We take the protection of your personal data very seriously and want you to feel secure when using our app and products. The protection of your privacy when processing personal data is an important concern for us that we also take into account in all our business processes. 

 

Personal data are collected, processed and used exclusively in accordance with legal regulations and in good faith. As far as possible, we design our business processes in such a way that the data protection requirements are already taken into account during the development of the products and service offers and to the extent possible, personal data is pseudonymized. 

 

Information we collect

As part of our business relationships, we process personal data that we have received directly from you. In addition, we process personal data which we legitimately obtain from publicly accessible sources or which is legitimately transmitted to us by other third parties, insofar as this data is necessary for the provision of relevant services we provide to you and/or within the scope of the Purposes as set forth below.

 

Purposes of processing (“Purposes”) and legal basis 

Your personal data will be processed in accordance with the provisions of the GDPR and for the following Purposes.

 

For the fulfillment of contractual obligations (Art. 6 Para. 1 b GDPR):

 

The processing of personal data takes place in the context of trade with products and services in the field of consumer electronics. The Purposes of data processing depend primarily on the specific product and its software applications. Further details on this data processing purpose can be found in the accompanying operating instructions, manuals and other terms and conditions at the purchase of such specific products.

 

Within the framework of the balancing of interests (Art. 6 para. 1 f GDPR):

 

If necessary, we process your data beyond the actual performance of the contract to protect the legitimate interests of us. This includes the examination and optimization of procedures for analysis; for the purpose of the assertion of legal claims and defense in legal disputes; the guarantee of IT security and the maintenance of our IT infrastructure and operation; the prevention and clarification of criminal offences; and for business management purposes and the development of services and products.

 

On the basis of your consent (Art. 6 Par. 1 a GDPR):

 

If we have your consent to the processing of personal data for specific purposes (e.g. forwarding of data within the Group or evaluation of data for marketing purposes), the legality of such processing is given on the basis of your consent. The given consent can be revoked at any time. The revocation of the consent does not affect the legality of the data processed until the revocation.

 

Due to legal requirements (Art. 6 para. 1 c GDPR) or in the public interest (Art. 6 para. 1 e GDPR):

 

This includes, for example, identity and age checks or the fulfillment of tax control and reporting obligations.

 

Special data protection at our Fitness tracker:

 

We use your data to make the use of the Fitness tracker as pleasant as possible for you and so that you can benefit optimally from your fitness program. At the same time, this information will improve our Service. The application stores and processes the following data: User Name, Gender, Birthday, Weight, Height, Steps, sleeping hours, heart rates, distance distances, calorie consumption, goals, successes and challenges. Your data will only be stored locally on your smartphone or device.

In order to ensure the compatibility of your Smart Watch with your smartphone or device, our application accesses the following functions of your phone:

 

1.      Allow Smart Watch to access your phone call logs

2.      Allow Smart Watch to make and manage phone calls

3.      Allow Smart Watch to access your phone call contacts

4.      Allow Smart Watch to take pictures and record video

5.      Allow Smart Watch to access photos, media, and files on your device

6.      Allow Smart Watch to access this device's location

7.      Monitor phone call status and read phone contacts

8.      Read Google service configuration

9.      Perform pairing with Bluetooth devices

10.   Access Bluetooth settings

11.   Optimize battery consumption

12.   Run at startup

13.   Get internet data

14.   Execute foreground service

15.   Retrieve WiFi connections

16.   WIFI Recognition

17.   Get network connections

18.   Access all networks

19.   Control vibration alarm

20.   Read and dismiss notifications

21.   Change certain settings of your smartphone or device

 

App permissions: 

 

In order to provide you with the functionalities of the app, the app must be able to access various functions and data of your mobile device. To do this, it is technically imperative that you grant the app selected access authorizations. Otherwise the app cannot be used for technical reasons. Before using the app for the first time, we will explicitly inform you of the requested access rights. Usually the authorizations are as follows:

 

Location: This permission is required to determine your current location for location-based services. This permission allows your phone to access your GPS data, WLAN identifiers and/or Bluetooth, depending on which of them you have enabled, to locate your location.

 

Push notifications: Push notifications are messages that are sent from the app to your device and are prioritized there. This app uses push notifications on delivery, provided the user has consented during the installation of the app or the first use. End user has to accept the enable notifications for the first time installation. Also, The reception of push notifications can be deactivated at any time in the settings of the device.

 

Access smartphone contacts: This permission is required to show caller’s name when user received a call notification.

 

User behavior: Within the framework of legal regulations, we, or companies commissioned by us, create user profiles under a pseudonym. We will not use your personal data for advertising and market research or for the demand-oriented design of the app. A direct conclusion to the user is not possible. The profile data is not linked to any further information about the user. 

 

Device information: In addition to protocol data, we may also collect information about the device on which the app is used. These include device type, operating system used, device settings, unique device identifiers and crash data. Whether some or all of this information is collected depends on the type of device used and its settings. This allows error messages and system crashes to be analyzed in order to improve future operation.  

 

We are distributing our apps via Apple App Store and Google Play Store. We have also incorporated Google Maps (for Android devices) and Firebase Crashlytics in our apps. As a result, usage of our apps are also subject to the following privacy policies:

 

• Apple App Store: https://www.apple.com/legal/privacy

• Google Play Store : https://policies.google.com/privacy

• Google Maps: https://policies.google.com/privacy

• Firebase Crashlytics: https://policies.google.com/privacy

 

Social Media: If you connect to this app via third party social media sites (such as Facebook, Twitter, Instagram or Google+), you may be subject to the data policy of such third party social media sites. We do not have access to any of your personal data stored on such third party social media sites.

 

Data transfer to third countries or international organization

 

Data are transmitted to offices in countries outside the European Union (so-called third countries) if

1.      it is necessary for the execution of your orders,

2.      it is required by law

3.      you have given us your consent.

 

We do not transfer any personal data to bodies in third countries or international organizations.

 

According to Article 45 GDPR, transmission is permissible if the European Commission has decided that an adequate level of protection exists in a third country. In the absence of such a decision, we or the Service Provider may only transfer personal data to a third country or to an international organization if appropriate safeguards are provided (e.g. standard data protection clauses adopted by the Commission or the

 

Supervisory Authority in a particular procedure) and enforceable rights and effective remedies are available. 

We have agreed contracts with these service providers for so-called order processing, which stipulate that the principles of data protection are always concluded with their contractual partners in compliance with the European data protection level.

 

Personal data processed

 

User Name, Gender, Birthday, Weight, Height, Steps, Sleeping hours, Heart rate, Running distance, Calorie consumption, Goals, Successes and Challenges.

Storage period

Your data only stored on your smartphone or device. Once the Smart Watch app is uninstalled, all personal data will be removed from your smartphone or device and none of the data will be retained.

 

Affected rights:

 

Any person concerned by the processing of personal data has the right to:

 

1.      Information (Art. 15 GDPR),

2.      Corrigendum (Art. 16 GDPR),

3.      Cancellation (Art. 17 GDPR),

4.      Restriction on processing (Art. 18 GDPR),

5.      Data transferability (Art. 20 GDPR) and

6.      Opposition (Art. 21 GDPR).

 

There is a right of appeal to a competent data protection supervisory authority (Art. 77 GDPR). You also have the right to lodge a complaint with the responsible data protection supervisory authority at any time. You can contact the responsible data protection supervisory authority located in your country or state.

You can revoke your consent to the processing of personal data at any time. You can uninstall your apps anytime if you would like to revoke this consent. Please note that the revocation will only take effect in the future. Processing that took place before the revocation is not affected by this.

 

Automated decision making 

 

In principle, we do not use fully automated decision making according to Art. 22 GDPR for the establishment and implementation of the business relationship. Should we use these procedures in individual cases, we will inform you separately, insofar as this is required by law. 

 

Information about your right of objection according to Art. 21 Basic Data Protection Ordinance (GDPR)

 

Right of objection in individual cases

 

You have the right to object at any time for reasons arising from your particular situation to the processing of personal data concerning you, which is based on Art. 6 para. 1 e GDPR (data processing in the public interest); this also applies to profiling based on this provision within the meaning of Art. 4 no. 4 GDPR.

 

If you object, we will no longer process your personal data, unless we can prove compelling reasons worthy of protection for the processing, which outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims.

 

Right of objection to the processing of data for direct marketing purposes

If you object to the processing for direct advertising purposes, we will no longer process your personal data for these purposes.

 

You have the right to object at any time by writing to the following points of contact:

Point of contact:

 

If you have further questions regarding the processing of your data or wish to exercise any of your rights under the GDPR or pursuant to this policy, you can contact our data protection officer at dataprivacy.synergy@gmail.com.

 

If you are based in Europe, you may also direct your inquiry to the data protection officer of our representative in Europe at dataprivacy.synergy@gmail.com.

 

Controller Details:

 

Synergy Technology Limited
Attn: Data Privacy Officer

Room 1003, Tower 1, Lippo Centre
89 Queensway, Admiralty
Hong Kong
dataprivacy.synergy@gmail.com

 

 

European Representative:

A6 Europe s.a
Attn: Data Privacy Officer

127-129 Rue Colonel Bourg
1140 Brussels
Belgium
dataprivacy.synergy@gmail.com

 

 

Amendments to the Privacy Policy

 

We reserve the right to amend the Privacy Policy all times.

Modifications will be posted on our website and we suggest that you review the Privacy Policy from time to time.

 

June 2021