Our privacy policy will be effective as of July 1, 2023. Starting from this date, this privacy policy will provide details on how we manage the privacy of your personal information disclosed when you use all USTAR products and services, except for specific USTAR products or services that have their own independent privacy policies.

Please take some time to familiarize yourself with our privacy practices, and if you have any questions, please let us know.

We promise to you

This privacy policy outlines how "USTAR COMPANY LIMITED" (hereinafter referred to as "USTAR" or "we") collects, uses, discloses, processes, and protects the information you provide to us through the "Uone Smart" App when using our products and services. If we request certain information from you to verify your identity when using USTAR products and services, we will strictly adhere to this privacy policy and/or our terms and conditions to use such information.

This privacy policy has been developed with your needs in mind. You have a comprehensive understanding of our practices for collecting and using personal information and can trust that you ultimately have control over all personal information provided to USTAR, which is crucial.

In this privacy policy, "personal information" refers to all data that, when combined with other information about a specific individual or information that USTAR can access, directly or indirectly identifies that individual. Such personal information includes but is not limited to the information you provide or upload and device information.

By using USTAR products and services or engaging in other activities in compliance with applicable laws, you signify that you have read and accepted all the terms described in this privacy policy, including any changes we make periodically. To comply with applicable laws, including local data protection laws (such as the European Union's "General Data Protection Regulation (GDPR)"), we may seek your explicit consent for the processing of specific categories of personal data (such as automated individual decisions). Furthermore, we promise to adhere to applicable laws (including data protection laws in your jurisdiction) to protect the privacy, confidentiality, and security of your personal information. We also commit to ensuring that all our employees and agents fulfill these obligations.

Finally, our goal is to provide the best possible experience for our users. If you have any questions about the data processing practices summarized in this privacy policy, please contact us at salesvn@uonesmart.com, so we can address your needs. We are happy to provide direct clarification and assistance.

What information will be collected and how we use this information?

Categories of Collected Information

In order to provide our services to you, we may ask you to provide personal information that is necessary to provide you with the services. If you do not provide personal information, we may not be able to offer our products or services to you.

We will only collect necessary information for the purposes that have been clearly defined, legitimate, and in accordance with the descriptions provided, ensuring that we do not process this information in a manner that is inconsistent with the aforementioned purposes. We may collect various categories of information (whether or not they are considered personal information), including:

a) We may collect personal information you provide to us, such as your mobile phone number, email address, data or information synchronized from devices that may access the USTAR platform, account and related profile information created on the USTAR platform, devices you add, and messages or feedback you send.

Handheld Device or SIM Card-Related Information: We may collect information related to handheld devices that run USTAR, such as IMEI numbers, IMSI numbers, system versions, device manufacturer information, model names, and network operators. We may also collect related device information associated with your account, such as MAC addresses, DID, device network status (IP/network signal), and firmware versions.

b) Specific Information Related to You: We may collect and use information such as your USTAR account.

c) Location Information (Applicable to Specific Services/Functions Only): Various types of information related to your location, such as region and country codes, city codes, mobile network codes, mobile device country codes, cell identification codes, region names, latitude and longitude information, time zone settings, and language settings.

How this personal information may be used?

The collection of personal information is intended to provide you with products and/or services while ensuring compliance with applicable laws. You hereby consent to our processing of personal information for the purposes outlined in this privacy policy and to the disclosure of personal information to our affiliated companies (involving communication, social media, technology, and cloud services) and third-party service providers (defined below).

We may use personal information for the following purposes:

a) Providing, processing, maintaining, improving, and developing our products and/or services to you, as well as services provided through devices or by USTAR.

b) Communicating with you regarding your devices, services, or any general inquiries (e.g., updates, device firmware/software upgrades, customer support, relevant information, notifications).

c) Conducting marketing-related activities, such as providing marketing and promotional materials and updates. For more information on marketing and promotional activities, please refer to the section titled "Direct Marketing Promotion" below.

d) Analyzing and developing statistical information related to the use of our products and services to better improve our products and services.

e) Storing and maintaining information related to you for our business operations or to fulfill legal obligations.

f) Providing local services without the need to communicate with our servers.

For more detailed information about how we use your information (which may include personal information), the following is provided:

a) Creating your USTAR account: Personal information collected when creating an account via the website or our mobile devices is used to establish a user's personal account and profile page.

b) Providing location-based services: When using USTAR and accessing USTAR-enabled devices, we may use location information to determine the device's time zone, ensuring accurate display of time on the device, and service location. This also includes activating corresponding devices in advance based on your preferences. You can access device settings at any time or stop using this application to disable this function.

c) Device access: Device operations via the app require verification of the device's authenticity, so we may need to verify the device's legitimate identity through factory MAC and DID information. Additionally, when devices need to connect to the network, they require corresponding network settings through the app. During this process, you may enter the Wi-Fi name and password, which is solely used for device configuration. The Wi-Fi and password data you provide will be encrypted and stored locally on the device, not uploaded to the server. You can delete this information from the device at any time. Furthermore, we need to determine the optimal connectivity method for the device based on IP and network signal to ensure stable device connectivity.

d) Device status display: You may remotely view the device's status, allowing you to monitor its operation at all times.

e) Setting automation tasks: Event information reported by your devices (information originating from devices you've added, with specific configurable information depending on your privacy authorization scope for that device, and each added device will provide privacy policy-related terms for you to choose whether to agree) can be used to create personalized automation tasks for you.

Whom do we share your information with?

We will not sell any personal information to third parties.

Sharing Information with Others

USTAR may disclose your personal information without further consent from you when required by applicable law.

Security guarantee

Security Measures at USTAR

We are committed to ensuring the security of your personal information. To prevent unauthorized access, disclosure, or similar risks, we have implemented reasonable physical, electronic, and managerial procedures to protect the information we collect from your use of the "Uone Smart" App. We will take all reasonable measures to safeguard your personal information.

For instance, when you access your USTAR account, you can choose to enable our two-step verification process for enhanced security. When you send or receive information from USTAR devices to our servers, we ensure encryption using secure socket layer (SSL) and other algorithms.

All your personal information is stored on secure servers and is protected within controlled facilities. We classify your data based on importance and sensitivity, ensuring the highest level of security for your personal information. We ensure that employees and third-party service providers who access this information to assist in providing you with products and services have strict contractual confidentiality obligations. Failure to fulfill these obligations may result in disciplinary action or termination of cooperation. Similarly, we have specific access control measures for cloud-based data storage. In summary, we regularly review information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.

We will take all feasible steps to protect your personal information. However, you should be aware that the use of the internet is not always secure, and therefore, we cannot guarantee the security or integrity of any personal information transmitted over the internet.

We will take appropriate measures in response to personal data breaches, such as reporting breach incidents to relevant regulatory authorities or notifying data subjects of personal data breaches in accordance with applicable laws, including local data protection laws.

What can you do?

a) You can play a role in protecting your personal information by not disclosing your login password or account information to anyone unless they have received your formal authorization. Whenever you log in to USTAR as an account user, especially on someone else's computer or a public internet terminal, you should always log out when the session is complete.

b) USTAR is not responsible for any breaches resulting from your failure to maintain the confidentiality of your personal information. Despite the above provisions, if there is any unauthorized use of your account by any other internet user or any other security breach, you must notify us immediately. Your cooperation will help us protect the confidentiality of your personal information.

Retention Policy

We will retain personal information as long as necessary to fulfill the purposes for which it was collected or as required by applicable law or permitted. If there are reasonable grounds to believe that retaining personal information can no longer achieve the purposes for which it was collected, we will no longer retain the personal information or associate it with specific individuals. USTAR may further retain data for further processing archives for public interest, scientific or historical research purposes, or for statistical purposes in accordance with applicable laws, even if the further processing purposes are inconsistent with the original purposes.

Access to Other Features on Your Device

Our applications may access certain features on your device, such as Wi-Fi network status. This information is used to allow these applications to operate on your device and allow you to interact with them. You can revoke permission at any time by disabling the application at the device level or by contacting us at salesvn@uonesmart.com.

You Can Control Your Personal Information

Control Settings

USTAR recognizes that everyone has different concerns about privacy. Therefore, we provide some examples of the various ways USTAR offers for you to choose to limit the collection, use, disclosure, or processing of your personal information and control your privacy settings:

a) Turn on or off location access.

b) Log in or log out of your USTAR account.

c) If you previously consented to our use of your personal information for the purposes mentioned above, you can change your decision at any time by contacting us in writing or by emailing salesvn@uonesmart.com.

Access, Update, Correct, Delete, or Restrict the Processing of Your Personal Information

a) You have the right to request access to and/or correction of any personal information we hold about you. When you update personal information, we may request verification of your identity before processing your request. Once we have sufficient information to process your request for access or correction of your personal information, we will respond to your request within the time frame prescribed by applicable data protection laws.

b) Upon your request, we may provide you with a copy of the personal data we collect and process free of charge. For any additional requests for the same information, we may charge reasonable fees based on applicable laws and actual administrative expenses.

c) If you wish to request access to personal data we hold or if you believe that any information we hold about you is incorrect or incomplete, please contact us in writing or via the email address provided below as soon as possible.

d) If you are an EU user governed by the "General Data Protection Regulation (GDPR)", you have the right to request the erasure of your personal information. If GDPR specifies such a requirement, we will consider the reasonableness of the erasure request and take reasonable steps, including technical measures if necessary.

e) If you are an EU user governed by the "General Data Protection Regulation (GDPR)", you have the right to restrict the processing of your personal information, and we will consider the reasonableness of the restriction request. If specified by GDPR, we will only process your personal information in accordance with applicable GDPR provisions and notify you before lifting the restriction.

f) If you are an EU user governed by the "General Data Protection Regulation (GDPR)", you have the right not to be subject to a decision based solely on automated processing (including profiling) that has legal effects on you or similarly significant effects.

g) If you are an EU user governed by the "General Data Protection Regulation (GDPR)", you have the right to receive your personal information in a commonly used structured format and transmit that information to another data controller.

h) More detailed information related to your personal information in your USTAR account can be accessed and changed by logging into your account on your device.

Transferring Personal Information Outside Your Jurisdiction

If we need to transfer personal information outside your jurisdiction, whether to our affiliated companies (involving communication, social media, technology, and cloud services) or third-party service providers, we will do so in accordance with applicable laws. Specifically, we ensure that all such transfers meet the requirements of local data protection laws through the implementation of appropriate security measures. You will have the right to be informed of the appropriate safeguards taken by USTAR for the transfer of your personal information.

USTAR is a global company headquartered in Vietnam. Therefore, while complying with applicable laws, we may transfer your personal data to any subsidiary of the USTAR Group worldwide for the purposes described in this privacy policy. We may also transfer your personal data to our third-party service providers, which may be located outside the European Economic Area (EEA) region.

If USTAR shares personal data originating from the EEA region with third parties, regardless of whether the third party is a subsidiary of USTAR outside the EEA, we will execute EU Standard Contractual Clauses or any other safeguards specified in GDPR.

USTAR may use overseas facilities operated and controlled by USTAR to process or back up your personal information. You acknowledge that the risks may vary under different applicable data protection laws, and we may transfer and store your personal information at our overseas facilities. However, this will not change our commitment to protecting your personal information in compliance with this privacy policy.

When you choose to use other third-party services within this product and service (such as Amazon Alexa, Google Assistant voice services, etc.), the third party may read your relevant information, and your relevant information may also be transferred to third-party servers outside your jurisdiction. You consent to such transfers in this scenario.

Other Provisions

Minors

a) We believe it is the responsibility of parents to supervise the use of our products and services by minors. However, our policy does not require obtaining personal information from minors or sending any promotional materials to this group.

b) USTAR will not seek or attempt to receive any personal information from minors. If parents or guardians have reason to believe that minors have provided personal information to USTAR without their prior consent, please contact us to ensure the deletion of such personal information and ensure that minors unsubscribe from any applicable USTAR services.

Priority Order

If you agree to applicable user agreements, and there is any inconsistency between such user agreements and this privacy policy, the user agreements shall prevail.

Privacy Policy Updates

We regularly review the privacy policy, and to reflect changes in our information practices, we may update this privacy policy. If we make significant changes to this privacy policy, we will notify you through email (sent to the email address associated with your account) or by posting in the "Uone Smart" App or via mobile device, so that you can understand what information we collect and how we use it. Such privacy policy changes will be effective from the date specified in the notification or website. We recommend that you regularly review this webpage to obtain the latest information about our privacy practices. Your continued use of our products, websites, mobile, and/or other services on any device will be considered as accepting the updated privacy policy. When we collect more of your personal information or wish to use or disclose your personal information for new purposes, we will seek your consent again.

Do I Need to Agree to Any Third-Party Terms and Conditions?

Our privacy policy does not apply to products and services provided by third parties. USTAR products and services may include products and services from third parties, as well as links to third-party websites. When you use these products or services, we strongly recommend that you take the time to read the privacy policy of the third party, just as you would read our policy. We are not responsible for how third parties use the personal information they collect from you, nor can we control its use. Our privacy policy does not apply to other websites linked through our services.

When you use the specific product extension services on the USTAR platform, the terms and privacy policies of third parties apply, and you will agree to the terms of each extension program.

How We Manage Your Personal Information Systematically?

If you are an EU user governed by the "General Data Protection Regulation (GDPR)", USTAR will provide:

Risk management means to provide a systematic approach to managing personal data related to our employees, management processes, and information systems. According to GDPR, USTAR will use processes such as (1) establishing a Data Protection Officer (DPO) responsible for data protection, with the contact information being salesvn@uonesmart.com; (2) establishing data protection impact assessments (DPIA), and other processes.

Contact Us

If you have any comments or questions about this privacy policy, or if you have any questions about USTAR's collection, use, or disclosure of your personal information, please contact our Data Protection Officer at the following address, mentioning "Privacy Policy":

USTAR COMPANY LIMITED

Hanoi, Vietnam

Email: salesvn@uonesmart.com

Thank you for taking the time to understand our privacy policy.