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LIGHTING FOR WELLNESS
Effective Date: July 1, 2022
Updated: July 1, 2022
Brilli Mobile Application
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 regarding this Policy, please do not hesitate to contact us via:
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, 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.
Apps refers to those mobile applications developed by Lucidity Lights, Inc. 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.
If the Services you request or purchase are based on your account, please go to the registration/login page for guidance.
Information based on additional functions:
In order to offer you with more convenient and higher-quality Services with optimized user experiences, we may collect and use certain information if you consent to use additional functions in the App. Please note, if you do not provide such information, you may continue to use basic Services of the App and connected Smart Devices, but certain features based on these additional functions may not be available. These additional functions may include:
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: a) real-time and precise location, for instance when you choose to use the automation scenarios for controlling your Smart Devices, or b) 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’s Data Processing and Security Terms for more details.
You may disable the collection and use of your location information by changing your mobile device settings in the location services through your mobile device operating system 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.
You may opt-out the using of camera permissions through the privacy settings within your mobile device operating system.
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.
You may opt-out the using of photo album permissions through the privacy settings within your mobile device operating system.
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.
You may opt-out the using of microphone permission microphone permissions through privacy settings within your mobile device operating system.
5) Additional services based on storage permission (Android):
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.
You may opt-out the using of storage permission: "Me - Setting - Privacy Right Setting - Switch on/off Storage".
6) Additional services based on Notification permission:
The reason why we ask you for the permission is to send you notifications about using the Smart Devices or Services, especially if you have purchased security services and you require an alert or message so that you can capture the real-time status.
You may opt-out the using of App notifications: "Me - Message Center - Setting - Switch on/off Notifications".
7) Additional services based on Bluetooth permission:
You can enable Bluetooth functions after turning on the permission, including controlling the Smart Devices, acquiring status of, discovering and configuring Smart Devices. In these functions, we will communicate with Smart Devices via Bluetooth. Please be aware that even if you have agreed to enable the Bluetooth permission, we will only use Bluetooth for communication in these scenarios: display device status on the home page and Smart Device panel; perform device control on the home page and Smart Device panel; discovering Smart Devices on the home page and the add device page, Smart Device distribution network.
You may opt-out the using of Bluetooth via through privacy settings within your mobile device operating system.
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.
Please note that we 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 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 aggregate or desensitize such information..
Purposes and legal basis for processing Personal Data
The purpose for which we may process information about you are as follows:
Provide You with Our Services: We process your account data, mobile device information, usage data, location information, and Smart Device related information to provide you with the Services that you have requested. The legal basis for this processing is to perform our contract with you according to our service agreement - https://www.bebrilli.com/pages/eula.
Improve Our Services: We process your mobile device information, usage data, location information and Smart Device related information to ensure the functions and safety of the Services, to develop and improve the Services, to analyze the efficiency of our operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our service agreement - https://www.bebrilli.com/pages/eula.
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 Lucidity Lights, Inc., we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:
(a) Comply with applicable law, regulation, legal process, or lawful governmental request;
(b) Enforce our User Agreement and other agreements, policies, and standards, including investigation of any potential violation thereof;
(c) Protect our operation and business systems;
(d) Protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law; or
(e) Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.
Except for the third parties mentioned above, we only disclose your Personal Data to other third parties with your consent.
International Transfer of Information Collected
Lucidity Lights, Inc. 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:
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:
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.
Withdrawal of consent Confirm the following details: We will exercise your privacy right to withdraw consent through the following approaches:
1) For privacy permissions acquired through device system settings, your consent can be withdrawn by changing device permissions, including Confirm: location, camera, photo album (picture library/video library), microphone, Bluetooth settings, notification settings and other related functions;
2) You may opt-out the non-marketing communication through “Me - Message Center - Notification Settings” to manage your selection;
3) You may opt-out the data analysis features through “Me - Settings - Privacy Settings”;
4) You may opt-out the Personalization feature through “Me - Settings - Privacy Settings - Personalization”;
5) Unbind the Smart Device through the App, and the information related to the Smart Device will not be collected;
When you withdraw your consent or authorization, we may not be able to continue to provide you with certain 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.
About Deletion of the Account: You can find the Delete function through “Me - Settings - Account and Security - Delete Account” (Deactivate Account）
We use commercially reasonable physical, administrative, and technical safeguards to preserve the integrity and security of your Personal Data. Lucidity Lights, Inc. provides various security strategies to effectively ensure data security of user and device. As for device access, Lucidity Lights, Inc. 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 email@example.com.
We process your Personal Data for the minimum period necessary for the purposes set out in this Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data.
When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.
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 any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information..
Lucidity Lights, Inc.