Zemyee Life Personal Information Protection Policy

 

Last Updated: April 1, 2025

Effective Date: April 18, 2025

 

Zemyee Life APP (also referred to as “this App”) is developed

and operated by Shenzhen Zhenyi Times Technology Co., Ltd. and

its affiliated

companies (registered address: Building 6AB, B1106, South Court,

Haihang

Guoxing Garden, 6001 Longgang Avenue (Longgang Section), Nalian

Community,

Longgang Sub-district, Longgang District, Shenzhen; hereinafter

“zemyee” or

“We”). This Personal Information Protection Policy explains to

you in detail

how we collect, store, use, process, transmit, provide,

disclose, or delete

your personal information during your use of this App, the

purposes and scope

of such processing, your rights regarding your personal

information, and the

security measures we take to protect information.

 

Before using this App, please read and understand this policy

and the related user service agreements. If you disagree with

this policy, you

may click “Disagree” to close and exit the App, and we will be

unable to

provide related services to you. If you click “Agree,” you are

deemed to have

carefully read and clearly understood the matters related to

personal

information processing described below. By using or continuing

to use this App,

you are agreeing to allow us to process your personal

information in accordance

with this policy.

 

If you are under 14 years old (or under any minimum age required

by the relevant jurisdiction), you may only use the App with

your guardian’s

accompaniment, who has read, understood, and explicitly agreed

to this policy.

 

We operate and provide global services. However, some smart

devices or services we offer may vary by your location. Please

carefully read

this policy and any privacy notices or supplemental statements

for the specific

device or service you are using to obtain detailed information.

 

This Personal Information Protection Policy covers the following

topics:

 

1. General Terms

  I. How we collect and use your personal information

  II. How we retain and transmit your personal

information

  III. How we appoint processors, share, transfer, or

publicly disclose your personal information

  IV. How we protect your personal information

  V. Your rights regarding your personal information

  VI. How we handle children’s personal information

  VII. Third-party providers and their services

  VIII. How to view and update this policy

  IX. How we use cookies and similar technologies

  X. Contact Us

  XI. Dispute Resolution

  XII. Glossary

 

2. GDPR-Specific Provisions

 

3. California-Specific Provisions (CCPA)

 

In addition to this Personal Information Protection Policy,

there may be product- or service-specific privacy policies

applicable to the

products or services you use. In every case, the general terms

in Part A apply

to you no matter where you are located. Part B applies to users

located in the

European Union, Liechtenstein, Norway, the United Kingdom, or

Switzerland (the

“Europe” region). Part C applies to residents of California,

USA.

 

1. General Terms

 

I. How we collect and use your personal information

 

1) The information we collect

 

We collect personal information on a principled basis: lawfully,

legitimately, and out of necessity. To provide our services,

ensure normal

operation and security of products and services, and improve our

offerings, we

collect information that you actively provide, authorize us to

obtain, or

generate during your use of our products and services.

 

The specific information we collect depends on the products and

services you actually use, your interactions with us, the

choices you make

(privacy settings and the particular products and features you

use). Please

note that if you provide information about another person, you

should have that

person’s authorization (and in some cases, their separate

consent).

 

This App provides core features such as online browsing, version

upgrades, user experience optimization, account

registration/login, setting

personal information, device binding/management, device cards,

device sharing,

location services, fitness data tracking and leaderboards,

Zemyee Store, help

and feedback, push notifications, connection to body fat scales,

AI Q&A, AI

watch face, and third-party device services. Please note that

the availability

of these features may vary depending on your location and the

devices you use.

 

When collecting information, you are not required to provide

personal information. However, for the core features that require

certain

information, if you decline, we may not be able to provide

related products or

services or respond to your issues. For optional features,

consent will be

obtained separately; if you refuse, those features may not be

available, but

essential core features will remain accessible.

 

We typically determine the actual usage location (and comply

with local data protection laws) by the region you first log in

from (or that

you later select in settings).

 

(1) We may collect the following categories of information:

 

1. Core business functions

 

(1) Online Browsing Service

If you only use the basic online browsing service, we will not

collect your personal information.

 

(2) Version Upgrades

To enable app version upgrades, we collect your App ID, app

version information, region code, and device language. To

provide firmware version

upgrades for connected devices, we collect your device ID,

device version

information, App version information, device MAC address, region

code, and

phone language. Without these, upgrading app versions or device

firmware may be

unavailable.

 

2. Additional features

 

(1) Account registration/login

 Zemyee account services are provided by Shenzhen Zhenyi

Times Technology Co., Ltd. If you register or log in, Zemyee

will collect your

mobile number or email address, password, and registration SMS

content to

create your account and assist with login. After registration,

you may

optionally provide a username/nickname, avatar, and gender to

complete your

profile. When you log in to Zemyee on your device, automatic

login may be

enabled.

 

(2) Set personal information

You can set your personal information in the app under My >

User Account. We will collect your avatar, gender, nickname,

date of birth,

height, and weight to identify you and provide accurate health

data

calculations. After connecting smart devices, your gender, date

of birth,

height, weight, or call history input in the app may be synced

to certain

wearable devices.

 

(3) Device binding, device management, device cards

To bind and manage smart devices (e.g., smart home devices such

as security, lighting, energy-saving, and home appliances;

wearables such as

bands, watches, scales), we collect device name and MAC address

to enable

Bluetooth connections, bind devices, manage configurations,

display data

sources, control devices, view status, and analyze service

operations. You can

view bound devices and their connection status in the device

space.

 

(4) Device sharing

When you use the device-sharing feature, you must provide the

recipient’s phone number or email to allow them to receive

information about

the device you are sharing.

 

(5) Location services

We collect location information to provide weather services, or

when using certain related devices where Android or other

platforms may require

location services to discover connected devices. If you do not

provide this

information, some location-based device connections may be

unavailable. You can

adjust location services in your device settings.

 

(6) Zemyee Store service

To enable shopping guidance, this App includes Zemyee Store (H5

page). When you use Zemyee Store, it processes your personal

information.

Zemyee Store and Zemyee products share infrastructure, systems,

and

technologies to provide a coherent, secure experience, including

the ability to

use a single account for Zemyee App and Zemyee Store. We may

process

information about you in accordance with applicable laws and

terms.

 

(7) Help and feedback service

When you use the help and feedback features, we collect your

phone/email, feedback content, type, contact details, and error

log information

to verify identity and process feedback or assist with error

analysis. Note

that due to Android design, your error events may include the

overall context;

we only use such data for error analysis and do not use it to

identify you or

for other purposes. Logs are regularly deleted.

 

(8) Message reminders

You can enable various reminders (incoming calls, messages,

alarms, events, health reminders) in the app and push them to

devices. This

feature does not require personal information collection. If

your device

supports caller ID and contact display, the app may collect your

frequently

contacted persons’ information and transmit it to the device via

Bluetooth to

display caller/message reminders. This information stays on the

device and is

not uploaded to the cloud.

 

(9) Push notifications

To provide notification services, we collect and use your

IMEI/MAC/Android ID/IDFA/OPENUDID/GUID, SIM IMSI, and

geolocation to timely

notify you of service messages.

 

(10) Voice services

When using voice features on smart devices, we collect your

voice data to control and use the devices. This data is

processed locally and

is not uploaded to the cloud.

 

(11) User experience optimization

When you use smart devices, we may collect your Android ID and

behavioral data (e.g., feature usage statistics, upgrade

statistics, site

navigation data, clicks, performance data) to optimize product

features and

UI/UX. You can opt out of user experience improvement in the app

settings, and

after opting out we will delete or anonymize data collected from

your device

for this purpose.

 

(12) Third-party device services

You may add third-party devices (e.g., watches, bands, scales)

via the “Bind Device” feature. Third-party vendors may also

collect information

in these scenarios. You should read the third-party vendor’s

terms and privacy

policy before using their services. We are not responsible for

how third parties

use their information. For third-party SDKs used in the app, you

should review

their privacy terms. See the “Third-Party Information Sharing

Checklist” at the

policy end for more details.

 

The above information, except where explicitly stored locally,

is encrypted in transit and stored on servers. The app will

retrieve data from

servers as authorized and display it on device pages. If data is

stored

locally, we cannot provide support or services related to

personal information

handling, and you may manage those data yourself.

 

Note: We continually update our features and services. Depending

on product or device features, we may request additional

personal information

in other contexts. We will inform you via separate personal

information terms,

page prompts, or interaction flows and obtain your consent as

required.

 

2) Mobile permissions

 

When you use this App, we may request certain phone permissions

(e.g., Bluetooth, network access, contacts, call logs, phone

state, dialing,

answering, SMS, camera, microphone, storage, photos (iOS),

location, sensors,

activity, notification listener, etc.) to collect corresponding

personal

information and provide related features or services.

 

For important or sensitive permissions, we will display a prompt

and obtain your consent when you use the corresponding

feature/service. You can

revoke permissions anytime in your device’s settings under “My →

System

Permissions” (exact UI varies by device). If you revoke

permissions, we will

stop using that permission and related features cannot be

provided, but other

features will not be affected.

 

Please note that we may work with third-party service providers

to enable these features, and such providers may receive and

store certain

personal information. These third parties will not use the

information for

other purposes.

 

3.Subscription Service Management and Payment

When you choose to purchase a service or transcription duration

within this product, we will collect your order information

(including: order

type, order number, order source, user ID, order price, actual

payment amount,

payment channel, payment method, order creation time, order

payment time). This

information is necessary for us to confirm your transaction,

activate the

corresponding benefits for you, and handle possible refunds or

after-sales

issues. If you do not agree, you will not be able to proceed

with payment

normally.

 

4.Payment Service Providers

We may offer paid products/services within the Zemyee Life

application. In such cases, we may use third-party service

providers for

payment processing (e.g., payment processors). We do not store

or collect your

payment details. Your payment information is provided directly

to our

third-party payment service providers, whose use of your

personal information

is governed by their respective privacy policies.

 

5.Third-Party Advertisers

We may provide advertising recommendation services within the

Zemyee Life application. In such cases, we may use third-party

service

providers to deliver advertising content. We strive to ensure

that, with your

consent, we do not provide your profile information to any third

party for the

purpose of displaying personalized advertisements to you.

 

6. Membership Services

After logging into your Zemyee Life account, you can activate

membership services and subscribe to paid memberships. We need

to collect your

paid subscription records, membership status, and benefits so

that you can view

them at any time, and this information is also used for content

copyright

protection. You can purchase a membership in Zemyee Life to

access

corresponding benefits, virtual items, or virtual assets. In

providing these

services, we will use your Zemyee Life account information to

verify

your identity, create and store your corresponding benefits,

virtual items, or

virtual assets, or share payment results with relevant third

parties. Among

these, your virtual assets are considered sensitive data, and we

implement

strict protective measures to ensure the accuracy and security

of your asset

data.

 

II. How this personal information may be used

 

We may use personal information for the following purposes:

 

- Provide, process, maintain, improve, and develop our products

and services, including services via connected devices or Zemyee

Life.

- Communicate with you, provide customer support, and deliver

push notifications. We may contact you regarding devices,

services, updates,

firmware/software upgrades, customer inquiries, and related

information.

- Product and user experience improvement. We analyze collected

usage information to improve our products and services and their

usability. You

may opt out of the User Experience Improvement Program in the

app, and upon

opt-out we will delete or anonymize all data collected from your

device for

this program.

- Personalization, notifications, and content/ad recommendations

tailored to you.

- Generative AI services.

- Direct marketing. We may use your contact information (phone,

email), account, IMEI, etc., to provide marketing materials from

us and our

affiliates or partners who offer network, mobile apps, cloud

products and

services. We will obtain your explicit consent or a clearly

affirmative action

before using your information for marketing per local laws. If

you do not wish

to receive certain categories of emails, you may unsubscribe or

contact us.

- Analytics, auditing, and fraud prevention. We may use your

data in aggregated, non-identifiable forms to assess business

performance and

prevent fraud.

- Allow and manage participation in our lottery, contests, or

similar promotional activities.

- Store and maintain information related to you for our

operations or legal obligations.

- Other purposes with your consent.

 

If we use information beyond what is described in this policy or

beyond the originally disclosed purposes, and within a directly

or reasonably

related scope, we will seek your consent in advance. Absent user

consent, we

will not share personal information and behavioral data with

third parties,

except as otherwise provided by law.

 

III. Exceptions to consent for processing or using personal

information

 

Under applicable laws, we may collect or use your personal

information without your explicit consent in certain situations:

 

- To fulfill or perform a contract with you.

- To comply with legal obligations.

- To respond to public health emergencies or to protect life,

health, or property.

- For public interest in journalism or oversight within

reasonable scope.

- To process information that you have made publicly available

or that has already been legally made public.

- Other situations prescribed by laws or regulations.

 

IV. Retention and transmission of your personal information

 

1) How we retain your personal information

 

We will retain your information only for the minimum period

necessary to fulfill the purposes for which it was collected,

unless a longer

retention period is required by law or you authorize a longer

retention. When

you request deletion or when the information is no longer

necessary to provide

services, we will delete or anonymize the data as required by

law. If a longer

retention period is required by law, we will retain the data

accordingly.

 

We determine retention periods based on:

- The purpose of processing and whether it remains necessary.

- The amount, type, and sensitivity of the information.

- The risk of unauthorized use or disclosure.

- To maintain records for inquiries or complaints.

- Security and quality of services.

- Any legal or regulatory retention requirements.

 

If there are serious violations of law, service agreements, or

policies, we may retain relevant information (including records

and credit

information) for the maximum period permitted by law.

 

If we cease operating all or part of our services for special

reasons,

we will inform you in advance and stop collection and

processing, and delete or

anonymize related personal information within the minimum

retention period

required by law.

 

2) How we transfer your personal information

 

As a China-based company with global operations, we operate data

centers in China, France, the U.S., and other locations. Your

personal

information may be transferred to destinations outside your

country of use, in

accordance with local laws. Generally, data collected and

generated in China

will be stored domestically; data collected and generated in the

EU will be

stored within the EU.

 

We understand that cross-border data transfers carry different

risk profiles depending on the jurisdiction. We will take

measures to ensure

that transfers comply with this policy and applicable laws,

including obtaining

your consent for cross-border transfers, applying encryption or

de-identification before transfer, and signing appropriate data

transfer/sharing agreements with recipients.

 

If you wish to learn more about cross-border transfer

safeguards, please submit a request through the Data Subject

Rights Exercise

Platform (DSR Platform): Zemyee Life App My → Feedback.

 

III. Data subject rights and related information

 

Under applicable privacy laws, you have the following rights:

 

- Access: Right to know how we process your personal information

and what choices you have.

- Correction or supplementation: If information is inaccurate or

incomplete, you may request correction or completion.

- Deletion: In certain circumstances, you may request deletion

of some or all of your personal information.

- Restrict processing: In certain situations, you may request

restriction of processing while we verify accuracy.

- Objection: You may object to processing based on legitimate

interests or for direct marketing.

- Data portability: You may receive a copy of your information

in a structured, readable format and request transfer to another

provider where

feasible.

- Withdraw consent: If processing is based on your consent, you

may withdraw it at any time. Withdrawing consent does not affect

processing

that occurred prior to withdrawal. If you withdraw consent for

marketing, we

may no longer provide certain services.

- Complaints: You may lodge complaints with supervisory

authorities or the courts.

 

To exercise these rights, you can use Zemyee Life’s Data

Subject Rights Platform (DSR Platform) or contact us via the

channels listed in

the “Contact Us” section. We aim to respond within 15 business

days after verifying

your identity, with possible extensions as permitted by law.

 

IV. How we respond to your requests

 

- How to respond: Use Zemyee Life’s Data Subject Rights

Platform (My → Feedback) or the contact details listed in this

policy.

- Response time: We strive to respond within 15 business days

after identity verification, subject to applicable laws and

complexity. We may

extend the period if necessary and will inform you of delays and

reasons.

- Identity verification: For your safety, we may verify your

identity before fulfilling requests.

- Fees: Generally, we do not charge for reasonable requests. For

excessive or repetitive requests, we may charge a reasonable fee

or refuse the

request with clear reasons.

 

V. Children’s privacy

 

Our products, websites, and services are primarily for adults

and not targeted at children under 14 (or other minimum ages as

defined by

law). If a child uses our services, a parent or guardian must

read and agree to

this policy with the child before use. Parents or guardians

should supervise

and guide children’s use of our services. If you believe we

process a child’s

information without parental consent, please contact us to

remove it.

 

VI. Third-party service providers and their services

 

This policy does not apply to third-party products or services

linked through Zemyee Life. Third-party sites or services have

their own

privacy policies; we have no control over them or responsibility

for their

handling of personal information. We encourage you to review

third-party

privacy policies before using those services.

 

Some Zemyee Life features may include SDKs from

authorized partners. We assess each partner’s privacy practices

and require

compliance with applicable laws, but you should review the

partner’s privacy

policy before using their services. If you encounter risk with

an SDK, stop

using it and contact us.

 

For product or service needs, we may integrate certain utility

SDKs that do not collect personal information or call sensitive

permissions

(for example, our use of OkHttp3 for network requests, Glide for

image loading,

or JSON tooling). 

 

VIII. Viewing and updating this policy

 

1) You can view this policy in Zemyee Life App under My →

Privacy Policy. You may view historical versions from the policy

text.

2) We may update this policy from time to time. We will notify

you via email, our site, or Zemyee Life push notifications for

material

changes. Your continued use of the product constitutes

acceptance of the

updated policy.

 

IX. How we use cookies and similar technologies

 

1) What are cookies?

Cookies are small files transferred and stored on your device by

Zemyee Life’s website, online services, interactive apps,

emails, and

ads. Cookies may be stored briefly or for long durations. We

cannot access

cookies not set by us.

 

2) Cookies we use

- Zemyee Life and partners use cookies or similar

technologies to better understand device software usage, app

usage frequency,

events inside the app, aggregate audience characteristics, and

performance

data. We do not link data collected by analytics to any personal

information

you submit in the app.

- We may use cookies to analyze trends, manage the website,

track user behavior, and collect high-level audience

information.

- Do Not Track: If your browser has a Do Not Track setting, we

respect it.

- We automatically collect information (e.g., IP address,

browser type, ISP, referrer/exit pages, pages viewed, OS,

timestamps, click

streams) to analyze trends and manage the site.

- We work with third parties to display ads or manage ads on

other sites. Partners may use cookies or similar technologies to

serve

interest-based ads. You can opt out of interest-based

advertising via cookie

controls; note that ads may still appear non-targeted.

 

3) Clearing/Disabling cookies

Manage cookies and preferences in your browser’s

options/settings for browsers such as Internet Explorer, Edge,

Firefox, Chrome,

and Safari (macOS and iOS). For more information, visit

www.allaboutcookies.org.

 

X. Contact Us

 

1) For questions or complaints about this policy or personal

information matters, submit a request via Zemyee Life My →

Feedback. We

will respond within 15 business days (or as permitted by local

law).

2) India Representative:

Email: yanchongzheng@zhenyikeji.team

 

XI. Dispute Resolution

 

This policy’s interpretation and dispute resolution are governed

by the laws of the People's Republic of China (mainland). If

disputes arise,

the parties shall seek amicable resolution; if unresolved,

either party may

bring a case to the Shenzhen Longgang District People’s Court.

 

The policy’s headings are for convenience and do not affect the

meaning of any terms.

 

XII. Glossary

 

Personal Information: Information that, in electronic or other

forms, relates to a identified or identifiable natural person,

excluding

anonymized data.

Sensitive Personal Information: Information that, if disclosed

or misused, could cause harm to a natural person’s dignity or

safety, including

biometric data, religious beliefs, specific identities, medical

health,

financial accounts, residence or movement, etc., and the

personal information

of children under 14.

Affiliated Company: Companies directly or indirectly controlled

by Shenzhen Zhenyi Times Technology Co., Ltd., or companies

jointly controlled

by or significantly influenced by the same parent, etc.

“Affiliated” refers to

any company or entity that controls, is controlled by, or is

under common

control with the Company now or in the future.

Hashing or anonymization is used for sensitive information in

some contexts.

 

B. GDPR-Specific Provisions

 

This section applies to users located in the European Union,

Liechtenstein, Norway, the United Kingdom, or Switzerland (the

“Europe

region”).

 

1) Legal bases for processing personal information

 

The processing of your personal information described in the

“How we collect and use your personal information” section is

based on the

following legal bases:

 

1. Consent: We process your personal information with your

consent, such as for promotional activities (marketing

communications),

participating in user experience programs, and certain

location-based services.

You may withdraw consent at any time; withdrawal does not affect

prior

processing legality. If you do not consent, we may not provide

related

services.

2. Performance of a contract or taking steps at your request to

enter into a contract: to provide Zemyee services, process

orders, activate

services, provide updates, diagnose problems, repair devices,

and deliver

support.

3. Compliance with legal obligations: to comply with tax,

business, and other legal requirements.

4. Legitimate interests: for example, customer surveys, market

analysis, service improvement, security and integrity of the

service, fraud

prevention, and other internal purposes. We will balance our

interests with

your privacy rights before processing.

 

2) Global data transfer safeguards

 

If we transfer your personal information outside the Europe

region, we will ensure there are appropriate safeguards, such

as:

- The recipient is in a country deemed adequate by the EU, or

- The recipient has signed EU-approved Standard Contractual

Clauses, or

- You explicitly consent to cross-border transfer or we apply

other recognized protections.

 

For more information about cross-border transfer safeguards,

please submit a request via Zemyee Life App My → Feedback.

 

3) Additional information about data subject rights

 

Under GDPR, you have these rights:

- Access, rectify, erase, restrict processing, objection to

processing, data portability, withdraw consent, and complain to

a supervisory

authority.

Details on how to exercise these rights and the applicable

channels are provided in the policy (DSR Platform link, contact

options, etc.).

 

5) EU representative contact

 

If you have questions or concerns about this policy or Zemyee’s

practices, you may submit a request via the Data Subject Rights

Exercise

Platform (DSR) in Zemyee Life App My → Feedback, or contact us

at:

Email: yanchongzheng@zhenyikeji.team

 

C. California-Specific Provisions (CCPA)

 

This section applies to California residents under the

California Consumer Privacy Act (CCPA).

 

1) Information we collect

 

We may have collected certain personal information about you in

the past 12 months as described in “General Terms – How we

collect and use your

personal information.” We have not sold California residents’

personal

information within the meaning of the CCPA.

 

2) California rights (supplemental information)

 

If you are a California resident and CCPA does not provide you

with exemptions, you have the following rights:

- Right to know/about: information about the categories and

specific pieces of personal information we collect, their

sources, purposes,

and third-party sharing.

- Right to request deletion: under certain circumstances, you

may request deletion of your personal information.

- Right to opt out of the sale of your personal information:

Zemyee does not sell personal information of residents under 16

or older.

- Non-discrimination: exercising these rights does not result in

discrimination.

 

To exercise these rights, you may contact privacy@zemyee.com and

include “California Privacy Rights.” We will verify your

identity and may

require additional information if needed. You may also authorize

a California-registered

representative to act on your behalf. We will respond within 45

days of a

verified request, with a possible 45-day extension with notice.

 

3) Contact us

 

If you have any questions, please contact:

Shenzhen Zhenyi Times Technology Co., Ltd.

Address: Building 6AB, B1106, South Court, Ha Hang Guoxing

Garden, 6001 Longgang Avenue, Nalian Community, Longgang Street,

Longgang

District, Shenzhen, China (attn: Shenzhen Qianhai Business

Secretary Co., Ltd)

DSR Platform: Zemyee Life App My → Feedback

 

Notes:

- This policy includes the policy’s “Third-Party Information

Sharing Checklist” at the end, which details sharing with

third-party service

providers and SDKs.

- We may require consent for cross-border data transfers or

implement safeguards as described.

- Throughout this policy, “we,” “our,” and “ Zemyee Life”

refer to Zemyee and its affiliates.

 

If you need adjustments to fit specific legal jurisdictions or

want a shorter executive summary version, I can prepare that as

well.