Privacy Policy

 

Last updated: February 18, 2024

 

Introduction 

This Privacy Policy for Cosori.de (“Website”) describes how Etekcity GmbH, a subsidiary of Vesync Group, its subsidiaries and affiliates (collectively, “Vesync”, “our”, “us” or “we”) collect, use, share, and store personal data. Etekcity GmbH is the data controller responsible for this Website. 

 

Coverage of Privacy Policy

This Privacy Policy only apply to the Website Cosori.de.

 

When you use smart products of Vesync Group, including but not limited to ETEKCITY, COSORI and Levoit brand, such smart products need to be connected to Vesync mobile application (“Vesync App”) to get full functions and services, please refer to Vesync App Privacy Policy for detailed information.

 

In addition, there are some links directed to third-party websites. When you use their services, they may collect your data. For this reason, we strongly suggest that you read the third party’s privacy policy. We are not responsible for, and cannot control, how third parties use personal data which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

 

The data we collect

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Profile Data, such as your username, password, email address and avatar.
  • Contact Data, such as receiver’s name, phone number, and delivery address.
  • Order Data, such as order number, product(s) purchased, payment information, delivery records.
  • Technical Data, such as the IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technologies on the devices you use to access this website.
  • Usage Data, includes data about how you use our website, products and services, such as session, history of operation, page response times, errors, length of visits to certain pages, page interaction data, history of logging in, your schedule settings, input records, search queries and methods used to browse away from the page.
  • Consumer Behavioral Data, such as products purchased, motivation for purchase, your interests, your preferences in receiving marketing from us and our third parties, your responses to surveys that we might ask you to complete for marketing and/or research purposes, and other purchasing behavior and preferences.
  • Communications Data, such as your communication preferences, and records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Content Data, such as the contentand review you post on the Website.

 

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.

 

We do not provide services for purchase by children. If you are under 18, you may use Vesync’s services only with the consent of a parent or guardian. We do not knowingly collect personal data from children under the age of 18 without the consent of the child’s parent or guardian. Should a parent or guardian have reasons to believe that a minor has provided Vesync with personal data without their prior consent, please contact us to ensure that the personal data is removed and the minor unsubscribes from any of the applicable services.

 

If you fail to provide personal data

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to provide some service, or perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions.You may give us directly your Profile Data, Contact Data, Order Data and Communication Data when you use some functions and service including but not limited to:
    • application for our products or services;
    • creation of an account on our website;
    • subscription of our service or publications;
    • request of marketing and promotion information to be sent to you;
    • entering a competition, promotion or survey; and/or
    • providing us feedback or contacting us.
  • Automated technologies or interactions.When you visit our website, we will automatically collect Technical Data, Consumer Behavioral Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.

 

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

See below for more information on the types of lawful basis that we will rely on to process your personal data.

 

Purposes for which we will use your personal data

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you for our services including to verify identity, assist with user-identification, and to determine appropriate services

Profile Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

To manage our relationship with you which will include:
(a) managing the purchase, delivery and post-purchase support of your products

(b) Sending important notices to you, such as communications about changes to our terms, conditions, and policies
(c) Asking you to leave a review or take a survey

Profile Data

Order Data
Consumer Behavioral Data
Contact Data
Marketing and Communications Data

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey

Profile Data

Order Data
Consumer Behavioral Data
Contact Data
Usage Data
Marketing and Communications Data

(a) Performance of a contract with you
(b)Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and for auditing, data analysis, loss prevention, and fraud prevention)

Profile Data
Order Data

Technical Data
Usage Data
Consumer Behavioral Data Marketing and Communications Data Contact Data

(a)Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you, such as providing our latest product and service announcements, software (including mobile applications) updates, and upcoming events, and to measure or understand the effectiveness of the advertising we serve to you

Profile Data
Consumer Behavioral Data
Contact Data
Usage Data
Marketing and Communications Data
Technical Data

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Technical Data
Usage Data
Consumer Behavioral Data
Marketing and Communications Data

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

Consumer Behavioral Data
Contact Data
Technical Data
Usage Data
Profile Data
Marketing and Communications Data

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table above:

  • Internal Third Parties - Your information may be shared among Vesync affiliates for the purposes described in this Privacy Policy. The term “affiliates” refers to companies related to Vesync by common ownership or control and who are based in the U.S., China and Germany and provide aftersales and technical support and undertake leadership reporting.
  • External Third Parties - In certain situations, the third party may sell items or provide services to you through our Services (either alone or jointly with us). Examples include sending emails, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), and providing customer service. For example, we use Shopify to power the Website- you can read more about how Shopify uses your personal data here:  https://www.shopify.com/legal/privacy.The third parties have access to the personal data that they need to carry out their tasks, but are not allowed to use it for other purposes. We will only share your personal information with third parties to the extent related to such transactions or services and in compliance with data protection laws.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

International transfers

Many of our affiliates and external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Whenever we transfer personal information to countries outside of the European Economic Area, we will ensure that the information is transferred in accordance with this Privacy Policy and as permitted by the applicable laws on data protection; or

Whenever we transfer your personal data to a country outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented in the form of specific contracts approved by the European Commission.

 

Data security

All information you provide to us is stored on the secure servers. Vesync implements reasonable and appropriate industry-standard security controls to protect personal data in its possession.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our application of any features and functionalities, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.

 

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

  • Request accessto your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correctionof the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasureof your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processingof your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processingof your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transferof your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any timewhere we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific data from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further data in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Entire Privacy Policy

We may provide you with separate privacy notices for specific products and services, and such privacy notices are incorporated into herein by reference. If there is any inconsistency between privacy notices and this Privacy Policy, the privacy notice shall prevail.

 

Changes to the privacy policy

We keep our privacy policy under regular review. These changes will be posted on this website and, where appropriate and applicable, notified to you by email.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

 

Contact details

If you have any questions about this privacy policy, please contact us using the details set out below.

Our full details are:

ETEKCITY GmbH

  • Legal Department
  • Email address:  privacy@vesync.com
  • Postal address: Vossbarg 1, 25524 Itzehoe, Germany

You have the right to make a complaint at any time to a relevant supervisory authority for data protection issues.