Chervon IoT Platform Privacy Policy


This Policy is designed to explain to you:


  1. Our role

  2. What information we collect about you

  3. How we use your information

  4. How we use cookies and similar technologies

  5. The circumstances in which we share your information

  6. The circumstances in which we publicly disclose your information

  7. How we store your information

  8. How we protect your information

  9. Your rights

  10. Account cancellation and personal information deletion

  11. How we protect minors' information

  12. How you can contact us

  13. Clause Update


Introduction

Chervon believes that the users' trust is essential, and Chervon understands how important users' personal information is to them. Chervon will collect personal information from the user in line with applicable laws and regulations, and to a reasonable and necessary extent. Chervon will make every effort to prevent users' data from being leaked, damaged or lost through the application of appropriate and effective information security technology and management processes, and will take corresponding security protection measures. To that end, Chervon IoT Platform Service Provider (hereinafter referred to as ‘We’) has drawn up this Privacy Policy. We would draw your attention to the fact that:

This Policy applies to all products and services provided to you by Chervon IoT Platform Service Provider in the form of websites, applications and new forms of technology developed by Chervon. The ‘Chervon IoT Platform’, as described in this Policy, refers to Nanjing Chervon Industry Co., Ltd. (hereinafter referred to as ‘Chervon’ or ‘We’).


The name of the controller of your personal information is Chervon IOT Platform.

Please be reminded that Chervon IoT platform is a unified account system. If you successfully register an account on the EGO Connect app (hereinafter referred to as ‘EGO Connect’), you can enjoy related services provided by Chervon IoT Platform through this account. Chervon provides you with a unified and efficient account service. Your account registration and deregistration, password modifications, e-mail modifications and other account-related actions on Chervon IoT Platform will be reflected and take effect on Chervon IoT Platform.

You agree and acknowledge that our products must be purchased through authorised channels. At the same time, Chervon has the right to charge for the developed services and new services at its discretion. With regard to services and content provided free of charge, Chervon has the right to cease providing them at any time. It is your responsibility to pay attention to the updated status of the services and content. During the use of the product, you may purchase the developed services and the new services through legally authorised channels. Alternatively, you may choose not to purchase them.

If there is an independent privacy policy for individual products or services we provide, the privacy policy/agreement concerned applies to those products or services.

It should be noted that this Policy does not apply to services provided to you by third parties, such as linking to third-party websites, clients or other programs through Chervon IoT Platform. This Policy does not apply to personal information you provide to third parties.

Before using the products or services of Chervon IoT Platform, please read and understand this Privacy Policy carefully, especially the terms that are marked in bold and underlined. You should only start using the products and services once you have fully understood and agreed to accept this agreement. If you have any questions about this Policy, you may consult the customer service of Chervon (contact information of customer service is service@egopowerplus.eu) or contact us through the contact information provided on the Chervon IoT Platform.


  1. Our role

    As the controller of your information, we have the right to decide how to handle your personal information and for which purposes. We know you care about how your data is used and shared, and we appreciate your trust. We will handle your information carefully and sensibly.


  2. Information we collect

    We collect your information based on the principles of legality, necessity, fairness and transparency. When providing you with a specific service, we will inform you of the information we will collect and its purpose in responding to your particular service

    request. Depending on the service you choose, we may organise one or more of the following types of information in the following scenarios:

    1. When logging in for the first time, you must provide your email address and your last name to register your account and set your account password so we can identify you on Chervon IoT Platform. If you do not provide relevant information, Chervon IoT Platform will not be able to create an account for you and provide services. Moreover, by collecting your last name and email address, our customer service staff can find the information of your equipment in the CRM system, so that we can provide you with more timely and accurate after-sales service when you seek help.

    2. After you have registered successfully, you can choose to fill in your personal information in the profile column, such as your nickname, gender, date of birth, profile picture, income level and education level. This information is collectively referred to as your ‘Account Information’, and the Account Information you add will help us provide you with more personalised services. However, if you do not provide such supplementary information, your use of the basic functions of Chervon IOT Platform will not be affected.

    3. For us to provide maintenance services to you, we need you to provide your name, contact information (telephone number and e-mail address), maintenance address, postcode, city, country, and service time so that we can respond to and address your maintenance problem in a timely manner. However, you can choose not to provide the above information, and failure to provide the above information will not affect your use of Chervon IOT Platform.

    4. In order to show the real-time situation regarding your product use, to optimise and improve our product design, to conduct timely optimisation of our products and services, and to improve the user experience, we will collect your APP online log-in time, single equipment cycle use time, your operating habits (including your use of single equipment page length, frequency, time, charging frequency and other operations), page retention time, operation record (including click record, click button record, click volume, duration of usage), cookies record, web browsing history, and link click record. If you refuse to provide the above information, you should stop using (device) product through EGO Connect and cancel your account in accordance with Article 10 of this Policy. However, your refusal will not affect your use of the (device) product separately.

      In the meantime, we will send marketing messages to you through EGO Connect after we manually screen the personal information collected above according to product type and model. You have the right to refuse to receive marketing messages pushed from us. Your refusal will not affect your use of Chervon IOT Platform. You can turn off EGO Connect marketing messaging in ‘My Account-Settings -Message Settings’.


    5. For us to be able to send product message notifications, system message notifications and marketing message notifications to you by e-mail, we need your permission to use the name and e-mail address you provided when registering and

      logging in. By clicking the box marked ‘Agree to this policy’, you are considered to have consented to our use of email notifications. You will receive e-mail notifications in your e-mail inbox even if you do not open the app. You can turn off e-mail marketing messages in EGO Connect under ‘My Account - Settings - Message Settings’.


      E-mail push notifications also stop when you log out of your account.

    6. In order for us to send Robot mower alarm messages and product reminder notifications to you via SMS, we need your phone number and your consent to send message notifications to the number you provide. Please be aware that you have the right not to provide your phone number for this purpose. By providing your phone number, you agree to receive push SMS notifications to your mobile phone number. Even if you do not open the app, you will receive SMS push notifications on your mobile phone.

      If the product you purchase and use supports WiFi connectivity, we need to collect the username and password of the wireless local area network you use. You need to fill in and provide these details yourself in order to link EGO Connect with the aforementioned product. You may choose not to provide the above information, and it will not affect your use of the product.

    7. To identify the abnormal status of accounts or products, understand or optimise the adaptation of products and services and provide application version upgrades or firmware version upgrades, we will collect information about your use of the products and services, including the unique device identifier of the relevant device, MAC address, IP address, phone model, operating system version, registration date and settings of the product that is used to access the service.

    8. To help us understand the performance of any of the above IoT platforms, we will record relevant product operation information, including your usage frequency, crash data, overall usage, and performance data. Information stored in our analytics software is not associated with any of your personal information. Please note that individual product information and service log information cannot identify a specific individual. If we combine such information with other information to identify specific individuals, such non-personal information will be regarded as personal information, and we will anonymise such information unless authorised by you or otherwise stipulated by law.

    9. To improve the security of the IoT platform service, protect the personal and property safety of you or other users or the public from infringement; better prevent against phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion and other security risks; and identify violations of laws and regulations or related protocol rules of the Chervon IoT Platform more accurately, we may use or integrate account information, product interaction information, web log information, and the information that you have authorised or shared by law, to the comprehensive judgment of your account and transaction risk. We may also use this data for authentication and/or inspection purposes, to help us prevent security incidents,

      and to dispose of records as required by law and in accordance with our audits and analysis.

    10. If your product has its own global positioning system (GPS), and if you agree to link the Chervon IoT Platform app with the product and use our products and services, we will obtain information about the geographical location of the product and its operating route so that you can know the location of the product and its operating route in real time.


    11. When you purchase or legally acquire a lawnmower robot with the ability to connect to an Internet network, the first time you use it until you change the initial password, you can use the initial password set in the instruction manual of the lawnmower robot to unlock the LCD screen of the device, and then follow the prompts to realise the connection between the lawnmower robot and your EGO Connect account via Bluetooth. Binding. You can also change the password after unlocking the LCD screen of the lawnmower robot by following the prompts. After the password has been changed successfully, you will need to use the changed password to unlock the LCD screen of the lawnmower robot in the future.


      Your attention is drawn to this:


      1. Anyone who is aware of the mower robot's unlock code may be able to connect the mower robot to their own EGO Connect account by following the instructions after unlocking the mower robot and changing the code after unlocking the robot's LCD screen. The password can be changed as instructed after unlocking the mower robot's LCD screen. The initial password set on the lawnmower robot and any subsequent passwords you set and change are very important and must be kept securely.


      2. Any user who uses the initial password set on the lawnmower robot and any subsequently changed passwords to bind the lawnmower robot to EGO Connect is entitled to be reasonably presumed by us to be a user who is entitled to lawful use of the lawnmower robot, which you may not dispute unless you can prove that there is a risk of the initial password and subsequently changed passwords being lost or compromised as a result of a fault on our part. You cannot dispute this unless you can prove that the risk of loss or disclosure of the initial password and subsequently changed passwords is due to our fault.


        If you have lost or disclosed the initial password set on the lawnmower robot or any subsequent passwords, please change them promptly.


      3. As a lawnmower robot with Internet connectivity can be bound to more than one user, once bound, each bound account can use the lawnmower robot via the EGO Connect App. If the lawnmower robot is operated by more than one bound account at the same time, the instructions to the lawnmower robot will be executed in the order

        in which they arrive, and all operations that arrive at the lawnmower robot will be executed, as you expressly know and agree.


    12. When you agree to link the Chervon IoT Platform app to a single device, we will collect your personal information stored on that single device. Of course, you can choose not to link a single device. This will not affect your continued use of the device.

    13. If we use information for other purposes not specified in this agreement, or use information collected on the basis of specific purposes for other purposes, we will obtain your consent in advance.

    14. If the information you provide contains personal information about other individuals, you will need to ensure that you have obtained legal authorisation before providing such personal information to us.

    15. Exceptions to the requirement to obtain consent: You fully understand and agree that your consent is not required for us to collect, use, share, transfer or publicly disclose your personal information under the following circumstances, and we may not respond to your requests for correction/modification, deletion, cancellation, revoke authorisation or request for information;

          1. Where data processing is necessary for the performance of a contract to which the data subject is a contractual party, or essential for the performance of a specific action required by the data subject before the conclusion of a contract.

          2. Where data processing is necessary to fulfil the legal obligations of the controller.

          3. Where data processing is necessary to protect the material interests of the data subject or another individual;

          4. Where data processing is necessary for the performance of tasks in the field of public interest or the exercise of official functions assigned to the controller;

          5. Where data processing is necessary for the realisation of the legitimate interests pursued by the controller or a third party, except where the interests, fundamental rights, and freedoms enjoyed by the data subject and the need to protect its data take precedence over the above-mentioned legitimate interests, especially in the case of children. At the same time, this situation cannot be used in respect of government agencies in the performance of their duties of data processing.

          6. Where personal information is disclosed by you to the public.

          7. Where data processing is necessary to maintain the safe and stable operation of the Products and/or services, such as the discovery and correction of errors in the Products and/or services.

  3. How we use your information

    1. We will keep your personal data up to date; safely store or destroy it; minimise the collection and retention of data we need to in order to provide you with services; protect personal information from disclosure, abuse, unauthorised access and disclosure; and take appropriate technical measures to keep your personal information secure.


    2. We use your information for the following purposes:

      1. To provide services according to the contract we signed with you.

      2. To fulfil your transaction or service request, including fulfilment of an order; to deliver, activate or validate products or services; to make changes at your request or provide information you request; and to provide technical support.

      3. To send marketing messages after manual selection based on product type and model.

      4. To maintain the integrity and security of our data technology systems for storing and processing your personal information.

      5. To enforce or protect our agreements or contracts with you.

      6. To detect and investigate information leakage, illegal activities and fraud.

      7. To contact you to resolve a problem.

    3. Please note that the above usages cover the main ways we use your information. We may periodically update the website and product version and develop other ways to provide users with more diversified services. If we intend to use the information for other purposes not specified in this Policy, or to use the information collected for a specific purpose, we will seek your consent again by asking you to sign a supplementary agreement, providing pop-up window tips and updating this Policy.


  4. How we use cookies and similar technologies

    Cookies and similar technologies are widely employed on the Internet. When you use our products and related services, we may use associated technologies to send one or more cookies or anonymous identifiers (hereinafter referred to as ‘cookies’) to your devices to collect, identify and store information (including profile picture, nickname, token ((account number token)) and search record information) about your access to and use of the products.

    We undertake that we will not use cookies for any purpose other than those described in this Privacy Policy. We use cookies and similar technologies primarily to deliver the following functions or services:


    1. To ensure safe and efficient operation of products and services:

      We will set up authentication and secure cookies or anonymous identifiers to enable us to confirm whether you are securely logged into the service or whether you are being subject to embezzlement, fraud or other illegal activities. These technologies will also help us improve service efficiency, log-in and response speed.


    2. To help you enjoy a more user-friendly access experience:

      We use local storage technology to save you from repeating the steps and processes of filling in your personal information and entering your search (example: record search, form filling).

    3. To troubleshoot exceptions:

During your use of the product, we will collect your browsing history and use cookies to record your browsing activities, which will be used to check for exceptions related to crashes and delays and explore better service methods.

If your browser or additional browser services permit it, you may clear corresponding data in the browser settings, modify the acceptance of cookies, or reject our cookies. When you clear this data, we will delete the data simultaneously. However, because of these modifications, you may not be able to log in or use the services or functions provided by us that depend on cookies.


  1. The circumstances in which we share your information

    We will not share your personal information with companies, organisations and individuals other than Chervon, except as set out below:

    1. Sharing for legal reasons: We may share your personal information with other parties pursuant to relevant laws and regulations, and in light of the need to resolve litigation disputes.

    2. Sharing with express consent: After obtaining your express consent, we will share your personal information with third parties.

    3. Third-party SDK management

      To ensure the stable operation of the Chervon IoT Platform, or to deliver relevant functionality, we will access third-party SDK products in our products or services. At present, the third-party SDKs in our system products are as follows:

      Google Maps SDK

      Affiliated organisation: Google Asia Pacific Pte. Ltd.

      Purpose: Obtain address details by geographic location for user services and product management

      Official link: https://www.google.com/maps

      Privacy Policy link: https://policies.google.com/

      Permissions invoked: WiFi permissions, camera permissions, storage permissions, access to network connections, access to network information status, voice interaction, location permissions.

      Personal information collected: Information about the product brand, model, software system version, basic paid information, carrier information, product time zone, longitude and latitude information used by users


    4. We will not transfer your personal information to any company, organisation or individual except for legal reasons or with your prior consent.


  2. Circumstances in which we publicly disclose your information


    By default, your account name is the nickname of the corresponding port when you log in. Therefore, when you post or comment on the Chervon IoT Platform, if you do not modify the default account nickname, you will disclose your aforementioned nickname to us and our authorised staff. You can also modify your nickname on the ‘My account

    - Account - Nickname’ page.


    In addition to the above, we will publicly disclose your personal information only in the following circumstances:


    1. After obtaining your consent.


    2. Disclosure for legal reasons: We may publicly disclose your personal information where required by law, legal procedures, lawsuits or the mandatory requirements of regulatory authorities.


  3. How we store your information

    As required by law, personal information collected and generated by us will be stored in data centres in the EU and in our data centres in mainland China.

    Unless otherwise specified by law, Chervon IoT Platform will retain your information for the following periods:

    1. When using Chervon IoT Platform products or services, we will keep your data for you unless you take the initiative to delete or cancel the Chervon IoT Platform account.

    2. We will periodically back up the collected information according to the data backup policy of the Chervon IoT Platform.

    3. After you delete your information or cancel your account on Chervon IoT Platform, Chervon IoT Platform will stop using your personal information and delete your personal information within 15 working days, except for information that must be retained pursuant to laws and regulations.

    4. Your personal information will constitute usable circulation data after being anonymised and desensitised. Chervon IoT Platform is not required to obtain your consent for the storage and usage of this data.

    5. When our products or services cease to operate, we will notify you through push notifications or announcements, delete your personal information, or anonymise it within a reasonable period.


  4. How we protect your information

    1. We have taken reasonable and feasible security measures in line with industry standards to protect your information from unauthorised access, public disclosure, use, modification and damage, or to prevent the loss of your personal information.

    2. The Internet environment is not perfectly safe; we strongly recommend that you do not use communication methods other than those recommended by Chervon IoT Platform to send your information when making use of products or services of Chervon IoT Platform.

    3. In the event of an unfortunate personal information security incident, we will inform you of the basic situation, including the nature of the breach, the type of data involved, the number of records and number of people affected, the name and contact information of the representative nominated by us, the possible impact of the security incident and the disposal measures we have taken or will take, as well as making suggestions as to actions you can take independently to reduce risks. We will also offer remedial measures for you, including the name and contact information of relevant regulators, etc. We will inform you of the relevant information by email, phone call, push notification and other means. If it is difficult to communicate to the subject of personal information individually, we will release an announcement reasonably and effectively. At the same time, we will also report the disposal of individual information security incidents based on the requirements of the regulatory authorities.

    4. You fully understand and agree that we have the right to review whether the identity information provided as part of the user registration is accurate and valid, and to take reasonable technical and management measures to ensure the security and effectiveness of the user account. You are required to maintain your account and password properly and to use your account and password correctly and securely. If the civil rights of the user or anyone else are damaged due to the loss of an account password or account theft caused by failure to carry out the obligations set out above, either party will bear the legal liabilities arising from such failure.

    5. If you find that others have used or stolen your Chervon IoT Platform account and password, or used it in any other way without your legal authorisation, you must notify us immediately using the contact details described in Clause 12. When you notify us, you will need to provide valid personal information consistent with your registration information. Upon receipt of your reasonable request and verification of your identity, we will take appropriate measures based on your requirements or specific

      circumstances (including, but not limited to, suspending the login and use of the account and unlinking and deleting the smart devices linked to the account). You will be held liable for any loss caused to you and other users by taking corresponding measures at your request. We have the right to refuse your request if you do not provide valid identity information or if the unique, proper identity information you provide is inconsistent with the registered identity information, and you shall bear the losses caused by such circumstances.


  5. Your rights

    You have the right to manage your information, including:

    1. Access to Your Personal Information:

      1. Account Information: If you wish to access or edit your personal information, you can access your data through the ‘My account-Account’ page after logging in to your account. If you want to change your password, you can log in to your account and then click ‘Profile picture’ to change your password.

      2. Other personal information (for example, when using after-sales service, repair service and other services): Personal information generated during your use of our products or services;

    2. Correct your personal information

      If you find that we have made mistakes in handling your personal information, you have the right to request us to make corrections or additions. You can make corrections or provide additional instructions by visiting the Personal Information Setting page, or contact us directly to request corrections or issue additional instructions in accordance with Clause 12.

        1. Deleting Your Personal Information

          In the circumstances set out below, you can contact Chervon IoT Platform customer service in accordance with Clause 12 to delete your personal information:

          1. If our behaviour in handling personal information breaches laws and regulations.

          2. If we collect or use your personal information without your explicit consent, or we are not subject to other legal requirements to do so.

          3. If our handling of personal information seriously breaches our agreement with you.

          4. If you do not need to use our products and services.

          5. If you have voluntarily cancelled your Chervon IoT Platform account.

          6. You have the right to request a third party and us to delete your personal information if we share or transfer your personal information to others without your explicit consent or are not subject to other legal circumstances.

          7. If we breach the agreement with you and publicly disclose your personal information, or if we are not subject to a legal requirement to publicly disclose your personal information, you have the right to request us to immediately cease the public disclosure and issue a notice requesting the recipient to delete the corresponding information.

      Once we receive your deletion request, we will promptly delete your personal information as required by law.

        1. Obtaining copies of personal information

          If you need a copy of your personal information, you can contact us via the contact information in Clause 12.

        2. Right to revoke authorisation

          1. When we rely on your consent to process data, you have the right to withdraw your consent at any time. You can do this for EGO Connect by going to ‘My Account

            - Settings - Legal Information – Revoke Authorisation’.


          2. After you revoke your authorisation, we will not be able to continue providing you with the services corresponding to the revocation of authorisation, nor will we process your corresponding personal information. However, your decision to revoke your authorisation will not affect any previous processing of personal data based on your consent or authorisation. After you revoke your authorisation, you need to re-enter your account and password before entering the function page again, and click “agree” to our Privacy Policy and User Agreement again. Your consent indicates that you voluntarily agree to our use and processing of your personal information.

        3. You have the right to restrict your personal information. If you exercise this right, we will suspend the processing of your data for a certain period. Circumstances which may give rise to this right include situations where the accuracy of your personal data is contested and we need some time to verify its (in)accuracy. This right does not prevent us from continuing to store your personal information. We will inform you before the restriction is lifted.

        4. Your right to data portability means that you may ask us to provide you with your personal information in a structured, commonly used and machine-readable format, and have such data transmitted directly to another controller, where technically feasible. Where legally required and technically feasible, we will transmit your personal information directly to the other controller.


  6. Account cancellation and personal information deletion

    1. You can cancel your registered account at any time. You can cancel by any of the following methods:

      1. Log in to EGO Connect and confirm for account cancellation. The operation path is "My account - Settings – Legal information – Cancel services" and press the

        “Confirm Cancel” button for account cancellation. After you submit the application for account cancellation, we will cancel your account and delete data associated with your account within 15 working days after verification according to your requirements. After you close your account, we will delete your personal information within 15 working days, unless otherwise provided by law. Once you confirm the account cancellation, you will not be allowed to log in to your original account again during the verification period, otherwise the cancellation may fail.

      2. Contact us through the contact information in Article 12 if you would like to cancel your account.

    2. After account cancellation, we will stop providing you with products or services, and your personal information will be deleted within 15 working days unless otherwise required by law upon your request.

    3. You must unbind the device before changing the email address if your account is registered through the email address and you change the email address for personal causes to ensure the security of your device. Otherwise, if others continue to use the email address, the owner of the email address can see and control your device, the loss arising therefore shall be borne by yourself.


  7. How we protect minors' information


    Our products and services are only for adults aged 18 and over, and children under 18 are prohibited from using them for safety reasons.


  8. How you can contact us

    1. If you have any questions, comments or suggestions regarding this Privacy Policy, if you wish to exercise any rights, or if you have any requirements to discuss with us, you can get in touch with our department that handles personal information protection in the following ways:

      1. Chervon IoT Platform service provider: Nanjing Chervon Industry Co., Ltd.

      2. Address: No. 529, 159, Jiangjun Avenue, Jiangning Development Zone, Nanjing City, Jiangsu Province, People’s Republic of China.

      3. Emailservice@egopowerplus.eu

      4. If you have a user account with us, you can log into your user account to make any changes to your specific user account as provided in your account settings. You have the right to access, update and correct your personal information in the Company's custody and control, subject to certain legal and contractual constraints. If you have questions or concerns regarding any personal information you have provided to us or would like to make any changes to such information you can contact us by aforementioned email.

    2. For security purposes, you may be required to provide a written request or otherwise prove your identity. Typically, we will reply within 15 working days. If you are not satisfied with our reply, especially if you believe that our personal information processing has harmed your legitimate rights and interests, you can also make a complaint or report to the local regulatory departments.


  9. Update Clause

    1. To provide you with better service and user experience, this Policy may be amended over time according to reflect business adjustments, laws, regulations or policy changes. If you continue to use any of our services or visit our related websites after any adjustment or change in our Privacy Policy, we will deem you to have fully read, understood and accepted the revised Privacy Policy and accepted to be bound by it.

    2. Chervon may develop and provide updates at our sole discretion, including but not limited to upgrades, bug fixes, patches, other bug corrections and/or new features (collectively referred to as ‘Updates’). Updates may also include modifying or removing all or certain features and functions of the application. All updates will be part of the application and be governed by this agreement.


      Depending on your device settings, you may receive notifications or prompts about downloading and installing available updates when your device connects to EGO Connect. You have the right to download and install all updates and confirm that you agree to the Privacy Policy. Otherwise, the application or some of its functions may not function properly.

    3. We shall update according to actual needs, and the date of this release is: 02/20/2024.

    4. How changes to this Privacy Policy will be communicated

Our business is constantly changing, which means that our Privacy Policy will be updated periodically. Please review this Privacy Policy periodically to ensure that you are satisfied with any changes we make.

We will not reduce your rights under this Privacy Policy without your express consent. We will publish any changes to the Privacy Policy, and if the changes are material, we will provide a more prominent notice, including personal e-mail notification where necessary.


The 02/20, 2024 version Effective 02/20, 2024