Update Date: May 24, 2024 Effective Date: May 24, 2024
Welcome to PeatsAir!
Shenzhen Xingkeqi Innovative Technology Co., Ltd. (referred to as "we" or "Xingkeqi Innovative Technology" in this policy) deeply values the importance of your personal information and is committed to protecting your privacy. This PeatsAir Privacy Policy (hereinafter referred to as "this Policy") aims to explain to you (hereinafter referred to as "user" or "you") how we collect, use, store, share, transfer, and protect your personal information when you use the PeatsAir application (hereinafter referred to as "this App" or "this Service"), as well as the rights you are entitled to.
Before using this Service, please read and fully understand the entire content of this Policy, especially the terms marked in bold, which may significantly relate to your rights and interests. If you disagree with any part of this Policy, you should immediately stop using this Service. Once you start using this Service, it means you have fully understood and agreed to the personal information processing rules described in this Policy.
If you have any questions, comments, or suggestions regarding this Policy, please contact us through the methods described in [Section 10: Contact Us] of this Policy.
How we collect and use your personal information
How we use cookies and similar technologies
How we share, transfer, and publicly disclose your personal information
How we store your personal information
How we protect the security of your personal information
Your rights to manage your personal information
How we handle the personal information of minors
Updates to this Policy
Scope of application and governing law
Contact Us
Personal information refers to any information recorded electronically or otherwise that relates to an identified or identifiable natural person, excluding anonymized information. Sensitive personal information refers to personal information that, if leaked, illegally provided, or misused, may endanger personal or property safety, easily lead to damage to personal reputation, physical or mental health, or discriminatory treatment. Sensitive personal information involved in this Policy will be bolded for identification.
We will only collect and use your personal information for the following purposes described in this Policy:
1.1 Account Registration and Login
When you register a PeatsAir account, you need to provide your email address and create a password to complete the account creation. We collect this information to identify your user identity, provide you with continuous services, and ensure the security of your account.
If you refuse to provide your email address, you will not be able to register an account or use core features that require login.
1.2 Equipment Management
Device Connection and Management: To connect and manage your SOUNDPEATS devices (e.g., earphones) with this App, we need to collect your device information, including device name, model, device MAC address, unique device identifier (e.g., serial number), and Bluetooth information. This information is necessary for basic functions such as device binding, status display, and firmware updates.
Device Operation and Status Information: To ensure normal service operation and optimization, we will collect your device’s operating system version, app version, network type, and device settings (e.g., language).
1.3 Providing Additional Features and Service Optimization
When you use the following additional features, we will collect the corresponding personal information after obtaining your explicit consent. If you do not provide this information, it will not affect your use of the basic hearing test and device management functions, but you may not enjoy the enhanced user experience brought by these additional features.
(If applicable) Hearing Aid/Assistive Listening Features: If you use features related to hearing aids or assistive listening that require access to the device microphone, we will request microphone permission and process voice information (classified as sensitive personal information) input through the microphone. Such information is collected solely to implement the specific function (e.g., real-time sound amplification or processing). We will not store the original voice information unless it is necessary for the specific function and you have been explicitly informed and given consent. You can disable microphone permission in your device system settings at any time.
User Experience Improvement and Analysis: To understand product usage, optimize user experience, and troubleshoot issues, we may collect device information (e.g., device model, OS version, app version, unique device identifier (such as Android ID/IDFA/OPENUDID/GUID, depending on your device system), language settings, carrier network type, and other hardware/software characteristics), log information (including your operation records, service usage, IP address, crash logs). Please note that standalone device information or log information cannot identify a specific individual. If we combine such non-personal information with other information to identify a specific individual or use it alongside personal information, such non-personal information will be treated as personal information during the combined use. Unless authorized by you or required by law, we will anonymize or de-identify such personal information.
Push Notifications: To send you device status notifications, activity updates, or important reminders, we may use your device identifier (e.g., device token) and system push services. You can manage or disable push notifications in your device system settings or in-app settings.
(If applicable) Customer Service and Feedback: When you contact us for inquiries, feedback, or complaints, we may need you to provide necessary personal information (e.g., account information, contact details, records or screenshots related to your feedback) to verify your identity and address your issue.
1.4 Ensuring Secure and Stable Service Operation
Security Assurance: To enhance the security of your use of our services, protect you or other users or the public from harm, and prevent risks such as phishing, fraud, network vulnerabilities, computer viruses, cyberattacks, or unauthorized access, we may collect or integrate your account information, device information (including device MAC address, software list information (for risk identification), unique device identifiers such as IMEI/Android ID/IDFA/OPENUDID/GUID, SIM card IMSI information (we will avoid collecting this unless necessary for security risk assessment)), network logs, and information shared by our affiliates or partners under your authorization or as permitted by law. This helps us comprehensively assess your account and transaction risks, perform identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and handling measures as required by law. We only collect such information when you launch the App or perform critical operations.
Self-starting/Associated Startup Explanation: To ensure this App can receive device connection status changes, firmware update reminders, or critical security notifications when closed or running in the background, this App may require self-starting or associated startup capabilities in specific scenarios. This may involve waking up the App through system broadcasts. This is necessary to implement the aforementioned functions and services. We will strive to minimize the frequency and necessity of such activations.
1.5 Permission Requests
To achieve the above functions, we may need you to grant the following device permissions. We will seek your consent separately via pop-ups or other means when you first use the relevant features. You can manage these permissions in your device system settings at any time. Please note that disabling certain permissions may affect your use of related features.
Storage Permission (Read/Write): Used to cache necessary data (e.g., audiograms, device information), store downloaded firmware, and read or save user settings to improve efficiency and user experience.
Bluetooth Permission: Used to discover, connect, and manage your SOUNDPEATS devices.
Location Permission (Only required for Bluetooth device connection on specific Android versions): Some Android versions require location permission to scan for Bluetooth devices. We only use this permission during Bluetooth scanning and do not collect your precise real-time location information.
Microphone Permission: Used to implement hearing aid/assistive listening features that require sound input (if applicable).
Notification Permission: Used to send you device status or activity update notifications.
1.6 Exceptions to Obtaining Authorization and Consent
Under relevant laws and regulations, we may collect and use your personal information without your authorization or consent in the following circumstances:
Related to fulfilling our legal obligations;
Directly related to national security or defense;
Directly related to public safety, public health, or significant public interests;
Directly related to criminal investigation, prosecution, trial, or execution of judgments;
Necessary to protect your or others' life, property, or other significant legitimate rights but difficult to obtain consent;
The personal information is voluntarily disclosed by you to the public;
Necessary for signing or performing a contract at your request;
Collected from legally publicly disclosed information, such as legitimate news reports or government disclosures;
Necessary to ensure the secure and stable operation of our products or services, such as identifying or resolving product or service failures.
To ensure the normal operation of this App and provide you with a smoother access experience, we may store small data files called Cookies or use similar technologies (e.g., local storage, web beacons, pixel tags) on your device.
Cookies: Typically contain identifiers, site names, and numbers/characters. With Cookies, we can store your preferences and determine whether registered users are logged in, improving service/product quality and optimizing user experience.
Similar Technologies: For example, we may use local storage to cache persistent data (e.g., device identifiers, user preferences) locally to enhance loading speed and operational efficiency.
We will not use Cookies or similar technologies for purposes beyond those stated in this Policy. You can manage or delete Cookies based on your preferences. You may refuse or manage Cookies through browser or device system settings. However, disabling Cookies or similar technologies may affect your service experience, and some features may not function properly.
3.1 Sharing
We will not share your personal information with any company, organization, or individual outside Soundpeats Innovative Technology, except in the following cases:
With Your Explicit Consent: We will share your personal information with others after obtaining your explicit consent.
Sharing Under Legal Circumstances: We may share your personal information as required by laws, dispute resolution needs, or administrative or judicial authorities.
Sharing with Affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information, bound by the purposes stated in this Policy. If affiliates change the purpose of processing, they will seek your authorization again.
Sharing with Authorized Partners: Certain services may be provided by authorized partners. We may share some of your personal information to improve customer service and user experience, such as technical support or data analysis providers. We will only share personal information necessary for the service and ensure partners do not use it for other purposes.
We sign strict data processing agreements with partners, requiring them to process personal information per our instructions, this Policy, and other confidentiality/security measures. We require data protection measures like encryption or anonymization.
Third-Party SDKs: To ensure stable operation and feature implementation, our App may integrate authorized partners' SDKs or similar applications. We conduct strict security checks on SDKs and require partners to adopt data protection measures. Typically, SDKs collect device identifiers (e.g., IMEI/IDFA/Android ID/MAC/OAID/OpenUDID/GUID), device information (e.g., model, OS), IP address, location (roughly inferred via IP/Bluetooth/Wi-Fi), app list information, etc. Currently, no third-party SDKs are integrated.
3.2 Transfer
We will not transfer your personal information to any company, organization, or individual, except:
With Your Explicit Consent: After obtaining your explicit consent.
Mergers, Acquisitions, or Bankruptcy: In cases involving mergers, acquisitions, asset transfers, or similar transactions, if personal information is transferred, we will require the new holder to comply with this Policy or seek your authorization again.
3.3 Public Disclosure
We will only publicly disclose your personal information in the following cases:
With Your Explicit Consent.
Based on Legal Requirements: If required by laws, legal procedures, litigation, or government authorities.
3.4 Exceptions to Authorization for Sharing, Transfer, or Public Disclosure
Under applicable laws, sharing, transferring, or publicly disclosing anonymized personal information that cannot be re-identified does not require prior notice or consent.
Additionally, in cases described in [Section 1.6], sharing, transferring, or publicly disclosing your personal information does not require prior authorization.
4.1 Storage Location
In principle, the personal information we collect and generate during operations will be stored within the jurisdiction required by applicable laws.
We comply with data protection laws regarding storage locations.
If cross-border data transfer is necessary for business needs or service provision, we will strictly comply with applicable laws (e.g., China’s Personal Information Protection Law, EU’s GDPR) to ensure your personal information receives adequate protection. In such cases, we will inform you of the purpose, recipient, type of personal information, security measures, and your rights regarding overseas recipients, and obtain your authorization if required by law.
4.2 Storage Duration
We will retain your personal information only for the period necessary to achieve the purposes stated in this Policy or as required by laws (e.g., China’s Cybersecurity Law mandates network logs be kept for at least six months). For example:
Your account information will be retained during your use of the service until you delete your account.
Your audiogram data will be retained during your use of the service until you delete it or deactivate your account.
After the retention period expires, we will delete or anonymize your personal information unless otherwise required by law. Anonymized information cannot identify you and may be used by us.
4.3 Service Termination Notice
If our product or service ceases operation, we will notify you at least 30 days in advance via push notifications or announcements and delete or anonymize your personal information within a reasonable period.
5.1 We have implemented industry-standard, reasonable security measures to protect your information from unauthorized access, disclosure, alteration, damage, or loss. For example, we use SSL encryption for data transmission; trusted mechanisms to prevent malicious attacks; access controls to restrict personal information access to authorized personnel; and security/privacy training for employees.
5.2 We use AES256 or stronger encryption algorithms to store your sensitive personal information (e.g., audiogram data) and enhance security with data masking (e.g., processing displayed information).
5.3 We have established strict information security management systems and dedicated teams to ensure personal information security. We will take all reasonable steps to avoid collecting irrelevant personal information.
5.4 While the internet is not 100% secure, we strive to ensure the security of any information you send us. If our physical, technical, or administrative safeguards are breached, compromising your rights, we will assume legal liability.
5.5 In the event of a personal information security incident, we will promptly notify you per legal requirements, including: the incident’s details and potential impact, measures taken or to be taken, self-protection suggestions, and remedial actions. We will notify you via email, letter, phone, or push notifications. If individual notice is impractical, we will issue a public announcement. We will also report the incident to regulators as required.
5.6 Please safeguard your account credentials (email and password). We strongly advise against sharing them. Always log out after use. If your personal information is compromised, especially your account or password, contact us immediately via [Section 10: Contact Us] for further action.
Under relevant Chinese laws, regulations, and standards, you have the following rights regarding your personal information:
6.1 Access Your Personal Information
You may access your personal information, unless legally exempt. You can do so via:
Account Information: Visit the "Me" or "Settings" page in the App to view or edit your profile (e.g., email, password).
Usage Records: View your hearing test records (audiograms) in the App.
If you cannot access certain information, contact us via [Section 10: Contact Us].
6.2 Correct Your Personal Information
If you find errors in your personal information, you may request corrections or supplements via the methods in 6.1.
6.3 Delete Your Personal Information
You may request deletion in the following cases:
If our processing violates laws;
If collection/use lacked your consent;
If our processing breached agreements with you;
If you stop using our services or deactivate your account;
If we no longer provide services to you.
Request deletion via in-app functions (e.g., deleting audiograms) or [Section 10: Contact Us]. Upon deletion, we will also notify entities that received your information to delete it, unless otherwise required by law or authorized by you.
Note: Deleted information may not be immediately removed from backups but will be deleted or anonymized during backup updates.
6.4 Change Your Authorization Scope
Core features require basic personal information. For additional information, you may grant or withdraw consent via:
Disabling permissions in device system settings (e.g., microphone, storage, notifications).
Contacting us via [Section 10: Contact Us].
Withdrawing consent does not affect prior processing based on your authorization.
6.5 Deactivate Your Account
You may deactivate your PeatsAir account via in-app paths (e.g., "Settings" - "Account & Security") or [Section 10: Contact Us].
After deactivation, we will stop providing services and delete or anonymize your personal information as required by law. Account deactivation is irreversible.
6.6 Obtain a Copy of Your Personal Information
You may request a copy of your personal information via [Section 10: Contact Us]. After verifying your identity, we will provide it.
6.7 Restrict Automated Decision-Making
If automated decisions (e.g., algorithms) significantly affect your rights, you may request explanations or remedies, provided trade secrets or others' rights are not compromised.
6.8 Responding to Your Requests
For security, we may require written requests or identity verification. We will respond within 15 working days. Reasonable requests are free, but repeated or excessive requests may incur fees.
We may refuse requests that are:
Related to legal obligations;
Related to national/defense security;
Related to public safety/health/interests;
Related to criminal investigations/proceedings;
Made in bad faith or abusive (e.g., harming public/others' rights or technically infeasible);
Necessary to protect life/property but hard to obtain consent;
Seriously harmful to others if fulfilled;
Involving trade secrets.
This Service is primarily for adults. We do not actively collect personal information from minors under 14 ("children") without parental consent. Children should not create accounts without parental permission.
For children’s information collected with parental consent, we will only use or disclose it as legally permitted, with parental consent, or to protect the child.
If we discover unintentional collection of children’s information without verifiable parental consent, we will delete it promptly. If you believe we hold children’s information inappropriately, contact us via [Section 10: Contact Us].
We may update this Policy occasionally.
We will not reduce your rights under this Policy without your explicit consent. Updates will be posted on this page.
For significant changes, we will provide prominent notice (e.g., in-app pop-ups, push notifications, or emails) explaining the changes. Significant changes include but are not limited to:
Major changes to our service model (e.g., purposes, types of personal information, usage methods);
Major changes in ownership or structure (e.g., business adjustments, mergers);
Changes in primary recipients of shared/transferred/disclosed personal information;
Major changes to your rights or how to exercise them;
Changes to our security responsibility department, contact details, or complaint channels;
High risks identified in personal information security impact assessments.
We will archive previous versions of this Policy for your reference. Your continued use of our services constitutes acceptance of the updated Policy.
9.1 This Policy applies only to the PeatsAir App and related services. It does not apply to third-party services (e.g., websites, apps, or SDKs) accessed through our services, which may have their own privacy policies.
9.2 This Policy shall be governed by the laws of Mainland China. Any disputes shall be resolved through friendly negotiation; if negotiation fails, either party may sue in a competent court at the defendant’s domicile.
If you have questions, comments, suggestions, complaints, or reports regarding this Policy or personal information processing, contact us via:
Company Name: Shenzhen Xingkeqi Innovative Technology Co., Ltd.
Email: [support@soundpeats.com]
Registered Address: [Room 1308-1309, Block B, Huihai Plaza, Chuangye Road, Longhua Street, Longhua District, Shenzhen]
We will generally respond within 15 working days after verifying your identity. If dissatisfied, you may complain to cyberspace, telecom, public security, or market regulators, or sue in a competent court.