specific and clearly defined objectives. Partners may not use shared data for any other purpose.

We execute strict confidentiality agreements with all receiving parties, requiring them to process personal information in line with our instructions, this Privacy Policy and applicable security safeguards.

3.2 Transfer

We will not transfer your personal information to external entities unless:

1. The transfer receives your explicit consent;
2. In the event of merger, acquisition or bankruptcy involving transfer of personal information. We will require the successor entity to continue abiding by this Privacy Policy; otherwise, the successor must obtain your renewed authorisation.

3.3 Public Disclosure

We may publicly disclose your personal information only in the following cases:

1. Disclosure of specified information in a manner you explicitly approve;
2. When required by applicable laws, mandatory administrative enforcement or judicial orders. Where permitted by law, we will verify formal legal documents (subpoenas, investigation notices etc.) prior to disclosure.

4. Protection of Your Personal Information

1. We implement industry-standard security controls to prevent unauthorised access, disclosure, misuse, alteration, loss or destruction of your data. Protective measures include SSL encryption for data transmission, HTTPS access, data encryption technology, anti-malware protection, access permission controls and regular privacy and security training for staff.
2. We minimise collection to only necessary personal information. Unless you provide written permission, we retain your personal information for 36 months after account deletion or cancellation. Upon expiry, data will be anonymised or securely destroyed.
3. The internet is not an entirely secure environment. Emails, instant messages and peer-to-peer communications are not encrypted. We strongly advise against transmitting sensitive personal information via these channels and recommend using complex account passwords.
4. We strive to secure all data you submit, but absolute security cannot be guaranteed. If security failures occur due to breaches of our physical, technical or administrative safeguards resulting in unlawful access, tampering or leakage causing damages to you, we shall bear corresponding legal liabilities.
5. In the event of a personal information security incident, we will notify you promptly. Notifications will cover incident overview, potential impacts, remedial measures, risk mitigation suggestions and support channels. We will notify users via email, letter, telephone or in-app push; where individual notification is impracticable, we will issue public announcements. We will also report incidents to relevant regulators as required.

5. Your Rights to Manage Personal Information

1. You may access, amend or delete your registration data and other personal information through service interfaces or by contacting us in accordance with guidance. Available operations depend on the specific services you use. For example, you may disable location sharing via device settings for location-based functions. Please review relevant operating guidelines carefully.
2. We process your information solely for the purposes defined in this Policy. You may request deletion if you discover we collect or use your personal information in violation of laws, regulations or our agreement. You may request correction if stored personal information is inaccurate. We may conduct identity verification before processing access, correction or deletion requests to protect account security.
3. We may decline to fulfil your requests where:

• Requests relate directly to national security, national defence, public safety, public health or major public interests;
• Requests relate to criminal investigation, prosecution, trial or judgment enforcement;
• Sufficient evidence demonstrates malicious or abusive exercise of rights;
• Fulfilment would seriously harm legitimate interests of you or other persons and organisations;
• Requests involve trade secrets.

6. Children’s Personal Information

Our products, websites and services target adult users. Minors under the age of 16 may not register accounts without parental or guardian consent. Where we collect minors’ personal information with valid guardian consent, we will only use or disclose such data when required by judicial/administrative authorities, with renewed guardian consent, or to protect the minor.

If we learn we have collected a minor’s personal information without verifiable prior guardian consent, we will take reasonable steps to delete such data promptly.

7. Updates to This Privacy Policy

This Privacy Policy may be revised from time to time. We will not reduce your rights established under this Policy without proper notice. Updated versions will be published on this page, and material changes will be notified via pop-up windows or equally prominent prompts. Your continued use constitutes acceptance of the revised Policy.

Contact Information

X Lights Ltd

Address: 44 Heritage Bay, Heritage Pointe - T1S 4H8, Canada

Contact Email: info@xlightsled.com

Contact Phone: +14038037974