Version: 1.0

Release Date: 2026-08-12

Quick Preview

To help you quickly understand how we protect and process your personal information, we have specially prepared a quick reading summary of this policy. For more details, please refer to the full version of the "Privacy Policy" below.

Introduction

Sunlipro Limited and its affiliated companies (hereinafter collectively referred to as "we" or "our") fully safeguard and respect your rights to personal information. In order to explain important information such as how we collect, use, store, and protect your personal information through this product/service and what rights you enjoy, we hereby formulate this policy for a full explanation. The relevant key points are as follows:

1. The basic business functions of this product/service are to add and control smart devices.

2. To ensure that you can fully use this product/service, before your first use we will inform you and prompt you in a prominent form such as pop-ups to carefully read this policy and related agreements, and simultaneously explain the necessary permissions for our basic business functions and the purposes for requesting such permissions, as well as the optional permissions for extended business functions and the purposes for requesting such permissions. You may choose on your own whether to use only the basic business functions or the full functions of this product/service (except where only basic business functions are provided). If you choose to refuse to grant or provide the necessary permissions or necessary personal information corresponding to the relevant business functions, we regret that we will be unable to provide you with the corresponding functional services.

3. Please be aware that when you use this product/service for the first time, your agreement to this policy and the corresponding permissions does not mean that we have actually obtained your necessary permissions, nor does it mean that we have begun collecting and processing your personal information. We may still apply to you again for the relevant necessary permissions and process your personal information in specific scenarios.

4. In addition to this policy, when you use this product/service, you may read separate processing rules that we additionally publish and notify in this product/service, all of which are important components of this policy. If there is any inconsistency between these separate processing rules and this policy, such separate processing rules shall prevail; where the separate processing rules do not provide otherwise, this policy shall prevail.

5. Before using this product/service, please be sure to read and thoroughly understand this policy carefully. For important and sensitive personal information processing activities involved in this policy, as well as terms or statements that may have a significant relationship with your rights and interests, we will provide prompts in prominent forms such as bold text. Please pay attention to reading them.

6. If you have any questions about this policy, you may contact us through the contact information provided in "IX. Contact Us" of this policy, and we will be very happy to answer them for you. We will also revise this policy from time to time based on laws and regulations and business development changes, and notify you in accordance with legal requirements.

I. How We Collect and Use Your Personal Information

We will follow the requirements of national laws and regulations, uphold the principles of legitimacy, lawfulness, necessity, and good faith to protect your personal information, and only process your personal information within the limits of the relevant purpose for the following business functions and necessary purposes described in this policy, after obtaining your consent or where other lawful basis conditions stipulated by laws and regulations are met. You are not required to provide us with the relevant permissions or personal information, but in some cases, if you choose not to provide or grant them, it may affect our provision of the corresponding business functions to you.

1. When you use Sunlipro to actively submit feedback on issues and agree to upload diagnostic logs, we will collect your mobile phone brand, mobile phone model, operating system version, App version, time when the issue occurred, function operation records, device connection status, and error logs, for the purpose of analyzing the cause of the issue, locating and handling device connection, network configuration, control, and App operation abnormalities.

2. When you register for or log in to our application in order to use this product/service, we will collect and use your relevant information according to the following different circumstances:

(1) When you register a Sunlipro account and log in to our application via email, we will collect your email address, account password, system version, generated ID, mobile device identifier (Android version: IMEI, iOS version: IDFV), location information, network information, and sliding track information for identity verification and matching during Sunlipro account registration and login.

3. When you add or manage devices, we will collect and use your user ID, device ID, device type, device name, device serial number, device Bluetooth address, IP address, WIFI name, gateway identifier, mobile device identifier (Android version: IMEI, iOS version: IDFV), device Bluetooth mac, mobile device model, and location information. This information is collected automatically by the system. The purpose of collecting this information is to realize smart home device adding and management functions. In this scenario, we may request your authorization to enable location permission.

4. When you add and manage rooms, we will collect and use your room information (room name, room ID). This information is collected through your active submission, and the purpose of collecting this information is to realize the function of adding and managing rooms for you.

5. When you review and choose to agree to/reject this policy in the interactive interface, we will collect and use your device information (variable AndroidID) and log information (timestamps and corresponding system, application, and protocol version information). This information is collected automatically by the system, and the purpose of collecting this information is to comply with laws and regulations and thereby confirm the version of this policy that is effectively applicable to you so as to protect your lawful rights and interests.

6. In order to provide you with customer service or respond to your related requests, we may need you to provide or verify necessary personal information with you to ensure secure processing. To facilitate contacting you, assisting you in resolving problems, or recording the handling solutions and results of related issues, we may collect the following related information: contact information (the telephone number/email address you use when contacting us or other contact information you proactively provide to us), your communication information (including text/picture/audio-video/call records between you and us or related personnel), and other necessary information (including account information, order information, and other information you provide to prove the relevant facts).

7. In order to provide you with application upgrade detection services, we will collect and use your device identifiers (GUID, OAID) and mobile platform type (Android, iOS). This information is collected automatically by the system, and the purpose of collecting this information is to provide you with application upgrade detection services.

8. In addition, in accordance with relevant laws, regulations, and national standards, in the following circumstances, we may process your relevant personal information without your consent:

(1) Where necessary for the personal information processor to perform statutory duties or statutory obligations;

(2) Directly related to national security or national defense security;

(3) Necessary for entering into or performing a contract to which you are a party;

(4) Reasonably processing personal information that you have made public on your own or that has otherwise been lawfully disclosed;

(5) Directly related to public safety, public health, or major public interests, or necessary in emergency circumstances to protect the life, health, and property safety of natural persons;

(6) Collecting personal information from lawfully publicly disclosed information, such as lawful news reports and government information disclosures;

(7) Where the personal information controller is a news entity and such processing is necessary for it to carry out lawful news reporting;

(8) Where the personal information controller is an academic research institution, and such processing is necessary for carrying out statistics or academic research for the public interest, and when it provides academic research or descriptive results externally, it de-identifies the personal information contained in the results;

(9) Other circumstances stipulated by laws and administrative regulations.

9. Please understand that the business functions we provide to you are continuously updated and developed. If a business function does not notify you in the foregoing description of the processing rules for collecting and using your information, we will separately notify you of the scenarios, purposes, categories, and methods of information collection, so as to obtain your consent or other lawful basis for processing personal information.

10. In order to ensure that you can normally or more conveniently use the relevant business functions of this product, we will invoke necessary sensitive permissions of terminal devices based on the invocation rules of terminal device system permissions. After your authorization, we will enable the relevant necessary permissions.

11. Please be aware that, in order to better protect the rights of users on different system versions, we will additionally provide "empty data" (or similar wording) permissions to users of specific system versions. After users select such permissions, we will only enable the corresponding permissions, but will not collect any personal information (i.e., empty data), thereby expanding the scope of optional permissions for the relevant system versions.

II. How We Entrust the Processing of, Share, Transfer, and Publicly Disclose Personal Information

(I) Entrusted Processing, Sharing

1. Where necessary personal information security impact assessments have been carried out, we may entrust authorized partners and other third parties to process your personal information, so that authorized partners may provide certain services to you or perform functions on our behalf. We will sign entrusted processing agreements with the entrusted parties or jointly comply with relevant personal information processing rules, clarifying the rights and obligations regarding the specific purpose, period, processing method, category of personal information, protection measures, and other matters of entrusted processing. The entrusted party is obliged to process the relevant personal information within the scope of authorization and take relevant confidentiality and security measures to protect the security of personal information.

2. Sharing means that we provide personal information to other personal information processors, and both parties independently determine the purposes and methods of processing in their respective personal information processing activities. Under normal circumstances, we will not share your personal information externally, except in the following situations:

(1) Sharing upon obtaining separate consent: after obtaining your separate consent, we will share personal information within the scope of your authorization with third parties or our affiliated companies;

(2) Sharing necessary for performing statutory duties or statutory obligations: we may share your personal information externally in accordance with laws and regulations, for litigation and dispute resolution, or in response to lawful requests made by relevant administrative or judicial authorities;

(3) Sharing with business partners: however, we will only share your personal information for lawful, proper, necessary, specific, and clear purposes, and will only share the personal information necessary for providing services. Our partners include:

① Suppliers of goods or technical services: we may share your personal information with third parties that support our functions, including third parties that provide us with infrastructure technical services, data processing services, push services, and the like. The purpose of our sharing this information is to realize the functions of the products and services.

(4) To help you clearly understand the third parties to whom we entrust processing and share information, we have specially prepared the "Third-Party Information Sharing List". Please note that the above third parties may have independent privacy policies or personal protection policies applicable to you, and may independently collect and use your personal information apart from our application. Such circumstances are not subject to this policy and do not give rise to our liability. If you need to learn more information, please read the privacy policies published by these third parties or contact such third parties directly. If you find that a third party's conduct may damage your lawful rights and interests, it is recommended that you terminate the relevant operation to protect your lawful rights and interests.

(II) Transfer

In the event of merger, division, dissolution, acquisition, or declared bankruptcy, if personal information transfer is involved, we will inform you in advance of the name and contact information of the recipient and require the recipient to continue processing your personal information in accordance with this policy. If the recipient changes the original purpose or method of processing, it shall obtain your consent again.

(III) Public Disclosure

We will only publicly disclose your personal information under the following circumstances: 1. after obtaining your consent; 2. public disclosure based on law or reasonable grounds: where required by law, legal procedures, litigation, or public and governmental competent authorities, we may publicly disclose your information.

III. How We Store Your Personal Information

1. Storage Location. Sunlipro Limited is incorporated in Hong Kong, and the servers used to provide Sunlipro services are located in Mainland China. If you use Sunlipro outside Mainland China, your personal information will be transferred to, stored in, and processed in Mainland China. We will take reasonable measures to protect your personal information in accordance with this Privacy Policy and applicable laws.

2. Storage period. Unless a longer retention period is required by law or separately authorized and consented to by you, we will store your personal information only for the shortest time necessary for the purpose of providing this product/service to you. We provide you with corresponding consent withdrawal (deregistration) and deletion functions in accordance with the law. When you apply to withdraw consent (deregister) or delete, we will delete in accordance with the law, and the minimum necessary storage period may be determined by you yourself.

3. After the personal information collected and used exceeds the necessary storage period, we will delete or anonymize your personal information as soon as possible in accordance with the requirements of laws and regulations, unless otherwise provided by laws and regulations.

IV. How Cookies and Other Similar Technologies Are Used

Cookies and similar device information identification technologies are technologies commonly used on the Internet. When you use our services, we may use relevant technologies to send one or more Cookies or anonymous identifiers (hereinafter referred to as "Cookies") to your device, in order to collect and identify information when you use this platform.

The use of Cookies is mainly for ensuring the secure and efficient operation of product functions and services, enabling us to confirm the security status of your account and transactions, and troubleshoot abnormal situations such as crashes and delays; helping you avoid repeatedly filling in forms and entering search content, so as to obtain a more convenient user experience; at the same time, we may also use the above technologies to recommend, display, and push content that may interest you, and optimize your selection of and interaction with content. We promise not to use Cookies for any purpose other than those described in this Privacy Policy.

You may manage or delete Cookies according to your own preferences. Most browsers provide users with the function to clear browser cache data, and you may clear Cookie data in browser settings. In addition, you may also clear all Cookies stored in the software. However, after clearing, you may be unable to use functions or services provided by us that rely on Cookies.

California Online Privacy Disclosures

This section applies to users residing in California. Sunlipro is a mobile application and does not respond to web browser "Do Not Track" signals. We do not use personal information collected through Sunlipro to track users' online activities over time and across third-party websites or online services for targeted advertising. Third-party SDKs integrated into Sunlipro may collect device, network, location, and interaction information for security verification and fraud prevention purposes, as described in the Third-Party Information Sharing List. We do not authorize these third parties to use information collected through Sunlipro for cross-context behavioral advertising.

V. How We Protect Your Personal Information

We value the security of personal information and adopt industry-standard practices to protect your personal information from unauthorized access, disclosure, use, modification, damage, or loss. To this end, we have in particular adopted the following measures:

1. We take all reasonably practicable measures to ensure minimization of personal information collection and will not collect personal information unrelated to achieving the purposes. We will only retain your personal information for the period necessary to achieve the purposes described in this policy, unless the retention period needs to be extended or is permitted by law.

2. To protect the security of your information, we endeavor to adopt various reasonable physical, electronic, and administrative technical control measures in line with industry standards to protect your information so that it will not be leaked, damaged, or lost. These technical control measures include but are not limited to local storage and processing as well as access control at data centers.

3. We will deploy access control mechanisms to ensure that only authorized personnel may access personal information; and, according to business needs and personnel hierarchy, control the number of authorized personnel and implement hierarchical permission management for authorized personnel; access to personal information will be logged and periodically audited by administrators.

4. We will strictly select authorized partners and incorporate personal information protection requirements into the commercial contracts between both parties or into activities such as audits and assessments.

5. We will also conduct security and privacy protection training courses, tests, and publicity activities to strengthen employees' awareness of the importance of protecting personal information.

6. We will do our best to protect your personal information. Nevertheless, no measure can be flawless, and no products and services, websites, data transmission, computer systems, or network connections are absolutely secure. To address risks that may arise such as personal information leakage, damage, and loss, we have established multiple systems and control measures and, in accordance with the requirements of security incident handling norms, launch security contingency plans for different security incidents, carry out loss mitigation, analysis, location, formulation of remedial measures, and joint tracing and crackdowns with relevant departments.

7. If a personal information security incident unfortunately occurs, we will inform you in accordance with legal requirements of: the basic circumstances of the security incident and its possible impact, the disposal measures we have taken or will take, suggestions for your independent prevention and risk reduction, remedial measures for you, and so forth. We will inform you of the relevant circumstances of the incident by email, SMS, push notification, and other means. Where it is difficult to inform personal information subjects one by one, we will adopt reasonable and effective means to issue announcements. At the same time, we will also report the handling of the personal information security incident in accordance with the requirements of local regulatory authorities.

VI. Your Rights as a Personal Information Subject

We respect your rights as a personal information subject and make every effort to protect your management and control over your personal information. To this end, we provide you with various means to facilitate more secure and convenient privacy settings and personal information management, so as to protect the security of your personal information. The following lists the rights you enjoy according to law and indicates how we will protect these rights.

Please note that, for security reasons, before processing your request, we may need to verify your identity; there may be differences in operation settings among different products/services, operating systems, and versions of product software; in addition, in order to optimize your user experience, we may adjust specific operation settings.

You enjoy the following rights with respect to your personal information:

(I) Access, Correct, and Supplement Your Personal Information

1. Access: You have the right to understand and access how we process your personal information. To improve the transparency of personal information processing, we have published this policy. In this product/service, you may review the privacy policy and relevant rules by viewing the pop-up statement of the product/service, and through [Me - Privacy and Agreements - Privacy Settings]; and you may review the personal information we may collect and process through [Me - Privacy and Agreements - Personal Information Collection List] and [Me - Privacy and Agreements - Third-Party Information Sharing List].

2. Correction, Supplementation: If you find that the personal information we process about you is inaccurate or incomplete, you have the right to require us to correct it in a timely manner and, where appropriate, require us to complete corrections to your personal information. For part of your personal information, you may directly correct or supplement it in the corresponding access interface above. In order to ensure the quality of personal information and avoid adverse effects on your personal rights and interests caused by inaccurate or incomplete personal information, we may need to carry out necessary identity verification before you exercise your right to correction or supplementation.

(II) Delete Your Personal Information

1. Under any of the following circumstances, we will proactively delete your personal information, or you may submit a deletion request to us:

(1) The processing purpose has been achieved, cannot be achieved, or is no longer necessary to achieve the processing purpose;

(2) We stop providing products/services, or the retention period has expired, for example, you no longer use our products/services;

(3) You have withdrawn your consent;

(4) We process your personal information in violation of laws, administrative regulations, or agreements;

(5) Other circumstances stipulated by laws or administrative regulations.

2. Please understand that when you request deletion or anonymization of your information, due to applicable laws and security technology limitations, we may not be able to immediately delete it from the system; we will securely store your personal information and restrict any further processing of it until deletion or anonymization can be achieved.

3. We have the right to refuse to process requests that are insubstantial/entangling repetitive requests, requests that harm others' privacy rights, extremely unrealistic requests, requests requiring disproportionate technical work, requests that need not be granted under local law, information that has already been made public, and information provided under confidentiality conditions. If we believe that certain aspects of a request to delete or access data may cause us to be unable to lawfully use the data for the aforementioned anti-fraud and security purposes, we may also refuse such request.

(III) Copy and Transfer Your Personal Information

1. You have the right to copy your personal information. You may assert your right to copy through [IX. Contact Us], and we will also continuously optimize the realization methods for the right to copy based on technical capabilities.

2. Subject to the conditions stipulated by the relevant national authorities, if you request that your personal information be transferred to a personal information processor designated by you, we will effect such transfer.

(IV) Withdraw Consent

1. Each business function requires certain basic personal information or permissions to be completed. You may change the scope of your authorization for us to continue collecting and using personal information by deleting information, managing device permission settings, changing relevant product/function settings pages, or withdrawing consent to the privacy policy through [Me - Privacy and Agreements - Privacy Settings - Withdraw Consent], thereby achieving withdrawal of consent within the corresponding scope.

2. Please note that your withdrawal of consent to a service or withdrawal of consent to the privacy policy may result in our being unable to continue providing you with the products/services corresponding to the original consent and authorization, and may also cause you to lose some rights and interests. At the same time, we will no longer process the corresponding personal information (except for the personal information and permissions required to realize basic business functions), but your decision to withdraw consent will not affect personal information processing previously carried out based on your authorization, nor will it affect your continued use of basic business functions. The relevant personal information will be anonymized or deleted after the statutory storage period or the retention period expressly stated in the privacy policy expires.

(V) Complain or Obtain an Explanation

You have the right to contact us through the methods disclosed in this policy to make complaints and seek assistance. If you are dissatisfied with our reply, especially if our personal information processing activities have harmed your lawful rights and interests, you may also file complaints or reports with regulatory authorities such as the cyberspace administration, public security, and market regulation authorities, or bring a lawsuit before a court with jurisdiction.

(VI) Rights of Close Relatives of the Deceased

If you unfortunately pass away, and provided that you did not inform us otherwise in writing or by other reasonable means during your lifetime, your close relatives may, based on their own lawful and legitimate interests, contact us to obtain relevant guidance for exercising the rights of access, copy, correction, deletion, and other rights provided by law.

(VII) Deregister Account

1. You may apply to deregister your Sunlipro account through [Me - Settings - Account Center - Account Deregistration].

2. We specifically remind you that deregistering your account is irreversible and may result in your loss of all rights and interests associated with the account, and you may also be unable to use the account to enjoy related products and services associated with the account. Unless otherwise provided by laws and regulations, after you deregister your account, we will be unable to respond to the rights claims under this chapter. After you deregister your account, we will delete or anonymize the relevant information concerning you. If deletion of personal information is technically difficult to achieve, we will stop processing other than storage and taking necessary security protection measures.

VII. How We Protect Children's Personal Information

We attach great importance to the obligations and responsibilities for protecting minors' personal information, strive to create a healthy online environment for minors, and provide minors with special protection.

Most of the products/services we provide are mainly intended for adults and are not targeted at children (children as defined by the laws applicable in their country or region), and we do not directly provide services to children. Please note that, due to objective limitations such as technical conditions, our products/services may not be able to proactively identify users' ages.

If you are a child, before using the relevant products/services, you should first obtain the consent of your parents or other guardians, and be sure to carefully read this policy together with your parents or other guardians and the "Rules for the Protection of Children's Personal Information" to learn more information. Without the consent of a child's parents or other guardians, children may not use our products/services.

VIII. Review and Update of This Policy

1. Review this policy. You may review this policy on our website, in products, services, and applications, and in this application you may view it in the [Me - Privacy and Agreements - Privacy Settings] module. There may be slight differences in the inquiry path among different devices, operating systems, and software versions.

2. Update this policy. We reserve the right to update or modify this policy from time to time. In order to provide you with better services, our products/services will be updated and changed from time to time, and we will update or revise this policy from time to time accordingly. When this policy changes, we will notify you by reasonable means such as push notifications and pop-up forms on our website, products, services, and applications.

3. Please note that only after obtaining your consent will we process your personal information in accordance with the updated policy. Without your explicit consent, we will not reduce the rights you should enjoy under this policy. If you do not agree to the modified policy, you have the right and should immediately stop using our websites, products, services, and applications.

IX. Contact Us

The interpretation of and dispute resolution under this policy shall be governed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China. However, nothing in this policy shall deprive you of any mandatory consumer protection rights or remedies available under the laws of your habitual residence. If any dispute arises with respect to the conclusion or performance of this policy, the parties shall attempt to resolve it through friendly consultation as far as possible; if consultation fails, either party may bring proceedings before a court of competent jurisdiction in Hong Kong, except where mandatory applicable law entitles you to bring proceedings before another competent court.

If you have any questions, complaints, or suggestions regarding this policy or matters related to personal information protection, you may contact us through the following methods, and we will complete identity verification and response handling within 15 working days. Considering the complexity and quantity of personal requests and the feasibility of technical implementation, this period may be extended when necessary.

Contact information for the person in charge of personal information protection:

Send your questions to the email address: support@sunlipro.com

Or mail them to the following address: Room A08, 2/F, Lee Ka Industrial Building, 8 Ng Fong Street, San Po Kong, Kowloon, Hong Kong

X. Meanings of Terms in This Policy

Personal information: refers to various information related to an identified or identifiable natural person recorded electronically or by other means, excluding information that has been anonymized.

Sensitive personal information: refers to personal information that, once leaked or illegally used, is likely to cause harm to the personal dignity of a natural person or endanger personal or property safety, including biometric data, religious beliefs, specific identity, medical health, financial accounts, whereabouts and trajectory information, and personal information of children that is classified as sensitive or otherwise subject to special protection under the laws applicable in their country or region.

Affiliated companies: refers to companies directly or indirectly controlled by Sunlipro Limited, companies that directly or indirectly control Sunlipro Limited, or companies that, together with Sunlipro Limited, are directly or indirectly controlled or significantly influenced by the same entity. In this definition, "control" means having, directly or indirectly, through shareholding, contractual arrangements, or any other means, the power to elect at least half of the directors or representatives of an entity, or holding at least 50% of the voting rights in such entity.