Privacy Policy

Last Updated: January 15, 2024

Company Name: Shanghai Jiangling Electromechanical Co., Ltd.

Registered Address: No. 3633, Shengang Road, Songjiang District, Shanghai

1. Introduction

We value your privacy and are committed to protecting your personal data. This privacy policy applies to our Door Tuning App, which is used to control elevator door machines via Bluetooth protocol. We process your personal data strictly in compliance with the European Union’s General Data Protection Regulation (GDPR). Please read the following information carefully to understand how we collect, use, and protect your information.

2. How We Collect and Use Your Personal Data

When using this App, we will collect and use the following information to enable Bluetooth device connection and elevator door control:

• Registration and Login Information: To create an account and verify user identity, you need to provide your phone number, email address, verification code, account name, and password. This information will be used for account registration, login, and password resetting.
• Bluetooth Connection Information: When you search for and connect Bluetooth devices, we collect the device’s MAC address, device name, connection status, etc., for device connection, management, and control.
• Location Information: When using the device location feature, the App collects GPS location data to provide precise positioning services and security monitoring. This data will be used to locate elevator equipment and record device operation history.
• Operation Logs and System Data: We will record your operations in the App, such as Bluetooth connections, device control, log queries, etc., for service analysis and improvement. This information may also be used for diagnosing and resolving technical issues.

3. How We Share, Transfer, and Disclose Your Personal Data

We do not sell or rent your personal data to third parties, but in the following cases, we may share, transfer, or disclose your data:

• Service Providers: To ensure normal service operation, we may share some of your data with third-party partners, such as those providing Bluetooth technology, GPS location, or data storage services. These partners will process your personal data in compliance with GDPR and implement the same level of protection as we do.
• Legal Requirements: If we are legally obligated to disclose your personal data, for example, in response to a lawful request by law enforcement or government authorities, we will disclose your data as required by law.
• Business Transfers: In the case of company restructuring, mergers, or sales, your personal data may be transferred as part of the assets. We will notify you in such cases and ensure the new party complies with this privacy policy.

4. Use of Cookies and Similar Technologies

We do not use cookies to store personal data in the App, but may use local storage to store device configuration data to quickly load Bluetooth device information when you use it next. You can clear these local storage data through your phone’s settings.

5. Your Rights

Under GDPR, you have the following rights:

• Right of Access: You have the right to request a copy of your personal data held by us. You can exercise this right through the App or by contacting our privacy department.
• Right to Rectification: If your personal data is inaccurate or incomplete, you have the right to request correction.
• Right to Erasure: In some cases, such as when your data is no longer relevant to the purpose of collection, you may request the deletion of your personal data. We will process your request promptly, unless we are required to retain data by law or contract obligations.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your data, for example, when you dispute the accuracy of the data.
• Right to Data Portability: You have the right to request that your personal data be provided in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.
• Right to Object: You can object to our processing of your personal data based on legitimate interests at any time. We will stop processing your data upon receiving your objection, unless we have compelling legal grounds to continue.

To exercise these rights, please contact us at: yu.mingliang@nbsl.com. We will process your request promptly and reply within a reasonable time frame.

6. Data Storage and Protection

We store your data on secure servers located within the EU and have implemented appropriate technical and organizational measures to prevent data loss, misuse, unauthorized access, disclosure, or alteration. All personal data will be retained during your use of the service and will be deleted or anonymized as required by law when no longer necessary.

• Data Encryption: We use encryption technology to protect data during transmission and storage.
• Access Control: Only authorized personnel can access your data, and we conduct regular system audits and security checks.
• Data Breach Response Plan: In the event of a data breach, we will notify users as required by GDPR and take appropriate measures to mitigate the potential impact.

7. GDPR Specific Provisions

In accordance with GDPR, we ensure the following to meet EU users' rights:

• Legal Basis for Processing: We process personal data based on user consent, contract performance, or legitimate interests. For processing location or Bluetooth device data, we will obtain your explicit consent in advance.
• Cross-Border Data Transfers: If data needs to be transferred outside the EU, we will ensure that such transfer complies with GDPR data protection standards, using appropriate safeguards such as Standard Contractual Clauses (SCCs) or Privacy Shield agreements.
• Data Portability: You have the right to receive your personal data in a machine-readable format and transfer it to another service provider.

8. Data Retention Period

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and will delete or anonymize it afterward.

• Registration Information: Deleted immediately after account cancellation.
• Location and Bluetooth Device Connection Data: Deleted immediately after account cancellation or when you stop using the App.
• Operation Logs: Stored for 30 days for technical support and security audits, after which it will be automatically deleted.

9. Policy Updates

This privacy policy may be updated due to legal, technical, or business changes. Any significant changes will be notified through in-App notifications to ensure that you are aware of the latest privacy protection measures.

10. Contact Us

If you have any questions regarding this privacy policy or wish to exercise your rights, please contact us at: yu.mingliang@nbsl.com

Phone: +86 4001120201

Address: No. 3633, Shengang Road, Songjiang District, Shanghai, Shanghai Jiangling Electromechanical Co., Ltd.

If you are unsatisfied with our response, particularly when our personal data processing activities have harmed your legal rights and interests, you can seek resolution through your local data protection authority.

For contact details of data protection authorities in other regions, please consult local government resources.http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm