Privacy Policy

1. What Information We Collect and How We Use It

• 1.1 Situations Requiring Your Authorization for the Collection and Use of Personal Information
  • We collect personal information to provide you with products and/or services and to ensure compliance with applicable laws, regulations and other normative documents. You have the right to choose whether to provide such information; however, in most cases, failure to provide the information may result in our inability to deliver corresponding services or respond to your inquiries. The relevant functions include:
  • 1.1.1. Smart Device Connection
    • We provide TOFEL services to enable you to securely connect and manage smart devices. When connecting a smart device, we may collect your login account information, mobile device-related information, IP address, smart device-related information, and information associated with your TOFEL account and smart devices. This information is used to provide functions including quick connection, device connection, nearby device discovery and device management. The detailed information is as follows:
    • Login account information: TOFEL Smart account ID, nickname, avatar.
    • Mobile device-related information: Hardware device identifiers (IMSI, IMEI, MEID, device hardware serial number, SIM card identifier, OAID, Mac address, Android ID), mobile model, system version, system language, device-set country/region, App Store version, screen size and resolution, CPU and display-related information.
    • Information collected during smart device connection:
      • Wi-Fi-connected smart devices: Wi-Fi information (SSID, BSSID, Wi-Fi Mac address, Wi-Fi password), device Mac address, device ID.
      • Smart devices connected via Wi-Fi after local Bluetooth connection: Wi-Fi information (SSID, BSSID, Wi-Fi Mac address, Wi-Fi password), device Mac address, device Bluetooth Mac address.
      • Bluetooth-connected smart devices: device Bluetooth Mac address, device ID.
      • Zigbee-connected smart devices: device Mac address, device ID.
  • 1.1.2. Community Function
    • When you use the Community function, we may collect your community name and location information to distinguish between multiple communities. If you use the QR Code Door Access, Remote Door Opening, Community Monitoring (including Intercom), and Visitor Reservation functions included in the Community feature, corresponding records will be stored for administrator review and will not be used by TOFEL for any other purposes. The specific records include:
    • QR Code Door Access: Access control records (user name, access identification method, entry/exit status).
    • Remote Door Opening: Access control records (user name, access identification method, entry/exit status).
    • Community Monitoring: Real-time audio and video from monitoring devices; intercom audio/video content, intercom time and response status for the Access Control Intercom function.
    • Visitor Reservation: Visitor's address, name and visit time.
  • 1.1.3. Family Management
    • You can create a family group and invite family members to join, and assign administrator permissions to manage family devices. To implement this function, we may collect your account ID, email address, avatar, and the account ID, email address and avatar of invited family members to display member information in the family list.
  • 1.1.4. Application and Firmware Update
    • To ensure you enjoy the latest TOFEL Smart services, we use the app version and mobile model to provide application updates when you check for updates. We also collect the list and version numbers of your connected smart devices to deliver device firmware updates, ensuring you use the latest service version.
  • 1.1.5. Intelligent Scene (Device Intelligent Linkage)
    • We support you in setting rules to enable smart device linkage under specific conditions. When using this function, we may collect your scene rule settings, scheduled work/rest time and specified device status to execute commands (e.g., turning on lights when a sensor detects motion). This function requires your active setup and activation, and can be disabled at any time.
  • 1.1.6. Face Recognition Management
    • If you connect biometric-enabled devices (e.g., T01 Pro Wi-Fi door lock) via TOFEL Smart, you can add face/fingerprint biometric information through the platform for an enhanced experience. We may collect your actively uploaded face, fingerprint, password and other personal data for identification purposes only. Such data will not be used for any other purpose. You may modify or delete uploaded biometric information/passwords via TOFEL Smart.
  • 1.1.7. Security Device Video Recording
    • If you connect a camera-equipped door lock, the device will automatically record video when detecting human presence (after you enable the function). Videos are encrypted and uploaded to the cloud for storage of no more than 7 days, for your playback only. Video data will not be used for any other purpose. You can control video recording in Smart Home - Security - Door Lock - Door Lock Settings - Park Detection.
• 1.2 TOFEL Smart Permission Call Instructions
  • The following device permissions may be triggered when using TOFEL Smart. We will inform you of the permission usage purpose and the impact of disabling permissions during use. You may choose whether to authorize the permissions before using specific functions:
  • Read/write device storage permission (Android): For reading/writing photos and files in QR code scanning and other functions.
  • Geolocation permission (Android, iOS): For smart device automation, WLAN/Bluetooth list acquisition for quick connection, nearby device discovery, and location acquisition for community/family management.
  • Camera permission (Android, iOS): For QR code scanning for device setup, account login and other functions.
  • Recording permission (Android, iOS): For video intercom and voice command pickup when binding smart door locks and other devices.
  • Read phone permission (Android): For generating local device identifiers on the client.
  • WLAN permission (Android, iOS): For connecting to device-generated Wi-Fi during quick device connection.
  • Bluetooth permission (Android, iOS): For connecting to device Bluetooth signals during quick connection and communication for Bluetooth-connected devices.
  • Floating window permission (Android): For displaying real-time camera images in a floating window when binding cameras.
  • Photo album permission (Android, iOS): For reading/writing photos and videos in QR code scanning and other functions.
• 1.3 Exceptions to Consent Requirements for Personal Information Collection and Use
  • You acknowledge that we do not require your consent to collect and use personal information in the following circumstances:
  • Necessary for the personal information controller to fulfill legal obligations.
  • Directly related to national security and defense security.
  • Directly related to public security, public health and major public interests.
  • Directly related to criminal investigation, prosecution, trial and judgment execution.
  • To protect the vital legitimate rights and interests of the data subject or other individuals, where obtaining consent is difficult.
  • Personal information voluntarily disclosed by the data subject to the public.
  • Necessary for concluding and performing a contract at the request of the data subject.
  • Collecting personal information from legally public sources (e.g., legal news reports, government disclosures).
  • Necessary to maintain the safe and stable operation of products/services (e.g., fault detection and handling).
  • The controller is a news organization performing legal news reporting.
  • The controller is an academic research institution conducting public-interest statistical/academic research, with de-identified results provided externally.
• 1.4 Collection of Personal Information from Third Parties
  • We may obtain your personal information from authorized third parties when providing product features or services:
  • For the Intelligent Scene function: With your authorization, we obtain device name, ID and status from bound smart devices to trigger linkage rules. You may add, delete or edit rules in Smart Home-Scene.
  • For third-party email login: We obtain your authorized account information (avatar, nickname, etc.) and bind it to your TOFEL Smart account after you agree to this policy. We use the information in compliance with laws and third-party agreements after verifying source legality.
• 1.5 Non-Personal Information
  • We may collect non-personal information (data that cannot identify a specific individual), such as statistical operational data (clicks, page jumps, browsing duration). This information is used to optimize our services. We aggregate such data for service improvement; aggregated data is treated as non-personal information. If combined with personal information, it will be treated as personal information during the combination period.

2. How We Use Cookies and Similar Technologies

• TOFEL Smart and third-party service providers use cookies, tags, scripts and similar technologies to analyze trends, manage the platform, track user activities and collect user base statistics. We receive individual or aggregated analysis reports from these technologies to understand user behavior, measure advertising effectiveness and optimize services. We treat data collected via cookies as non-personal information; if local law classifies IP addresses as personal information, we will handle such identifiers accordingly.
• Log Files: We collect IP addresses, browser type, ISP, referral/exit pages, OS, timestamps and clickstream data, and do not link this data to personal information.
• Advertising: We cooperate with third-party ad providers to deliver targeted ads based on browsing behavior. We obtain your explicit consent before providing advertising services.
• Mobile Analytics: We use analytics software to log app usage frequency, events, performance data and crash locations, without linking to personal information.
• Local Storage (HTML5/Flash): We use local storage to save content and preferences. Third parties may use HTML5/Flash cookies for features/advertising; you may manage storage via browser settings.

3. Retention Policy

• We retain personal information only for the period necessary to fulfill the purposes outlined in this policy or to comply with legal requirements. We will cease retention, delete or anonymize information after the collection purpose is fulfilled, upon your deletion/cancellation request, or upon termination of related products/services. For public interest, scientific, historical research or statistical purposes, we may retain data in accordance with applicable law.
• Pursuant to the E-Commerce Law of the People's Republic of China, your product/service information and transaction records will be retained for no less than three years from the date of transaction completion.

4. Your Rights

• 4.1 Control Settings
  • We provide you with options to control the collection, use, disclosure and processing of personal information:
  • Modify personal information (nickname, avatar, etc.) via Account page.
  • Enable/disable device intelligent linkage scenes.
  • Log in/out of your TOFEL Smart account.
• 4.2 Rights Regarding Your Personal Information
  • In accordance with applicable laws, you have the right to request access, correction and deletion of your personal information. To protect your information security, requests must be submitted via official channels, in written form (unless local law permits oral requests), and include sufficient identity verification information.
  • We will respond to valid requests within the timeframe required by data protection laws:
  • We provide free records of collected/processed personal information upon request; reasonable administrative fees may apply for additional requests.
  • You may request correction of inaccurate or incomplete personal information.
  • You may request deletion of personal data in accordance with applicable laws. We will process valid requests and isolate/secure data until backup deletion/anonymization (compliant with the E-Commerce Law retention requirements).
  • We reserve the right to reject frivolous, repetitive, privacy-infringing, unrealistic or legally non-mandatory requests.
• 4.3 Cancel Service or Account
  • You may cancel your TOFEL Smart account via Account Security. Account deletion will disable access to all TOFEL products and services. Please carefully review the TOFEL Account Deletion Agreement before proceeding.

5. Global Transfer of Your Personal Information

• TOFEL processes and backs up personal information through global operations and control facilities, with data centers in China and Singapore. Your information may be transferred to these centers in accordance with this policy and applicable law.
• We may transfer information to third-party service providers and business partners globally. We comply with cross-border data transfer laws and implement uniform security safeguards to protect your information:
• Personal information collected in mainland China is stored in mainland Chinese data centers, except for legally permitted cross-border transfers.
• Personal information collected in Southeast Asian countries is processed and stored in Singaporean data centers, in compliance with Singaporean laws.

6. Sharing Your Personal Information with Third-Party Service Providers

• Some services are provided by third-party partners, requiring us to share limited personal information. We use encryption to protect your information, conduct security reviews of third parties, and sign strict data processing agreements requiring them to comply with laws and implement adequate protection measures.

7. How to Update This Policy

• We regularly review and update this privacy policy to reflect business and technological changes. Material changes will be notified via in-app pop-ups. Updated terms take effect on the specified date. Your continued use of products/services constitutes acceptance of the updated policy. We will obtain re-authorization if we collect additional personal information or use it for new purposes.

8. Contact Us

• We have established a dedicated personal information protection department. If you have comments, questions or concerns regarding this policy or our personal information handling practices, please contact us. We will respond to your inquiries and rights requests promptly. For unresolved complaints, you may escalate to the relevant regulatory authority in your jurisdiction.