Pet Access Privacy Policy

Our Commitment to You

This Privacy Policy outlines how the APP collects, uses, discloses, processes, and protects any personal data you provide when using our software and/or services. If we request that you provide certain information that can identify you while using our software and services, such information will only be used in accordance with this Privacy Policy, our Terms and Conditions, and/or applicable laws. This Privacy Policy is intended to help you understand how we collect, use, disclose, or otherwise process the personal data you provide to us, and to assist you in making informed decisions when using our software and/or services or when disclosing personal data to us in any other way.

In this Privacy Policy, such personal information may include, but is not limited to, information you provide or upload to us, device information, etc.

By using our software and/or services, you acknowledge that you have read, understood, and agreed to all the provisions of this Privacy Policy, including any changes we may make from time to time.

If you have any concerns about our data processing practices as outlined in this Privacy Policy, please contact our Data Protection Officer. We are happy to address any concerns you may have.

What Personal Data/Information We Collect and How We Use It

Types of Personal Data/Information Collected

In order to provide you with our services, we may require you to provide personal data necessary for us to offer these services. If you do not provide the personal data, we may be unable to offer you our services.

Generally, we do not collect your personal data unless:

You directly provide it to us or disclose it through a third party (your "Authorized Representative") that you have formally authorized, and (i) you (or your Authorized Representative) are informed of the purpose for collecting the data, and (ii) you (or your Authorized Representative) have given written consent for the collection and use of your personal data for these purposes;
Under applicable laws, you are deemed to have consented to the collection of your data;
Under applicable laws, the collection and use of your personal data are permitted or required without consent.

Before collecting any additional personal data, or before using your personal data for purposes that were not previously notified to you (except where permitted or authorized by law), we will seek your consent.

Depending on your interactions with us, we may collect network information, location data, login account information, mobile-related information, and more. These include but are not limited to the following:

Login Account Information: APP account, username, profile picture, email-related information, etc.
Mobile-Related Information: Hardware device identifiers (IMEI/OAID, MAC address, Android ID, device SN), phone model, system version information, system language, the country or region set on the phone, app store version number, phone screen size and resolution, CPU and display device-related information.
Network Information: When your smart device connects to a network, we may collect network-related information, including Wi-Fi signal strength, RSSI, current connection mode, IP address, MAC address, device’s network status with the phone, device’s network status with the server, device’s online status (including online and offline), and Wi-Fi name (SSID), Wi-Fi password, etc., which you actively provide.
App Updates: To ensure you continuously enjoy the latest Pet Access services, we may use your app version information and phone model to provide you with updates for the Pet Access app.
Other Information: We may collect feedback you provide, feedback logs, and email addresses you enter. We may also collect other non-personally identifiable information, such as statistical data generated when you use specific services, including users' operational behaviors (including clicks, page transitions, and browsing time). Additionally, we may also request access to certain device permissions. Below is a list of business functions corresponding to the permissions requested, the purposes for which we request them, and whether we seek your consent before doing so. You can choose to disable some or all of these permissions in the device settings to refuse our request for these permissions.

Device Permissions	Corresponding Business Functions	Purpose of Use	Consent Requested
Location	Location services, add device	To obtain users' location information for device services (e.g., installation), and to display nearby Wi-Fi or Bluetooth lists when adding a device	Yes
Camera	Add device, set profile picture	To take photos, upload images, and scan QR codes	Yes
Album	Set profile picture download video	To write and read users' album information	Yes
Storage	Set profile picture, app upgrades	To write and read users' album information	Yes

How We Use Your Personal Data/Information

The purpose of collecting personal data is typically to provide you with services and to comply with applicable laws. By providing your personal data to us, you agree that we may collect, use, process, and disclose (including transfer) your personal information to our affiliates, third-party service providers (as defined below), in accordance with this Privacy Policy and applicable laws. If you do not agree with this Privacy Policy, please do not provide any personal information to us.

We may use your personal information for the following purposes:

To provide, process, maintain, improve, and develop our services, including offering services via our website and application.
To execute and/or enforce the terms and conditions in necessary situations.
To communicate with you regarding your services or any general inquiries, such as updates, customer support, information and notifications related to our activities, and to respond, handle, and process your inquiries, requests, applications, complaints, and feedback.
To store and maintain your information for business operations or legal obligations.
To provide local services without communication with our servers.
To verify your identity, update your personal information and contact details, and manage our business relationship with you.
To send you information about our services.
To improve our applications, software, and services.
To promote our products, applications, software, and services, including via email, in-app notifications, phone calls, text messages, or faxes.
For any other purposes you provide information for.
To comply with any applicable laws, regulations, business codes, guidelines, or rules, or assist any government and/or regulatory agencies in enforcement and investigations, or provide assistance for legal purposes.
For the above purposes, transmit your personal data to third-party service providers, agents, and other entities we engage (including subcontractors who process your personal data) as well as relevant government and/or regulatory bodies within and outside the applicable jurisdiction.
Any other purposes reasonably related to or incidental to the above purposes.

Who We Share Your Information With

We do not sell, trade, or rent any personal information to third parties.

When Necessary to Provide Services

During the course of providing services or in connection with it, we may disclose your personal data if necessary to fulfill our obligations.

Sharing Information with Third Parties

We may disclose and share your personal data with the following parties:

Within Our Company Organization: The company is part of a company organization that includes multiple legal entities, business processes, management structures, and technical systems. We may share your personal data with our affiliated companies or, in some cases, other subsidiaries of our corporate group for business maintenance and personalized continuity purposes, such as enabling you to enjoy a personalized user experience in our services, offering customized services, or taking action according to your requests or preferences.
Service Providers: We may share your personal data with third-party service providers listed in the table below:

Vendors/Service Providers/Processors	Services Provided
IT Systems and Software Providers	Website hosting services (including cloud storage), mobile application or software optimization services, customer relationship management software, email service providers or system maintenance services.
Marketing and Advertising Services	Assist in reaching potential new customers through various communication channels, or collaborate with affiliates promoting our products and/or services on their websites.
Customer Service Providers	Assist with customer service and support.
Fraud Prevention and Data Security Providers	Identity verification, fraud prevention, or credit risk reduction services to protect our website/applications and our business.

According to our written instructions, we strive to ensure that our third-party service providers can only use your data for the purposes provided to them and within the necessary scope of those purposes.

Consent: With your consent, we may disclose your personal data for any purpose.

Third-Party SDKs Involved in Information Collection During APP Use:

Third-Party SDK Name	Provider	Information Collected	Purpose of Information Collection/Use	Applicable Operating Systems	Privacy Policy Details
Google Analytics	Google Inc.	Device SN, device identification information (IMEI [for Android versions below Q], MAC address, Android ID, IDFV, OpenUDID, GUID), SIM card, IMSI, ICCID, IP, and SD card.	To collect statistics and report application errors to improve the APP's stability.	Android and iOS	Google Privacy Policy
Google Location Services	Google, Inc.	Device identification information (IMEI [for Android versions below Q], MAC address, Android ID, OpenUDID, GUID), and location information (approximate location).	To match service providers near the user's area for quick on-site service.	Android	Google Location Services
FCM Push	Google	List of running applications.	To send push notifications, including APNS, for users of overseas devices receiving push messages. These messages are sent to the phone's system notification bar.	Android	Firebase Data Processing Terms
360 Reinforcement	Qihoo 360 Technology Co. Ltd.	None (Since the Taobao SDK collects device identifiers such as IMEI, IMSI, and Android ID, after the APP is hardened by the Bangcle security framework, it will appear as if the Bangcle framework collects IMEI, IMSI, and Android ID).	None	Android	Bangcle Security Framework

Sharing Information with Others

In accordance with written guidelines issued by applicable laws, the APP may disclose your personal information without your consent or further consent when permitted.

Control Over Your Information

Email Communication: We may occasionally send you emails regarding updates to our services, notifications from our organization, or information about products/services we offer that we believe you may be interested in. If you wish to unsubscribe from these emails, simply click the "unsubscribe link" at the bottom of the emails. Please note, you cannot unsubscribe from certain service-related communications (e.g., account verification, transaction confirmations, technical or legal notices).
SMS: We may use the personal information we collect to communicate with you via SMS, including (with your consent) sending you marketing messages or updates about products or services we believe you may be interested in. You can unsubscribe from further marketing SMS messages at any time by replying with “STOP” or clicking the unsubscribe link (if available) in any of our messages.
APP Notifications: We may send you notifications through the APP, including occasional marketing notifications. You can disable such notifications in the account settings provided in the app.

Information That Does Not Require Consent

This privacy policy does not apply to aggregated information, such as statistical data about user groups, that does not include names, contact information, or any other information that could identify a specific individual.

For business purposes, we may share anonymous information and statistical data with third parties (e.g., advertisers on our website), such as general usage trends of our services (e.g., the number of customers in specific demographic groups who purchase certain products or perform certain transactions).

We reserve the right to disclose your personal information as required by law or when we deem it necessary to protect our rights and/or comply with legal processes, court orders, regulatory requests, or other legal proceedings.

We may also disclose your information if we believe such disclosure will help protect the rights, property, or safety of our company or our customers in situations we deem reasonable, such as in the execution of our agreements or policies.

Security Measures

We are committed to safeguarding your personal information. To prevent unauthorized access, disclosure, or other similar risks, we have implemented reasonable physical, electronic, and managerial measures to protect the information collected when you use our products and services. We take all reasonable steps to ensure the security of your personal information.

All your personal information is stored on secure servers and protected in controlled facilities. We classify your data based on its importance and sensitivity, ensuring that your personal information is appropriately secured. We guarantee that employees and third-party service providers who access this information to assist in providing products and services to you are bound by strict confidentiality agreements. Any failure to fulfill these obligations will result in disciplinary actions or termination of cooperation. In summary, we regularly review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access and use.

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

Managing Your Personal Information

Concerns about privacy vary from person to person. Therefore, we provide several options within the APP for you to manage your personal information and control your privacy settings:

Turn on or off location access, camera, microphone, Bluetooth, HomeKit, and read/write storage permissions.
Agree or disagree when the privacy policy window pops up.
Log in or log out of your APP account.
Modify your personal information, such as your nickname and profile picture, by clicking "My" in the platform.

Data Retention Policy

We will retain personal information as necessary to achieve the purposes for which it was collected or to comply with applicable legal requirements. We will delete personal information or anonymize data that can no longer achieve the purpose for which it was collected, once it is reasonably concluded that retention is no longer necessary, or if it is no longer required for legal, dispute resolution, enforcement of our agreements, or other business purposes.

Accessing Other Device Features

Our application may require access to certain features on your device, such as Wi-Fi network status. This information allows the application to function properly on your device and enables you to interact with the application. Additionally, to address risks such as personal information leakage, damage, or loss, we have developed several policies to define the classification and handling processes for security incidents and vulnerabilities. In the event of a personal information security incident, we will promptly notify you of the situation via email, letter, push notification, or other means, in accordance with legal and regulatory requirements.

Access, Update, Correct, or Delete Your Personal Information

You have the right to request access to and/or correct any personal information we hold about you. When you update your personal information, we will ask you to verify your identity before processing your request. Once we have sufficient information to fulfill your request to access or correct your personal information, we will respond within the time limits set by applicable data protection laws (unless otherwise required by law). If we are unable to provide any personal data or correct it as requested, we will normally inform you of the reasons we cannot do so (unless otherwise required by applicable data protection laws).

We will provide you with a copy of the personal data we collect and process about you, free of charge, unless the request incurs a reasonable fee. For additional requests for the same information, we may charge a reasonable fee based on actual administrative costs, as permitted by applicable law. If this is the case, we will inform you of the charges before processing your request.

If you wish to access the personal data we hold about you or if you believe any of the information we hold about you is incorrect or incomplete and you wish to submit a correction request, please submit the request to the Data Protection Officer by using the following contact information.

Depending on the applicable regulations in your location, you may have the right to request the deletion of your personal data. We will evaluate your request and, if it meets the relevant requirements, take appropriate measures, including using technical means to process the request. When you delete or assist in deleting the relevant information, we may not immediately be able to remove the information from our backup systems due to applicable laws and security technology. We will securely store your personal data and refrain from further processing it until the backup can be cleared or anonymized.

Withdrawal of Consent

This can be done through the settings where you can withdraw your authorization for the Terms of Use and Privacy Policy. We will process your request within a reasonable time after you make it, and, upon your request, we will no longer collect, use, and/or disclose your personal information.

Please note that withdrawing your consent may lead to certain legal consequences. Depending on the scope of your withdrawal of consent for us to process your personal information, this may mean you will not be able to enjoy some or all of the products or services offered by Pet Access.

Accuracy of Personal Information

We generally rely on the personal data provided by you (or your authorized representative). To ensure that your personal data is up-to-date, complete, and accurate, please notify our Data Protection Officer if your personal data changes.

Rights of California Residents under the CCPA

If you are a resident of California, the following section applies to you in addition to the rest of this Privacy Policy. Unless exemptions under the 2018 California Consumer Privacy Act ("CCPA"), and its amendments by the 2020 California Privacy Rights Act, apply to you or your personal information, you have the right to:

Require us to disclose to you, free of charge, for a period of 12 months prior to the date of your request:
1. the categories of your personal information that we have collected;
2. the categories of sources from which we have collected your personal information;
3. the purposes for which your personal information was collected; and
4. the categories of third parties to whom we have disclosed your personal information and, if applicable, the categories of personal information disclosed and the purposes for which your personal information was disclosed; and
5. the specific personal information about you that we have collected.
Request that we delete any personal information we have collected from you, except in cases where the CCPA provides exemptions.
Not be subject to unlawful discrimination for exercising your rights under the CCPA, including being offered different levels or quality of services or being denied goods or services when exercising these rights.
You have the right to opt-out of the use or disclosure of your personal information. If you have previously consented to our processing of your personal information, you can withdraw that consent at any time and opt out of further processing by contacting our Data Protection Officer. To provide you with our services, we require personal information necessary for providing these services. If you do not provide your personal information, we may not be able to provide you with our products or services. Even if you opt out, we may still collect and use non-personal information about your activities on our website and/or third-party websites for non-interest-based advertising purposes, such as determining the effectiveness of ads.

Our goal is to complete your request within 45 days after verifying your identity under the CCPA. If necessary, we will extend the response time by another 45 days, and we will explain the reason for the delay.

Transfer of Personal Information Outside Your Jurisdiction

If we need to transfer personal information outside of your jurisdiction, whether to our affiliates (engaged in communications, social media, information technology, and cloud computing businesses) or third-party service providers, we will do so in accordance with applicable laws. Specifically, we will take measures to ensure that your personal data remains protected.

Miscellaneous

Minors

By using this website, you represent that you are at least of legal age in the United States and that you have consented to allow any minor dependents to use this website.

We believe that it is the responsibility of parents to supervise their children's use of our services. However, our policy is not to require minors to provide personal information, nor do we send marketing materials to minors.

The APP does not seek or intend to collect any personal information from minors. If a parent or guardian believes that a minor has provided personal information to the APP without prior consent, please contact us to ensure the information is deleted and to unsubscribe from any applicable APP services.

Priority

This Privacy Policy applies in conjunction with any other notices, contractual terms, and consent agreements applicable to our collection, use, and disclosure of your personal data. If you have agreed to our user agreement, in case of any inconsistency between such User Agreement and this Privacy Policy, the terms of the User Agreement will prevail.

Updates to Privacy Policy

We regularly review and update our Privacy Policy to reflect changes in our information practices. If we make significant changes to this Privacy Policy, we will notify you of these changes through email (sent to the email address associated with your account) or through notifications on all Pet Access websites or mobile devices to ensure you fully understand and agree before using the updated Privacy Policy.

Significant changes to this Privacy Policy include, but are not limited to:

Major changes in our products or service patterns, such as changes in the purposes for processing personal information, types of personal information, or how personal information is used.
Significant changes in ownership and organizational structures, such as business adjustments, bankruptcy, mergers, or acquisitions.
Major changes in the parties with whom we share, transfer, or disclose personal information.
Significant changes in your rights concerning personal information processing and how those rights can be exercised.
Changes in the department responsible for personal information security, contact information, or complaint channels.
High-risk findings in personal data security impact assessments.

If you do not accept the updated changes, we may not be able to provide you with the corresponding services, and you will bear the consequences. Therefore, please carefully read and confirm the updated content carefully!

These changes will take effect from the date specified in the notification or on our website. We recommend that you regularly check this page for the latest information on our privacy practices. Your continued use of the products, website, mobile app, and/or the services on any other devices will be deemed as acceptance of the updated Privacy Policy. If we collect more personal information from you or wish to use or disclose your personal information for new purposes, we will seek your consent again.

If you have agreed to the applicable User Agreement and there is an inconsistency between that User Agreement and the updated Privacy Policy, the updated Privacy Policy shall prevail.

Do I have to agree to third-party terms and conditions?

Our Privacy Policy does not apply to products and services provided by third parties. The APP service may include links to third-party products, services, or websites. When you use these products or services, they may also collect your information. Therefore, we strongly recommend that you read the privacy policies of third parties just as you take the time to read our Privacy Policy. We are not responsible for and cannot control how third parties use your personal information. They collect such information from you. Our Privacy Policy does not apply to other websites linked to our services.

Contact Us

If you have any comments or questions about this Privacy Policy or concerns about how we collect, use, or disclose your personal information, please contact us using the contact information below and referring the "Privacy Policy." For any rights requests or inquiries related to your personal information, we will arrange for a professional team to contact you within 15 working days and resolve your issue promptly upon confirming your information. If your inquiry involves significant matters, we may request more information from you. If you are not satisfied with the response you receive, you can escalate the complaint to the relevant regulatory authority in your jurisdiction. If you consult with us, we will provide information on potential complaint channels that may be applicable to your situation.

Contact Information

LAYSON TECHNOLOGY GROUP LIMITED

Address: Room 22,11/F,China United Plaza,1008 Tai Nan West Street,Lai Chi Kok,Kowloon,Hong Kong

Thank you for taking the time to read our Privacy Policy!