WellRing Privacy Policy

Overview

“WellRing” is an application provided by Shenzhen Mingyang Industrial Development Co., LTD. (hereinafter referred to as the “Company”, or “we” or “us”) to you with respect to exercise guidance and health services. We respect your privacy and are committed to protecting your privacy by complying with this Policy. This Policy sets forth:

• The types of information we will collect or you may provide when you download, install, register, access, or use the application “WellRing”;
• The practices that we will collect, use, maintain, protect and disclose such information.

This Policy applies only to information that we collect in this App or by e-mails, texts, and other electronic communications sent through or in connection with this App.

This Policy does not apply to the following information:

• The information we collect offline or in the App or website of any other companies, including the website that you can access through such App;
• The information provided by you to any third parties or collected by them (see below).

There may be privacy policies on our website or App and other third parties, and we encourage you to read such policies before you provide information through them.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will process your information. Please do not download, register or use this App if you disagree with our Privacy Policy. By downloading and registering WellRing for use, you agree with this Privacy Policy. Your exercise and health information include sensitive personal information, which will be stored on the Linode Cloud Server, and we will not upload it to the server of WellRing until you give consent in the App. Generally, the data from local residents will be only stored on the server within the local jurisdiction and will be not transferred across borders. In this Privacy Policy, we reserve the right to update or amend this Policy from time to time, and we will post the updated Privacy Policy here in case of any change in our Privacy Policy. By continuing to use this App after we have amended this Policy, you indicate that you have carefully read and agreed to these changes and you are kindly requested to check this Policy regularly for updates.

This App does not apply to minors under the age of 16 (or under the age of 13 in some jurisdictions) and we will not intentionally collect the personal information about these minors under the age of 16 (or under the age of 13 in some jurisdictions) If we find ourselves collecting personal information about these minors without prior provable consent of their parents, we will manage to delete the same as soon as possible and terminate the accounts of these minors; if you believe that we may have any information about these minors, please contact us at mingyang.rd@gmail.com.

What kind of information do we collect and how do we collect information

We collect information from users of this App by:

• Directly obtaining the same from you when you make available it to us;
• Automatically executing the collection of information provided by you to us when you use this App.

We may request you to provide the following information when you download, register or log in to use this App:

• Which may be used to identify your personal identity, such as name. mailing address, e-mail address, phone number, password, date of birth, gender, height and weight or any other identifier that can contact you online or offline (“Personal Information”);
• Which is about you, but it doesn’t identify you individually, for example, health information; This information includes:
• Those that you provide by filling in a form in this App, which includes the information provided when you register this App, subscribe to our service, and post materials,

and request further services. We may request you to provide information when you participate in our sponsored contests or promotions and when you report that there are issues that occurred to this App.

• Records and copies of your correspondence (including email address and phone number) (if you contact us);
• Your responses to surveys we may ask you to complete for research purposes;
• Details of the transactions and order fulfillment that you make through this App. You may be required to provide financial information when you place an order through this App.
• Your search and query on this App.

You may also provide information in the public area of this App or on the websites you visit through this App (collectively referred to as “User Contributions”) for the purpose of posting or displaying (“Posting”). Your User Contributions are posted and transferred to others, at your own risk.

It is reminded that no security measures are perfect or unbreakable. Moreover, we are unable to control the actions of third parties with whom you may choose to share User Contributions.

As a result, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automated information collection and tracking

When you download, access and use this App, it may use technology to automatically collect information arising from:

• Account cancellation

If you need to cancel an account, the following conditions are required to be met at the same time:

(a) The account had no abnormal login in the last 1 month;

(b) No complaint or report in respect of the account occurs;

(c) There are no unused benefits in the account, and if you have any unused benefits, you will be deemed as having waived such benefits by making an application for cancellation;

(d) You have completely waived rights to retain and retrieve such data;

(e) The account cancellation does not involve any complaints, disputes, lawsuits, or investigations by competent authorities that have occurred and there is no such realistic risk of being sued or adjusted;

(f) There are no obligations in respect of the account to be performed but not be performed yet, in accordance with laws and regulations;

If you do need to cancel your account, please contact us at mingyang.rd@gmail.com. Before you cancel your account, we will conduct the verification of your account information. You acknowledge and understand that canceling the account is irreversible.

• Consequences of account cancellation

You acknowledge and agree that completing the process of account cancellation will result in (including without limitation) the following consequences:

(a) You will have no permissions to operate relying on such an account;

(b) You will be unable to log in to this App with such an account again;

(c) After cancellation, we will clear your data and you will be unable to retrieve all information, data, etc. that you have stored or used under this account;

(d) Other consequences that may damage your benefits or cause loss to you;

• Details of usage

When you visit and use this App, we may automatically collect some particulars that you visit and use this App, including traffic data, location data, logs, and other communication data as well as the resources you access and use through this App.

• Photo Information

When you customize the display avatar, customize the background of the watch face, or synchronize the QR code from the album to the watch, the application will access your photo information.

• Location information

This App will collect real-time information about the location of your device, including GPS signals, device sensors, Wi-Fi access points, and base station IDs (if you have granted us access to this information).

• Information on the biometric characteristics

This App will collect your biometric information, such as your exercise, activity, sleep, or health data, including the number of steps you took, the distance you walked, calories burned, weight, heart rate, sleep stages, active minutes, and any similar information you grant us access to from other services.

• Other information

Apart from the above, this App will also collect other information you provide, including your CV or account information such as country/region; information about the service functions provided by the product and this App, such as alarm clock, friends information, diet records, weight records, sleep records, records of drinking water, etc.; information about a product or service; and the information recorded by your device, which may vary depending on the device you are using.

If you do not want us to collect this information, please do not download this App or delete it from your device. For more information, please refer to the following content regarding the disclosure of your information. But it is noted that opting out of this App’s location information collection will disable its location-based function. We may collect information about your activities over a period of time and across third-party websites, applications or other online services (behavior tracking) by using these techniques.

Information collection and tracking techniques

The techniques we use for automated information collection may include:

• Cookies (or Mobile Cookies)

A cookie is a small file placed on your smartphone. Mobile Cookies may be rejected by activating the appropriate settings on your smartphone. However, you may be unable to access certain parts of our App if you choose this setting.

• Web beacons.

There may be small electronic files called web beacons (also known as transparent GIFs, pixel labels and single-pixel GIFs) on the pages of the App, our emails and relevant websites, such as users who allow the Company’s computers to visit these pages or open emails and other relevant application statistics (e.g. logging the popularity of certain application content and verifying the integrity of systems and servers).

• Similar techniques

For the same purpose, we use techniques similar to cookies or web beacons.

Device Management

In order to manage your WellRing device (including WellRing ecological devices such as wristbands, watches, smart rings and other wearable devices produced and sold by us and its affiliates, as well as third-party devices), we need to collect your device identifier, device hardware Information, device usage information, system basic information and network information. The purpose of collecting this information is to establish a Bluetooth connection, manage device configuration, complete software upgrades, display data sources, and count device activations, and this data will also be used to improve the network connection experience.

In order to support the linkage between the wearable device and the mobile phone information, it is necessary to read the mobile phone calendar schedule and basic system information to the wearable device. We connect the WellRing device via Bluetooth to obtain the fitness data of the device. You can terminate the collection of such data by disconnecting or unbinding.

After connecting some WellRing devices, in order to provide more accurate data monitoring, the gender, age, height, and weight you enter in “Mine” and “Profile” in the “WellRing” app will be synchronized to the devices (such as bracelets, watches, smart rings, etc.) Wait).

Device permission call

Storage permission: When you use functions such as sharing, vibration step counting, or logging in to your account, you can choose to enable this permission to read or write application usage information, pictures, videos, and intermediate step data. If you do not need such services, you can turn off this permission at any time, which will not affect the use of other services.

Camera permission: When you scan the QR code to connect the device, bind the bus card or use the group function, we need to apply for and obtain this permission from you in order to complete the picture shooting. If you do not need such services, you can turn off this permission at any time, which will not affect the use of other services.

Location permission: When you use a single movement to generate track pictures, Bluetooth pairing, weather push or other location-related searches, you can choose to enable this permission to determine your current location information. If you do not need such services, you can turn off this permission at any time, which will not affect the use of other services.

Collection of information by third parties

Some third parties may use automated information collection techniques to collect information about you or your device when you use the App or its content. These third parties may include:

• Advertisers, ad networks and ad servers;
• Analytics companies;
• The manufacturer of your mobile device;
• Your mobile service provider.

These third parties may use tracking techniques to collect information about you when you use this App. The information they collect may be linked to your personal information, or they may collect information, including personal information, about your online activities over a period of time and on different websites, applications and other online service sites.

They may use such information to provide you with interest-based (behavioral) ads or other targeted content.

We do not control the tracking techniques of these third parties or how they are used. If you have any questions about ads or other targeted content, please contact the responsible provider directly.

How we use your information

We use the information we collect or that you provide to us (including any personal information) to:

• Provide you with the App and its content, and any other information, products or services that you request from us;
• Fulfill any other purpose for which you provide it;
• Send you notices about your account;
• Perform our obligations and exercise our rights arising out of any contract you enter into with us, including billing and collection; to notify you when App updates are available, as well as changes to any products or services we offer or provide through it.

Disclosure of your information

We may disclose aggregate information about our users and information that does not identify any person or device without restriction. In addition, we may disclose personal information that we collect or that you provide:

• To our subsidiaries and affiliates;
• To contractors, service providers and other third parties that we use to support our business;
• To purchasers or other successors in the event of a merger, divestiture, reorganization, restructuring, dissolution or otherwise sale or transfer of some or all of our assets (whether as a going concern or as part of bankruptcy, liquidation) or similar proceedings in which the personal information we hold about users of our App is part of the transferred assets;
• If you do not opt out of these disclosures, to third parties who market their products or services to you;
• To fulfill the purpose for which you provided it. For example, if you provide us with an email address to use the “email a friend” function of our website or App, we will send the content of that email and your email address to the recipient.
• For any other purpose that we disclose when you provide information;
• To obtain your consent;
• To comply with any court order, law or legal process, including responding to any governmental or regulatory request;
• To exercise our rights arising out of any contract between you and us, including the license agreement for the App’s end users, terms of sale, and billing and collection;
• Where we believe that disclosure is necessary or appropriate to protect rights, property or our security and the safety of our customers or others. This includes exchanging information with other companies and organizations in order to prevent fraud and reduce credit risk.

Your choices about our collection, use and disclosure of your information

We strive to provide you with choices regarding the personal information you provide to us. This section describes the mechanisms we provide for you to control certain uses and disclosures of your information.

• Tracking techniques

You can set your browser to refuse all or some browser cookies or to alert you when a cookie is being sent. If you disable or reject cookies or prevent the use of other tracking techniques, some parts of the App may not be accessible or may not function properly.

• Location information

You can choose whether to allow the App to collect and use real-time information about your device’s location through your device’s privacy settings. If you prevent the use of location information, some parts of the App may not be accessible or may not function properly.

• Company promotions

If you do not want us to use the email address or other contact information you provide to promote our own or a third party’s products or services, you may opt out by logging into the App and adjusting your user by checking or unchecking the relevant box or sending us an email stating your request to [email address]. We do not control the collection or use of your information by third parties to provide interest-based advertising. However, these third parties may provide you with a way to opt out of having your information collected or used in this manner. You may opt out of receiving targeted advertising from members of the Network Advertising Initiative (“NAI”) on NAI’s website. Accessing and correcting your personal information

You can view and change your personal information by logging into the App and accessing your account profile page.

If you delete your User Contributions from the App, a copy of your User Contributions may still be visible on the Cache and Archive pages or may have been copied or stored by another App user.

Proper access to and use of the information provided on the App (including User Contributions) is governed by our Terms of Use.

For our policy on children, we comply with the requirements of the EU’s General Data Protection Regulation (\”GDPR\”) and the Children’s Online Privacy Protection Act (\”COPPA\”). The services are available to persons aged 16 years or older. If you are a guardian of a child under the age of 16, you acknowledge and warrant that you agree and consent to the use of the Platform and this Privacy Policy.

California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

You have the right to know how we collect, use and disclose your personal information, to access your information, to request that we delete certain information, and will not be discriminated against for exercising your privacy rights. You may use your account settings to exercise these rights.

If you need further assistance regarding your rights, please contact us at [email address] and we will consider your request in accordance with applicable laws. As described above, we collect the categories of personal information listed below. We receive this information from you, your device, your use of the App and related products and services, third parties, and as otherwise described in this Policy. We use and disclose information in these categories for the business purposes described above. Categories are:

• Identifiers, such as your name or username, email address, mailing address, phone number, IP address, account ID, device ID, cookie ID, and other similar identifiers;

demographic information that may be protected by law, such as your gender, age, health information, and physical characteristics or description;

• Business information, including your payment information and records of services or equipment you have purchased, obtained or considered;
• Biometric information, such as your exercise, activity, sleep, or health data, including the number of steps you took, the distance you walked, calories burned, weight, heart rate, sleep stages, active minutes, and any similar information you grant us access to from other services;
• Internet or other electronic network activity information, such as usage data that we receive when you access or use our Services. This

includes information about your interactions with the App, products and services and the devices and computers you use to access the App, products and services;

• Geolocation data, including GPS signals, device sensors, Wi-Fi access points, and base station IDs (if you have granted us access to this information);

electronic, visual or similar information, such as your profile picture or other photographs;

• Other information you provide, including account information such as your country/region; information about the functions of the App, products and services, such as alarm clocks, information about your friends, and weight, sleep, health or exercise records; messages on the App; and the information recorded by your device, which may vary depending on the device you are using.
• Inferences drawn from any of the above, including the number of calories you have burned, the distance you have traveled, sleep insights, and personalized exercise and activity goals.

We never sell personal information about our users, and we do work with partners who provide us with advertising services as described above.

Data Security

We have measures in place designed to protect your personal information from accidental loss and unauthorized access, use, alteration and disclosure. All information that you provide to us is encrypted. The safety and security of your information also depends on you. If we provide you with a password (or a password you choose) to access certain parts of our App, you are responsible for keeping that password confidential.

We ask that you do not share your password with anyone. The information you share in public areas may be viewed by any user of this App.

Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. While we strive to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App.

Any transmission of personal information is at your own risk, and we are not responsible for the circumvention of any privacy settings or security measures we may provide.

Examples of situations involving embedded third-party SDKs are itemized below:

(1) Google Login

Type of personal information: information on commonly used personal devices

Personal information fields: device information

Application scenario: Google Login

Name of third party organization: Google at https://developers.google.com/

Related privacy policy of the third party: https://developers.google.com/terms/api-services-user-data-policy

Note: this function is only available to users not from the Chinese mainland due to national policies.

(2) Facebook Login

Type of personal information: information on commonly used personal devices

Personal information fields: device information

Application scenario: Facebook Login

Name of third-party organization: Meta at https://developers.facebook.com/?no_redirect=1

Related privacy policy of the third party: https://www.facebook.com/about/privacy

Note: this function is only available to users not from the Chinese mainland due to national policies.

Changes to our Privacy Policy

We may update our Privacy Policy from time to time. If we make material changes to the way we handle users’ personal information, we will post the new Privacy Policy on this page and notify you that the Privacy Policy has been updated, or by email to the email address you provided.

The date of the last revision of the Privacy Policy is shown at the top of the page. It is your responsibility to ensure that we provide you with a current, valid and deliverable email address and to periodically visit this Privacy Policy to check for any changes.

Contact information

For questions or comments about this Privacy Policy and our privacy practices, or for recording a complaint or concern, please contact us at:

Address:  Room 211, Building 3, Minle Industrial Park, Minzhi Street, Longhua New District, Shenzhen, China

E-mail: mingyang.rd@gmail.com