Privacy Policy

Last updated: December 17, 2018

Innway strives to make life easier and less stressful. This policy details what information we collect from you and how we use it to accomplish that mission.

We take your privacy as seriously as you do, and because of that we take great care to collect only the information necessary to provide you with the best Innway experience.

Thank you for choosing to be part of our community at Shenzhen Innway Technology (“Company”, “we”, “us”,or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices concerning your personal information, please contact us at kelvin.liu@innwaytech.com.

This privacy policy applies to all information collected through our website https:// innwaytech.com (“Sites”), mobile applications (“Apps”), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Services”).

When you visit our Sites, use our Apps, and use any of our Services, you trust us with your personal information. We take your privacy very seriously. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue the use of our Sites or Apps and our Services.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

1.Information Innway Collects

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps.

We automatically collect certain information when you visit, use or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. See “Cookies and other tracking technologies” below for more detailed information on how we use cookies.

Information collected through our Apps

In Short: We may collect information regarding your geo-location, mobile device, push notifications, when you use our apps.

If you use our Apps, we may also collect the following information:

- Account Information. You’ll need to use a valid email address and create a password to create an account on the Innway app.

- Device Information. When you activate a device using the Innway app, that device’s unique identifier (or device ID) will be associated with your account. If you choose to name your device or add a photo of it, this information will also be associated with your account.

- Geo-Location Information. Innway is designed to tell you where your items are. In order to do that, it’s necessary to collect data about your location. We use the term “Location Information” to refer to the combined location data of your phone or device, and your devices. We may request access or permission to and track Location Information, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

- Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, camera, microphone, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

- Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

- Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

Information collected from other sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, third-party social networking service (“Social Network”), such as Facebook, Instagram, or Twitter, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, current city, state and country, user identification numbers for your contacts, profile picture URL and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).

If you decide to interact with a Social Network when using our Sites, we are permitted to collect Personal Information that you have already made public on your Social Network account. You can manage this information in the privacy settings of each Social Network.

2.How Innway uses your information

In Short: We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent

We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

- To facilitate account creation and logon process with your Consent.

- To send administrative information to you for Business Purposes. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

- To locate your device when it goes out of range of our mobile device. While the app is running on your device, it periodically transmits your location information. This allows us to show you, on your map, the last place your device was seen by your device. It is one of the primary ways devices helps you find your lost items.

- Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Sites or Apps.

- For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites or Apps, products, services, marketing and your experience. We use your Location Information to provide the Sites and may use your Location Information to promote the Sites or provide you with offers. However, your Location Information is never shared with other users unless you choose to share it through our Sites.

3.How Innway shares your information

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

We only share information with your consent, to comply with laws, to protect your rights, or to fulfil business obligations.

- Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

- Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.

- Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Sites or Apps.

4. Cookies and other tracking technologies

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.

Cookies are small text files that are stored on your computer’s hard drive or onto your mobile device’s memory, if your browser is set to accept cookies. Like many other online services, cookies and other tools like them help us collect and understand how you use our services.

Although most internet browsers automatically accept cookies, you can change your settings or use third-party tools to prompt you before accepting cookies from the websites you choose to visit, or to refuse cookies altogether. You can even delete them through your browser. Most browsers also have settings to prevent them from accepting new cookies, to notify you when you receive a new cookie, or to delete or disable cookies altogether. Some parts of our Sites may not work for you if you disable cookies.

How We Use Cookies

We use cookie technology in various ways to help make it easier for you to use our Sites. For example, we use cookies to remember you when you return to our website, identify you when you sign-in, authenticate your access, keep track of your in-app specified preferences or choices, tailor content to you or geographic region, display a personalised browsing history, and/or to provide specific technical support.

We may also use cookies to gauge site usage, conduct research and diagnostics to improve the content we provide you, our products and services, and to help us analyse general web traffic.

The cookies we use expire after they have fulfilled their purpose. Some cookies expire when you close your browser (i.e., session cookies) or after a set period of time (i.e., persistent cookies). The expiration time of cookies that are placed by third parties (explained below) is determined by the third-party, not us.

Web Beacons

Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Sites for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Sites, to monitor how many visitors view our Sites, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on web pages (or in an e-mail).

5. Use of Google Maps

In Short: Yes, we use Google Maps for the purpose of providing better service.

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs Terms of Service. To better understand Google’s Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.

6. How Innway uses your social logins

In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.

Our Sites or Apps offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites or Apps. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. How long we keep your information

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8.How we keep your information safe

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.

9. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at kelvin.liu@innwaytech.com.

10.Your privacy rights

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/ justice/data-protection/bodies/authorities/index_en.htm

11. We are not responsible for content on third party websites

Our Sites and Apps may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service, or that is collected by a Third-party Service, is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

12. You may access, modify, and rectify your information

You can access and modify your contact information, such as your name, email address or phone number, within the Sites or Apps, or by contacting us at kenny.liu@innwaytech.com. Where otherwise permitted by applicable law, you may send an e-mail or use any of the methods set out in this Privacy Policy to request access to, receive, seek rectification, or request erasure of Personal Information held about you by Innway. Please include your full name, email address associated with your account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Under Privacy Shield, you may also inquire as to whether Innway is processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate or has been Processed in violation of the Privacy Shield Principles.

Please note that the Location Information associated with your Account is a core part of our Services and you will not be able to modify it. However, if you do not want us to use your Location Information, you can delete it by deleting your Account using the process set forth below.

13. Your account may deleted upon your request

If you want us to delete your Personal Information, Location Information and your Account, please contact us at kenny.liu@innwaytech.com with your request. We’ll take steps to delete your information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

14. Privacy Shield

Innway complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of Personal Information transferred from the European Economic Area and Switzerland to the United States. Innway is in the process of certifying to the Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Innway’s certification, please visit https:// www.privacyshield.gov.

Additionally, Innway may protect information through other legally valid methods, including international data transfer agreements.

“Privacy Shield” means the seven (7) principles of the Privacy Shield Framework: (1) notice, (2), choice, (3) accountability for onward transfer, (4) security, (5) data integrity and purpose limitation, (6) access, and (7) recourse, enforcement, and liability. Additionally, it includes the sixteen (16) supplemental principles described in the Privacy Shield: (1) sensitive data, (2) journalistic exceptions, (3) secondary liability, (4) performing due diligence and conducting audits, (5) the role of the data protection authorities, (6) self-certification, (7) verification, (8) access, (9) human resources data, (10) obligatory contracts for onward transfers, (11) dispute resolution and enforcement, (12) choice – timing of opt-out, (13) travel information, (14) pharmaceutical and medical products, (15) public record and publicly available information, and (16) access requests by public authorities.

If you are an EU or Swiss citizen and feel that Innway is not abiding by the terms of this Policy, or is not in compliance with the Privacy Shield Principles, please contact Innway at the contact information provided below.

In addition, Innway has agreed to refer unresolved complaints related to Personal Information to JAMS Privacy Shield Dispute Resolution Program and, with respect to employee and human resources data, has committed to cooperate with the panel established by local data protection authorities and comply with the advice given by the panel for EU citizens and with the Swiss Federal Data Protection and Information Commissioner’s authority and advice for such data of Swiss citizens. For more information and to submit a complaint regarding individual data to JAMS, a dispute resolution provider which has locations in the United States and EU, visit https://www.jamsadr.com/file-an-eu-usprivacy-shield-or-safe-harbor-claim.

Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.

You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article? id=ANNEX-I-introduction. The FTC has jurisdiction over Innway compliance with the Privacy Shield.

15. Policy updates

In Short: We will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

If you object to any of the changes to this Privacy Policy, you must cease using our Sites and may request us to erase your Personal Information. Any information that is collected via our Sites is covered by the Privacy Policy in effect at the time such information is collected.

16. We take security seriously

We implement various systems, applications and procedures to secure your Personal Information, in order to reduce the risks of theft, damage, loss of information, or unauthorised access, disclosure, modification or use of information. Please be aware, however, that these measures cannot absolutely guarantee the security of your Personal Information. Therefore, although we take great efforts to protect your Personal Information, we cannot guarantee and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

17. You are responsible for maintaining the accuracy and confidentiality of your email address and password

You are responsible for keeping the secrecy of your password at all times. We recommend using a strong password that you do not share with other services.

If you believe the security of your account has been compromised, please change your password immediately via the Innway website or through your Innway app. You can also contact us at kelvin.liu@innwaytech.com for assistance.

You are responsible for ensuring the email address associated with your account is accurate. We use that email to contact you about service updates, changes to our policies, and account activities such as requests for your information or locate attempts on your device. Innway is not responsible for personal data transmitted to a third party as a result of a user providing an incorrect email address.

18.Contact information

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Kelvin Liu, by email at kelvin.liu@innwaytech.com, or by post to:

Shenzhen Innway Technology

Kelvin Liu

5F, Torch Building, No 22, YanshanRoad, Shekou Town, Nanshan District, Shenzhen, Guangdong 518000

China

If you have any further questions or comments about us or our policies, email us at kelvin.liu@innwaytech.com or by post to:

Shenzhen Innway Technology

5F, Torch Building, No 22, YanshanRoad, Shekou Town, Nanshan District, Shenzhen, Guangdong 518000

China

Phone: +86 755-26508703