Privacy Policy
This Policy applies to Loona products or services including Loona robot and Loona APP provided by Beijing Keyi Technology Co., Ltd. (domicile: Room 801, 8/F, No. B3, Huayuan Road, Haidian District, Beijing, hereinafter referred to as “Keyi Tech” or “We/us/our”) only.
Last updated: Sep 1, 2023.
This Policy will help you understand:
• How we collect and use your data
• How we store your data
• How we protect your data
• How we share your data
• Your rights
• How we process children's data
• How this Policy would be updated
• How to contact us
Aware of the importance of personal data to you, we will use the best endeavor to ensure the security and reliability of your data. Committed to maintaining your trust and faith, we abide by the following principles to protect your data: lawfulness, fairness and transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, and accountability. In line with developed security standards in the industry, we pledge to take appropriate security measures to protect your data.
Please carefully read and understand this Policy before using our products or services.
I. How we collect and use your data
As you use Loona products or services, we will collect and use the information which you offer for using such services or which results from such services in the ways below:
1. When you register an account, we will require you to offer relevant data, including your e-mail address, password, nationality, age, and guardian’s e-mail address (if necessary). The e-mail address and password information are collected for helping you complete account registration, use Loona products or services, and secure your account; we contact and send important notices to you. Nationality information is collected to define your region and fairly grant you access to relevant servers. Age information is collected to determine whether you are children defined in this Policy (refer to “How we process children's data” for details). If you are a child, we will also collect your guardian’s e-mail address to guarantee that children offer personal data for the use of Loona products or services with parents’ or guardians’ consent.
Besides, you may also enter gender, nickname, DoB, and avatar information on demand. Such information is not required for using Loona products or services but is instrumental in improving the integrity of account data and the quality of Loona products or services. Offer of such information is not compulsory, and your refusal to offer such information will not make any adverse effects on the service features.
1. When you use Loona products or services to connect to WiFi, we will obtain your location information. We collect location information to obtain your accurate location so that Loona products or services can use WiFi functions smoothly.
2. As you use the Loona APP community, we will collect, use and display text, images, videos, programs, comments, likes, avatars, nicknames, and other information posted in the community in line with rules set by you, to enable other community users to browse what you share. You may also delete any content you shared in the community whenever possible.
3. As you interact with the Loona robot via voice command, we will collect your voice command information to recognize and analyze your voice commands and keep improving service quality by collecting voice commands.
4. As you use Loona products or services, we will collect and use your device model, system version, login IP address, Loona software version, Loona robot version, log information (e.g., APP operating data or service failure information), Loona robot ID number, etc., to secure your regular use of our services, improve and optimize our service experience and ensure your account security.
5. We may also offer you recommendations directing to relevant content, products, or services, using your data. With your consent, we will send you relevant intriguing product or service information; invite you to attend our activities (including promotions), market surveys, or satisfaction surveys. If you don’t want to be disturbed by such push notifications or messages, you may unsubscribe notifications as instructed or in other ways offered.
6. We will not collect your facial features. The entered facial features for the use of the Loona robot are saved in the Loona robot terminal device, and Loona robot will use such features to identify and interact with you.
7. We will not collect your remote surveillance video information. The real-time video information generated from using the remote real-time video feature will be directly delivered from the Loona robot to Loona APP via P2P transmission for playing, or to Loona APP via server streaming for playing, wherein the real-time video information will not be stored.
II. How we store your data
1. Storage location
Loona products or services are available worldwide, suggesting that servers used for processing your data may be placed outside your country/region. Under such circumstances, we will take all reasonable actions to ensure the collected data are processed as required by this Policy and applicable laws.
We will select locations that best serve your interests and benefits for storing your e-mail address, password, nationality, age, guardian’s e-mail address, gender, nickname, DoB, voice command information, login IP address, device mode, system version, Loona software version, Loona robot version, log information, Loona robot ID number, etc. The data collected and processed within the territory of the People’s Republic of China will be stored within the territory of the People’s Republic of China; the data collected and processed within the territory of the EU will be stored within the territory of the EU.
Contents shared in the APP community, including text, images, videos, programs, comments, likes, avatars, nicknames, and other information, will be simultaneously stored in servers of multiple countries/regions, in a bid to enable other community users to browse what you share. Please ensure the contents to be shared contain no privacy information before sharing such contents. We will take appropriate technical measures to ensure the security of your data.
2. Storage period
Generally, we will only reserve your data within the time required for realizing purposes and the period prescribed by laws and administrative regulations. Here are two examples:
E-mail address: We will save your e-mail information as long as necessary, to ensure your regular use of Loona products or services. After you cancel your Loona account, we will delete relevant information by law (unless we need to keep the information for a longer period to discharge some legal duties);
Information shared in the community: We need to save your information shared in the community, to ensure the regular use of community features. After you delete the information, we will delete relevant information (unless we need to keep the information for a longer period to discharge some legal duties).
If our products or services fall into disuse, we will inform you via push notifications or announcements, and delete or anonymize your data within a reasonable period.
III. How we protect your data
We spare no effort to defend your data security, to prevent such data from being lost, misused, falsified, accessed, or disclosed without authorization.
We will take multiple security protection measures to ensure information security, within reasonable safety limits. For instance, we will protect your data through encryption, de-identification, and anonymization.
We set in place unique management systems, operating procedures, and organizations to ensure the security of personal data. For instance, we strictly restrict access to data and require those with access to observe a duty of confidentiality.
In the event of a breach of personal data or any other security incidents, we will activate emergency plans and remedial actions, prevent relevant security incidents from worsening, and perform related duties of reporting and notification by law.
We do everything in our power to protect your data. But it should be understood that no security actions are impeccable.
IV. How we share your data
We will not sell your data to anybody categorically. In addition, we also require our partners or third-party organizations to act in line with the provisions which allow/prohibit their use or leakage of the information we offer/offered in any way. Specifically, we will share your data with a third party in the following cases:
1. To ensure a positive user experience, we will embed third-party SDK in the APP. Keyi Tech does not have the right to control such third parties. You may [Click here] to refer to The List of Person Data Shared with Third Parties to learn more about why and how the data are processed by SDK, and which data are processed.
2. In the wake of business continuity and development, we stand a chance of merger, spin-off, or any other transactions. If the transfer of personal data is involved in such transactions, we will notify you of relevant situations, and continue to protect your data in accordance with laws and regulations and in line with the standards set in this Policy or require the new data processor to do so.
V. Your rights
Where applicable laws require, you have the right to withdraw your consent to us for processing your data at any time. But the withdrawal of such consent will make no difference to the legality and effectiveness of our processing of your data with your consent before such withdrawal, or to our processing of your data based on other appropriate and justified grounds.
1. The right to access- You have the right to request us for copies of your data. You may [Click here] to refer to our List of personal Data Collected, or [Click here] to refer to related permissions you may enable for use of Loona products or services, and modify any allowed permissions as instructed.
2. The right to rectification- You have the right to request us to correct any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete.
3. The right to erasure- You have the right to request us to erase your data, under certain conditions.
4. The right to restrict processing- You have the right to request us to restrict the processing of your data, under certain conditions.
5. The right to object to processing- You have the right to object to our processing of your data, under certain conditions.
6. The right to data portability- You have the right to request us to transfer the data that we have collected to another organization, or directly to you, under certain conditions.
7. The right to Delete Personal Information Subject Account - You can delete the account you registered at any time. You can do this by going to "Settings - Account - Delete the Account". After you delete your account, we will stop providing products or services to you. Except as otherwise provided by laws and regulations, we will delete your personal information as per your request.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: dataprivacy@keyirobot.com
In principle, we waive charges for processing your reasonable requests. But for those repetitive or beyond reasonable limits, we will charge some fees as the case may be. We may turn down requests that are groundlessly repetitive or unrealistic, claim for an excess of technical means, or jeopardize others’ legitimate rights or interests.
VI. How we process children's data
We attach great importance to the protection of children's data. Though the definition of children varies by local laws and customs, we regard any and all under the age of 16 as children. If you are under the age of 16, you shall need to obtain written consent from your parents or guardian while using our products or services. If you are a children’s guardian and have doubts about the data of children under your guardianship, you may e-mail dataprivacy@keyirobot.com to contact us at any time. We will clarify your doubts in reply within one month.
If we collect children’s data with the consent of their parents/legal guardians, In that case, we will use or disclose the personal data only where laws allow, parents or guardians give explicit consent, or under necessary circumstances for protecting children.
VII. How this Policy would be updated
We may revise this Privacy Policy in due course. In the event of any material changes to this Privacy Policy, we will show you the updated Privacy Policy through push notifications, pop-ups, or other proper forms in line with legal requirements while you log in and update the version. We will also save prior versions of this Policy for your reference.
VIII. How to contact us
If you have any questions, complaints, or suggestions about any matter in connection with this Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us. Typically, we will reply within one month upon receipt of your request.
Email us at: dataprivacy@keyirobot.com
or write to us at: Room 801, 8/F, No. B3 Huayuan Road, Haidian District, Beijing, China, 100191
Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the local data protection office.