Qutewear Privacy Policy

Welcome to Qutewear! This Privacy Policy is designed to transparently explain how we collect, use, store, share, and protect your personal information when you use Qutewear smart wearable devices (hereinafter referred to as 'Devices'), companion applications (hereinafter referred to as 'App'), and the official website.

This policy is formulated and released by Xiamen Meiya Zhongmin Technology Co., Ltd. as the personal information processor. Qutewear is committed to providing a safe and reliable multimodal intelligent experience for global users, strictly following global mainstream privacy protection frameworks, including but not limited to the EU General Data Protection Regulation (GDPR), the US California Consumer Privacy Act (CCPA/CPRA), as well as the 'Personal Information Protection Law of the People's Republic of China' and 'Network Data Security Management Regulations' and other Chinese laws and regulations. For users in mainland China, the rights and obligations under this policy shall preferentially apply the laws of the People's Republic of China.

Special Note: Bystander Privacy and Responsibility for Compliant Use

Qutewear is a multimodal smart wearable device that integrates photo, video, and audio recording functions. When using these functions, you may inadvertently collect personal information from third parties, such as their voices or facial images. We strongly remind you that when using the device for audiovisual recording, please strictly respect the legal rights of others, including their right to privacy and portrait rights. Please use these functions with caution in private places without permission and strictly abide by local laws and regulations. Any privacy disputes caused by the user's non-compliant use will be the sole legal responsibility of the user.

1. Information We Collect

We strictly follow the 'minimum necessity' principle and only collect information essential to achieving the core functions of the product. Among them, audiovisual materials, location information, and voice interaction content are sensitive personal information, and we will obtain your separate explicit consent in accordance with the law.

1.1 Account Information

When you register for a Qutewear account, we will collect your email address or mobile phone number for account creation, identity verification, login notifications, and customer service communication, which are basic personal information.

1.2 Device and Connection Data

To achieve stable pairing, connection, and data synchronization between the phone and Qutewear hardware, we will apply for Bluetooth permission and collect the device hardware serial number, IMEI, OAID, MAC address, phone operating system version, and Bluetooth connection status information for ensuring hardware-software synergy and troubleshooting.

1.3 Media Assets and File Permissions

To achieve core functions such as device photography, video recording, audio recording, and subsequent AI audiovisual analysis, we will apply for microphone permission and system album/storage permission after obtaining your separate explicit consent. The media assets such as photos, videos, and audio recorded through the device are only stored locally on the device by default. The automatic synchronization to the cloud function is turned off by default and requires your proactive manual activation: only when you proactively upload a single piece of material in the App, or you explicitly turn on the 'Automatic Sync / Upload' function, will the relevant material be synchronized to the Timeline in the App and our cloud server for subsequent cloud storage and multimodal AI intelligent analysis.

1.4 Location Information (Optional)

After you proactively authorize, we will collect your location information to add space-time tags to the recorded content and automatically adapt to the local time zone. Location information is sensitive personal information. You can turn off the permission in the system settings at any time. After turning it off, the corresponding function will not be available, but it will not affect other core services.

1.5 AI Interaction Data and Commitment to No Use for Model Training

Voice input, text instructions, and multimodal analysis results generated when you use AI and other intelligent functions are used to respond to your instructions and optimize the effect of AI services. We are deeply aware of the privacy of your personal memory data and hereby solemnly promise: without your separate explicit consent, we will never use any of your audiovisual materials, text instructions, and AI interaction data for any public or third-party AI foundation large model training.

1.6 Transaction and Subscription Payment Information

When you purchase our software subscription service (such as monthly/annual membership) or value-added functions, we will collect your order transaction records, transaction time, purchased goods/service content, and payment status. All the above payments are completed independently and securely by trusted third-party payment channels (such as WeChat Pay, Alipay, Apple Pay, etc.). We only receive the payment results returned by them to activate the rights. The platform itself will not collect or retain your plaintext bank card number, payment password, and other sensitive financial information.

1.7 Localization Setting Preferences

Your independently chosen language, time zone, currency, and unit preferences are used to adapt to your usage habits and optimize the interface display.

1.8 Operation and Fault Logs

To ensure the stability and security of the service, we will collect crash logs and operation exception information of the device and the App. This type of information is only used for troubleshooting and performance optimization and is not associated with your identity-sensitive content.

2. How We Use Your Information

We only use your personal information within the scope of achieving product functions and fulfilling legal obligations. Specific usage scenarios include:

2.1 Service Provision and Optimization

Maintaining the synergistic operation of hardware and software, processing audiovisual materials, and providing multilingual transcription, content recognition, and cross-modal AI intelligent analysis; optimizing product functions and user experience based on anonymized statistical data. All cloud AI computing processing is carried out under strict data protection protocols to ensure the exclusive purpose of data processing.

2.2 Globalization and Localization Adaptation

Automatically matching the corresponding time zone timestamp, currency format, measurement unit, and language interface according to your registration region and system settings.

2.3 Security and Troubleshooting

Monitoring the running status of the device and account, analyzing crash logs to improve system stability; identifying abnormal logins and malicious operations to prevent security risks and protect your account and data security.

2.4 Compliance and Legal Needs

Complying with applicable laws, regulations, legal procedures, or mandatory government requirements to fulfill statutory obligations.

3. Data Storage and Cross-Border Transfer

3.1 Regional Storage Strategy

We adopt a strict data regionalization storage strategy to meet the compliance requirements of different jurisdictions worldwide:

• Personal information of users in mainland China is encrypted and stored in compliant data centers within the People's Republic of China.
• Personal data of users in other countries/regions will be encrypted and stored in corresponding regional compliant data center nodes (such as EU nodes, North American nodes, Asia-Pacific nodes, etc.) according to your registration place or actual place of residence.

3.2 Information Storage Period

We only retain your personal information for the shortest period necessary to achieve the functions:

• Basic account information: Retained until 15 working days after you proactively cancel the account, then deleted.
• Device and connection data: Deleted within 15 working days after the device is unlinked from the account.
• Audiovisual, location, and other media materials: Retained until 15 working days after you proactively delete the corresponding content or cancel the account, then deleted.
• AI interaction data: Retained until 15 working days after you cancel the account, then deleted.
• Order and transaction records: Retained to the statutory minimum period in accordance with legal and financial compliance requirements, then deleted or anonymized.
• Operation fault logs: The retention period does not exceed 6 months.

If laws and regulations have other provisions on the information retention period, we will follow their provisions. After the retention period expires, we will completely delete or anonymize your personal information.

3.3 Cross-border Transfer Rules

We adhere to the principle of 'Local Data, Local Processing' and implement differentiated data processing strategies based on the user's jurisdiction:

• For users in mainland China: Your personal information will be stored and processed entirely within the People's Republic of China, and there is no provision or transfer of personal information to overseas parties.
• For users in other countries / regions: Your personal information will be stored and processed in compliant data centers within your respective region; if cross-regional transfer is indeed necessary, we will strictly follow local cross-border data laws and regulations (such as EU Standard Contractual Clauses SCC, relevant regional security assessments, etc.) and adopt security technical measures such as encryption and de-identification.

4. Data Sharing and Third-Party Services

We never sell or rent your personal information to any third party. We may only share information in the following necessary circumstances in accordance with the law:

4.1 Third-Party Service Providers (SDK)

To achieve necessary functions such as message push, cloud storage, AI computing support, and third-party channel payment, the App may access trusted third-party service providers. We will conduct a strict security assessment of third-party services, disclose the third-party name, type of collected information, purpose of use, and data export situation to you through the 'Third-Party Sharing List' in the App, and require third parties to strictly abide by this Privacy Policy and relevant confidentiality agreements and fulfill data security protection obligations.

4.2 Legal Compliance Disclosure

When required by applicable laws, regulations, legal procedures, or mandatory government requirements worldwide, we may disclose personal information within the necessary scope. We will only disclose the minimum information necessary to achieve the purpose and conduct a compliance review of the disclosure behavior in accordance with the law.

5. Your Personal Information Rights

No matter where you are, we guarantee your legal control over your personal information. You can exercise the following rights by contacting customer service in the App, and we will verify and process them within 15 working days after receiving your request:

5.1 Right of Access and Correction

You can view and update your account information and basic information in the App at any time; if you find that the personal information we process is incorrect, you can apply for correction.

5.2 Right to Withdraw Consent

You can turn on or off individual permissions such as Bluetooth, microphone, album, and location in the system settings at any time to withdraw your consent to the corresponding information collection. Withdrawing consent does not affect the effectiveness of information processing activities already carried out based on your consent.

5.3 Right to Data Portability

You have the right to apply for a copy of your personal information, and we will provide it to you in a structured, commonly readable electronic format to support you in transferring data to other service providers. You can submit an export application through the customer service channel in the App, and we will complete the verification and delivery within 15 working days.

5.4 Deletion Right and Account Cancellation

You can submit a cancellation application through 'Cancel Account' in the App at any time. After the account cancellation audit is passed, we will completely delete or anonymize your personal information within 15 working days without setting unreasonable obstacles. For information that meets statutory retention requirements (such as financial transaction logs), we will only keep it until the statutory period expires and then delete it, and it will no longer be used for other purposes.

6. Special Rules for Processing Sensitive Personal Information

According to legal and regulatory requirements, we adopt special protection rules for sensitive personal information (including audiovisual materials, location information, voice interaction content, etc.):

1. Explain the purpose, method, and scope of processing to you before collection and obtain your separate consent.
2. Only processed for achieving the corresponding core functions, not for other unrelated purposes.
3. Adopt higher-level encryption storage and access permission control, strictly limiting internal personnel access.
4. You can withdraw your consent and apply for the deletion of relevant sensitive information at any time, and we will respond to your request in a timely manner.

7. Protection of Minors

Qutewear's services are primarily intended for adults.

• Mainland China Users: We will not knowingly collect personal information of minors under the age of 14. If we find that we have unintentionally collected personal information of minors, we will take measures to delete it as soon as possible after verification.
• Users in Other Countries/Regions: We will strictly abide by the relevant laws and regulations on the protection of minors in the local area (such as under 13 in the United States, under 16 in some EU countries, etc.).

8. Personal Information Security Guarantee

We adopt industry-standard technical and management measures to protect your personal information security in all aspects:

• Technical Protection: Adopt measures such as encryption storage, transmission encryption, and access permission level control for personal information; adopt higher-level protection such as de-identification and end-to-end encryption for sensitive personal information (such as your private audiovisual materials and AI dialogue streams).
• Management Standards: Establish a data security management system, regularly conduct privacy security training for employees, and strictly limit the scope of information access and the approval process.
• Emergency Response: Formulate an emergency plan for data security incidents. In case of security incidents such as personal information leakage or damage, we will start the emergency response in a timely manner, report to the regulatory authorities in accordance with the law, and notify you through App push, internal messages, etc.

9. Policy Update and Notification

With the development of global privacy laws and the iteration of product functions, we may revise this Privacy Policy from time to time.

In case of significant changes (such as substantial changes in information processing purposes, information types, cross-border transfer rules, user rights, etc.), we will send a notification to you at least 7 days in advance through App push, prominent announcements on the official website, etc. You can choose to continue using the service or cancel the account to terminate use.

In case of minor adjustments (such as text expression optimization, contact information updates), they will be directly announced on official channels after the update and will no longer be notified separately.

10. Contact Us

If you have any questions, comments on this policy, or need to exercise your privacy rights, please contact our data protection team:

• Personal Information Processor: Xiamen Meiya Zhongmin Technology Co., Ltd.
• Contact Email of Personal Information Protection Officer: support@qutewear.com
• Customer Service Email: support@qutewear.com
• Company Address: 3rd Floor, No. 12 Guanri Road, Software Park, Lianqian Street, Siming District, Xiamen City, Fujian Province