Smart Home Screen Privacy Policy

I. General Provisions

1.1 Basis and Purpose of Formulation

To protect your personal information security and legitimate rights and interests, and to regulate the collection, use, storage, sharing, and other processing of personal information by this application, this Privacy Policy (hereinafter referred to as "this Policy") is formulated in accordance with internationally accepted privacy protection guidelines and industry standards such as the General Data Protection Regulation (GDPR).

This Policy applies only to the personal information processing activities of Smart Home Screen (hereinafter referred to as "this application") and does not apply to third-party applications, websites, or services (including system applications accessed through this application, Google services, etc.). When using third-party services, you should comply with their independent privacy policies, and we are not responsible for the information processing activities of third parties.

1.2 Definitions

Personal Information: Refers to various information recorded electronically or otherwise that relates to an identified or identifiable natural person (excluding anonymized data);

Sensitive Personal Information: Refers to personal information that, if leaked or illegally used, could easily lead to infringement of personal dignity or harm to personal or property safety;

Anonymization: Refers to the process of processing personal information through technical means to make it impossible to identify a specific natural person and to restore it;

Operator: Refers to the entity that develops and operates this application, hereinafter referred to as "we".

1.3 Policy Effectiveness and Scope of Application

This policy is an important part of the "Smart Home Screen Terms of Service" and has the same legal effect as the Terms of Service. By downloading, installing, or using this application, you indicate that you have fully read, understood, and agreed to all the contents of this policy. If you do not agree to this policy, you should immediately stop using this application.

II. Collection and Use of Personal Information

We adhere to the principles of "legality, legitimacy, necessity, and transparency," collecting only the personal information necessary to achieve the service functions and not collecting beyond the scope required.

2.1 Collection of Necessary Information

Necessary information is fundamental to ensuring the normal operation of this application's core functions. We will automatically collect this information after obtaining your authorization or upon application launch:

Usage Data Access: This type of data includes the names of applications you have recently used, the frequency of application use, and the most recent usage time. The collection of this data must be based on your explicit consent as a legal prerequisite: We will request your authorization via a pop-up window when you first use this application; you can choose whether to enable "Usage Data Access" permission in your device settings.

Basic Device Information: This includes device model, operating system version, device unique identifier, and network type. The purpose of collecting this information is to adapt to application functions, ensure operational stability, promptly fix technical vulnerabilities, and ensure that this application operates normally on your device.

Personalized Settings Data: This includes clock/date alignment, search bar position, and hidden app list settings. This type of information is actively set by you, and we save it to record your desktop personalization configuration to provide you with a consistent user experience.

2.2 Information Use Restrictions

We will only use your personal information within the following scope. Any use beyond this scope requires your explicit consent:

To provide and optimize the core services of this application;

To ensure service security, identify abnormal operations, and prevent malicious attacks and fraudulent activities;

To analyze user habits and optimize the application's functional experience;

To fulfill obligations stipulated by international privacy guidelines and the laws and regulations of your region.

2.3 Explanation of Information Collection

We will not collect personal information before you agree to this policy, and will only request necessary permissions when you use the corresponding functions;

We will not forcibly collect information unrelated to the service in any way, strictly adhering to the "least necessary" principle.

We will not collect sensitive personal information.

III. Storage and Protection of Personal Information

3.1 Storage Method and Duration

Storage Location: Your personal information will be stored on cloud servers that meet international security standards. Data storage will comply with the data localization requirements of your region. For cross-border data transfers, we will take compliant measures such as encrypted transmission and Data Processing Protocols (DPAs) to ensure compliance with the cross-border data flow rules of the target region.

Storage Period: Following the principle of "minimum necessary + reasonable period," your personal information will only be stored for the shortest time necessary to achieve the service purpose. Anonymized Information: Can be used for compliant purposes such as operational analysis without time restrictions (anonymized data cannot be associated with any specific natural person).

3.2 Security Protection Measures

We adopt internationally accepted technical and management dual security measures to protect the security of your personal information:

Technical Protection: We use SSL/TLS encrypted transmission technology to protect the security of information transmission; we use encrypted storage, access control, firewalls, and other technologies to prevent unauthorized access;

Management Standards: We have established an information security management system that complies with ISO/IEC 27001 standards, restricting information access permissions (only authorized personnel can access it); we provide privacy protection training and assessment for employees; we have developed a data breach emergency response plan, and in the event of a breach, we will notify you and relevant regulatory agencies within the time limit required by the laws and regulations of your region;

Security Reminder: Although we have taken the above security protection measures, please understand that the network environment has inherent uncertainties, and the development of information technology may also bring new security risks. We cannot guarantee the absolute security of personal information.

IV. Sharing, Transfer, and Disclosure of Personal Information

4.1 Legitimate Sharing Scenarios

Sharing with Third-Party Service Providers: We will only share personal information with rigorously screened third-party service providers who possess legal qualifications and robust data security capabilities, provided it is necessary to achieve the core functions or specific optional functions of this application.

Other Legitimate Sharing Scenarios: If we need to share your personal information due to changes in corporate operations such as mergers, acquisitions, or business restructuring, we will send you a clear notification in advance via in-application pop-ups, informing you of the recipient's identity information, the purpose of data processing, and security measures, and obtain your separate consent; if the recipient needs to change the purpose of data use, they must obtain your authorization separately. 4.2 Legally Approved Disclosure Scenarios

We will only disclose your personal information in the following legally permissible circumstances, and the scope of disclosure will be strictly limited to the minimum necessary to achieve the legal purpose:

In response to legal requests from judicial authorities, regulatory agencies, or administrative departments (such as court subpoenas, search warrants, regulatory investigation notices, etc.), and we have rigorously reviewed the legality and compliance of the relevant requests;

To protect the legitimate rights and interests of us, you, or third parties from imminent harm (such as preventing serious fraud, responding to personal safety emergencies, and preventing major illegal and criminal activities), within the scope permitted by law;

To fulfill disclosure obligations in accordance with international practice, arbitral awards, or effective legal instruments;

To maintain public interests (such as public safety, public health, public order, etc.), and subject to compliance with laws and regulations.

4.3 Prohibitions

We firmly prohibit any form of misuse of personal information and make the following strict commitments:

We will not transfer your personal information to any third party in any form (including sale, rental, exchange, donation, etc.) for commercial profit purposes;

We will not provide third parties with additional personal information beyond the necessary scope beyond the functionality, or allow third parties to collect, store, or transmit shared data a second time.

V. User's Personal Information Rights and How to Exercise Them

In accordance with Articles 15-20 of the General Data Protection Regulation (GDPR) and related supporting regulations, as the subject of personal information, you enjoy the following legal rights, and we will provide convenient support for you to exercise these rights:

5.1 Legal Rights and Specific Exercise Paths

(1) Right to Know and Right to Access

You have the right to know all aspects of how we process your personal information and to access your personal information.

(2) Right to Correction

If you find that your personal information stored by us is inaccurate or incomplete, you have the right to request that we correct or supplement it immediately.

(3) Right of Erasure

You have the right to request that we immediately erase your personal information in the following circumstances: ① The purpose of processing your personal information has been achieved and it is no longer necessary; ② You have withdrawn your consent to processing and there is no other legal basis for processing; ③ You object to processing for marketing purposes and there is no overwhelming legal reason; ④ The processing of your personal information violates GDPR or other laws and regulations; ⑤ Other circumstances where deletion is required by law.

(4) Right of Restriction of Processing

You have the right to request that we restrict the processing of your personal information in the following circumstances: ① You object to the accuracy of your personal information and it is under verification; ② The processing is illegal, but you do not wish to have your personal information erased; ③ We no longer need the personal information, but you need it for legal claims; ④ You have objected to processing and it is under evaluation of the legality of processing and the priority of your rights.

(5) Right of Data Portability

You have the right to request that we provide your personal information to you in a structured, commonly used, and machine-readable format (such as CSV, JSON, XML, etc.), or directly transfer it to other data controllers (if technically feasible).

(6) Right to Object

You have the right to object to our processing of your personal information in the following circumstances: ① Processing based on Article 6, paragraph 1(e) (public interest) or (f) (legitimate interest) of the GDPR, where your specific circumstances require the protection of your fundamental rights and freedoms, outweighing our legitimate interests; ② Processing for marketing purposes.

(7) Right to Withdraw Consent

You have the right to withdraw your consent to the processing of your personal information at any time. Withdrawal of consent will not affect the legality of the processing based on consent prior to withdrawal.

5.2 Protection of Rights

We promise not to discriminate against you (e.g., refuse to provide services, reduce service quality, etc.) on the grounds that you exercise your statutory rights under the GDPR, unless the exercise of such rights renders the relevant core services unavailable.

If you encounter obstacles in exercising your rights (e.g., inability to operate independently, lack of response, etc.), you can file a complaint with us through the contact information provided at the end of this policy. If you are dissatisfied with our processing results, you have the right to file a complaint with the data protection regulatory authority in your region (such as the data protection authority of an EU member state), and we will fully cooperate with the regulatory authority's investigation. You will not incur any fees to exercise the above rights. We may charge a reasonable administrative fee or refuse to provide additional copies only if your request is clearly unfounded, excessive, or repetitive.

VI. Third-Party Service Description

To achieve feature richness, this application integrates third-party services such as Google Play Services, Firebase, and Google Admob. The information processing behavior of these third-party services is not governed by this policy. Their collection, use, and storage of personal information comply with their own official privacy policies. We have rigorously screened all third-party service providers, requiring them to comply with international and regional privacy laws and regulations:

6.1 Details of Third-Party Services

Google Play Services

Functions involved: App adaptation, security, basic service support

Firebase

Functions involved: Data statistics, feature analysis, app crash monitoring

Google Admob

Functions involved: Ad display, ad performance statistics

Facebook

Functions involved: Personalized ad display, ad performance analysis

Pangle

Functions involved: Ad display

TopOn

Functions involved: Ad aggregation, ad display

6.2 Disclaimer

We only provide integration, redirection, or feature connection for third-party services and are not responsible for the information processing behavior of third parties (unless we are at fault for the processing behavior of third parties);

The collection and use of personal information by third-party service providers is premised on your authorization of the corresponding permissions to this application;

Please carefully read their official privacy policies before using the relevant functions of third-party services in this application to understand their rules on information collection, use, and sharing. Your use of the relevant functions of third-party services indicates your agreement to the privacy policy of that third party.

You have the right to opt out of personalized advertising services from third-party service providers. This can be done through your device's system settings (e.g., "Limit Ad Tracking" on Android devices, "Turn Off Personalized Ads" on iOS devices). After opting out, the third-party service will no longer display personalized ads based on your personal information; only general advertising content will be provided.

VII. Children's Privacy Protection

This application does not provide services to children under the age of 13 (complies with international child privacy standards such as COPPA and GDPR). We do not intentionally collect personal information from children under the age of 13. If a guardian discovers that a child has mistakenly used this application and submitted personal information, they can submit a deletion request to us via the contact email address. We will delete the relevant information immediately upon verification.

VIII. Updates to the Privacy Policy

We reserve the right to modify, supplement, or improve this policy based on changes in international privacy guidelines, service function upgrades, adjustments to third-party service cooperation, and revisions to laws and regulations. All policy updates will adhere to the principles of "legality, necessity, and transparency," ensuring that they do not increase your obligations or diminish your legitimate rights (unless otherwise stipulated by laws and regulations).

IX. Contact Information and Dispute Resolution

9.1 Inquiry and Complaint Channels

If you have any questions, suggestions, or complaints regarding this policy, please contact us through the following methods:

Contact Email: [email protected]

9.2 Dispute Resolution

The interpretation and dispute resolution of this policy shall be governed by the laws and regulations of your region (unless otherwise agreed, the laws and regulations of the location of the application's operator shall prevail). Any dispute arising from this policy shall first be resolved amicably through negotiation between the parties; if negotiation fails, either party shall have the right to file a lawsuit in a court with competent jurisdiction.

Effective Date: This policy shall take effect from the date of its publication. If you have any questions about this policy during use, you may consult us at any time through the above contact information.