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LIGHTING FOR WELLNESS
Effective Date: 9.24.2021
Confirm1: If the App has integrated the ‘Try Now’ or other features representing non-login (visitor mode), if yes, please refer to the following description and if no, please delete then.
If you do not want to provide your profile data when you start to use any of the Services, you may use the App without login or creating an account, and you may still use certain Tuya services, such as searching and browsing any features on the Services. At this moment, we will not collect Personal Data about account or profile, and the collected data will be limited to those you have authorized to be collected for purpose of using the additional functions of the App and/or the Smart Devices, as well as corresponding usage information. However, if the Services you request or purchase are based on your account, please go to the registration/login page for guidance.
Before you use our Products, please carefully read through this Policy and understand our purposes and practices of collection, processing of your Personal Data, including how we use, store, share and transfer Personal Data. In the Policy you will also find ways to execute your rights of access, update, delete or protect your Personal Data.
When you accept this Policy when you register with your Personal Data, or if you start to use our Products and does not expressly object to the contents of this Policy, we will consider that you fully understand and agree with this Policy. If you have any question r regarding this Policy, please do not hesitate to contact us via:
Confirm2：please enter the contact information of corporate customer privacy office or other responsible party who deal with privacy matters.
Confirm3: Whether the customer will OEM/customize the App to your customers. If yes, please refer to the following description; if not, please delete then.
For other branded mobile applications powered by Brilli, our Clients control all the Personal Data collected through our Products. We collect the information under the direction of our Clients and the processing of such information shall be limited to the purpose of providing the service for which our Clients has engaged us. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly.
In this Policy, Personal Data means information generated, collected, recorded and/or stored, electronically or otherwise, that can be used to identify an individual or reflect the activity of an individual, either from that information alone, or from that information and other information we have access to about that individual.
Personal Sensitive Data includes personal biometric information, communication records and contents, health information, transaction information, and precise location information. When we collect Personal Sensitive Data from you, we will generate an explicit notification for your consent before we collection personal sensitive data about you.
Smart Devices refers to those computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, including: smart home appliances, smart wearable devices, smart air cleaning devices, etc.
Apps refers to those mobile applications developed by Brilli that provide end users remote control to Smart Devices and with the ability to connect to the supplier IoT Platform.
What Personal Data do we collect
In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.
1.Information You Voluntarily Provide Us
Confirm4: Determine whether the account registration/login is integrated with a third-party account system, such as WeChat or Facebook. If yes, please refer to the following description; if not, please delete then.
If you authorize login to the Products with a third party account, we will obtain from such third party your account information (such as portrait, nickname, region, gender, etc.) which may be bound with your Brilli account for quick login. We will ensure compliance with applicable data protection laws and regulations, as well as agreements, policies or documentations agreed with such third party regarding sharing personal information, in processing your Personal Data.
1)Additional functions based on location information:
When you enable the location-based functions through permission settings on your mobile device, we will collect and process your location information to enable these functions, such as pairing with your Smart Devices. Also, we may collect information about your real-time precise or non-precise geo-location when you use certain Smart Devices or the Services, such as robot cleaner and weather service.
Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/. You may reject such use of your location information by managing the permission settings in the Services, upon which we will cease to collect and use your location information.
2)Additional services based on camera:
You may use the camera to scan the code by turning on the camera permission to pair with a Smart Device, take video, etc. Please be aware that even if you have agreed to enable the camera permission, we will only obtain information when you actively use the camera for scanning codes, video recording, etc.
3)Additional services for accessing and uploading pictures/videos based on photo albums (picture library/video library):
You can use this function to upload your photos/pictures/videos after turning on the photo album permission, so as to realize functions such as changing the avatar, reporting device usage problems by providing photo proofs, etc.. When you use the photos and other functions, we will not recognize this information; but when you report a device usage problem, we may use the photos/pictures you upload to locate your problem.
4)Additional services related to microphone-based service:
You can use the microphone to send voice information after turning on the microphone permission, such as shooting videos, waking up the voice assistant, etc. For these functions, we will collect your voice information to recognize your command. Please be aware that even if you have agreed to enable the microphone permission, we will only obtain voice information through the microphone when you voluntarily activate the microphone in the App.
5)Additional services based on storage permissions:
The purpose is to ensure the stable operation of the App by utilizing the storage permission. After you give or indicate the permission to read/write your mobile device’s storage, we will access pictures, files, crash log information and other necessary information from your mobile device’s storage to provide you with functions, such as information publications, or record the crash log information locally.
Please note that if you turn on any permission, you authorize us to collect and use relevant personal information to provide you with corresponding Services. Once you turn off any permission, we will take it as canceling the authorization, and we will no longer continue to collect Personal Data based on the corresponding permissions, and the related functions may be terminated. However, your decision to turn off the permission will not affect the previous collection and use of information based on your authorization.
2.Information We Collect Automatically
Please note that one cannot identify a specific individual by using Device Information or Log Information alone. However, if these types of non-personal information, combined with other information , may be used to identify a specific individual, such non-personal information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will anonymize and desensitize such non-personal information.
Based on your consent, when you enable the geo-fence feature on the Products, your location information will be generated and shared with Google Map services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details: https://privacy.google.com/businesses/gdprservices/. You may reject such use of your location information by managing the permission settings in the Products, upon which we will cease to collect and use your location information.
3.Smart Devices Related Information:
Confirm5.2 (depending on the 5.1): Whether integrated third-party health analysis functions, such as Apple Health, Google Health, etc., if so, please refer to the following description; if not, you can delete then:
Please note that when you actively agree to enter the App name and the application is connected to the Apple Health app, we will share your measurement data with Apple Health (including only your BMI, height, weight and body fat% data). The purpose of sharing data is only to measure and analyze health-related indicators related to you, and it will never be disclosed to other third parties. You can close at any time by managing the settings page. Please enter the App name. The application is authorized to connect with Apple Health.
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about you are as follows:
If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.
Who do we Share Personal Data with?
At Brilli, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:
Except for the third parties described above, to third parties only with your consent.
International Transfer of Information Collected
Brilli will comply with applicable data localization requirements in corresponding jurisdictions with respect to storage of data. To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches:
Agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
Your Rights Relating to Your Personal Data
We respect your rights and control over your Personal Data. You may exercise any of the following rights:
Confirm6: please provide at least 2 approaches for individual user executing their privacy rights, for instance, via the privacy office email address; ***@***.com, or via the route of Feedback imbedded in the App: Me&rt;Personal Center&rt;Account and Security&rt;, etc.
You do not have to pay a fee and we will aim to respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.
1) For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notifications and other related functions;
2) In the marketing communications that you agree to, the information we send to you contains instructions that allow you to withdraw your consent in accordance with the “unsubscribe” method described in the information;
3) Unbind the Smart Device through the app, and the information related to the Smart Device will not be collected;
4) By using product with the visitor mode, we will not collect any personal data about you;
When you withdraw your consent or authorization, we may not be able to continue to provide you with the products or services correspondingly. However, your withdrawal of your consent or authorization will not affect the processing of personal information based on your consent before the withdrawal.
Confirm7: if the App enables the account deletion/termination, please fill out the route in the App to delete/terminate the account.
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Brilli provides various security strategies to effectively ensure data security of user and device. As for device access, Brilli proprietary algorithms are employed to ensure data isolation, access authentication, applying for authorization. As for data communication, communication using security algorithms and transmission encryption protocols and commercial level information encryption transmission based on dynamic keys are supported. As for data processing, strict data filtering and validation and complete data audit are applied. As for data storage, all confidential information of users will be safely encrypted for storage. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you could immediately notify us of the problem by emailing Please enter your privacy email address.
Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of thirteen (13)(or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from anyone under the age of thirteen (13) unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from anyone under the age of thirteen (13) without permission from that child’s parent or legal guardian, we will take steps to remove that information.
Lucidity Lights, Inc. (d/b/a Brilli)
Postal Mailing Address:
P.O. Box 290659
Boston, MA 02129