Privacy Policy

So you have purchased our Tellur device hardware and are starting to use Tellur device software and all its functionalities! Any information you share with the operator - Tuya Smart Inc. - will be used in order for the services to be provided and in order to improve them to make them even better. Below you will find explanations regarding the ways of collecting and using information, and how the operator ( Tuya Smart Inc. ) protects your privacy. In this privacy policy, “personal data” means information that can be used to identify an individual, either from that information alone, or from that information and other information the operator has access to about that individual. Both personal and non-personal data are collected in order to enable and facilitate the best user experience possible.

What information is collected and how it is used?

Types of Personal Data Collected

In order to receive our services, you will be asked to provide the operator (Tuya Smart Inc.) necessary personal data that is required to provide those services. If you do not provide your personal data, the operator (Tuya Smart Inc.) will not be able to provide you with any services related to the Tellur device software.
- Set up and log in of Tellur Account. Personal data that are collected for creating a Tellur Account may include your email address or mobile phone number, device related information (e.g. IMEI number) and various location related information (e.g. location area code, mobile network and country codes).
- Purchasing your Tellur products. When you make purchases through the Tellur e-commerce website, your Tellur Account ID (or mobile phone number or email addressed used to create your Tellur Account), name, phone number, etc. are collected. ABN Systems International SRL, owner of Tellur brand has an after sales system to handle after sales related matters in respect to Tellur hardware. When you use these services, ABN Systems International SRL (operator in such cases) may also collect the order number, invoice date, list of purchased items and your contact details in order to process the services.
- Activating Tellur device. When you activate the Tellur device software, the operator (Tuya Smart Inc.) may collect your age, height, weight and gender. Also other details you provide as part of your profile such as your birthday, picture and signature may be collected.
- Sharing your content. When you share content or send information to family and friends, the operator (Tuya Smart Inc.) may collect personal information of those people, such as their names, email addresses, telephone numbers, and mailing addresses. You hereby represent and warrant that you have obtained necessary consent for use of third parties’ personal data if you choose to provide them to us. When you share content or invite users to use Tellur device, please note that other users may see personal data you share.
- Processing the services. In providing the above services, the operator (Tuya Smart Inc.) may also collect data in relation to your device, including your TELLUR device ID, firmware version, device OS version, model and system, and visiting IP and time.

How the Personal Data is used

- To provide you with products and services, performing contractual obligations, to ensure the functions and safety of Tellur products, to verify your identity, to prevent and trace fraudulent or inappropriate usage
- To develop Tellur products and services, together with general and statistical information
- To conduct investigations regarding our Tellur products and services
- To provide maintenance services, monitor software licenses, to improve Tellur products or analyse the efficiency of our operations

Other Information

Statistical data that does not specifically identify you (non-personal data) are used by the operator (Tuya Smart Inc.) to help and improve the products and services and provide a better user experience for you. Here are some of the non-personal data that may be collected and how it is used:

- When you create a Tellur Account, download Tellur software, register in the e-commerce website, participate in online surveys or interact in other ways, the operator (Tuya Smart Inc.) may collect your language preferences, postal code, area code number and time zone in which you use our products and services, and your profession.
- When you opt-in to participate in User Experience Improvement Program, statistics relating to your Tellur products functions, on an anonymous basis may be gathered. This may include information relating to your use of website, products and services. If there is an abnormal shutdown or breakdown, information relating to your mobile device may be collected to diagnose the problem.
- When you use Tellur services or functions that are based on location information, e.g. carry out a location search, take advantage of advertising, use weather functions, access information based on maps, etc., the operator (Tuya Smart Inc.) may collect your geographical information.
- When you use interactive applications, the operator (Tuya Smart Inc.) may use cookies and other technical elements (e.g. pixel label) to collect and store non-personal data.
- When you use the Internet browser in using Tellur products and services, the operator (Tuya Smart Inc.) may collect log information, e.g. IP address, browser type, language, reference source, operating system, date and time marking and click rate data.
- When you first use and activate your Tellur device, the device’s unique identification code and approximate geographical information may be collected.

You have control over your information!

Privacy concerns differ from person to person. Therefore, here are examples of ways you are free to choose to restrict the collection, use, disclosure or processing of your personal data and control your privacy settings, such as controlling the settings under the User Experience Improvement Program, Location Access functions, and your Tellur Account.

Access, Updating or Correcting Your Personal Data

- You have the right to request access and/or correction or any other personal data that the operator (Tuya Smart Inc.) holds about you. When you update your personal data, you will be asked to verify your identity before your request is proceeded. Once sufficient information is obtained to accommodate your request for access or correction of your personal data, the operator shall process in accordance with the laws of your country. While the operator will try its utmost in acceding to your requests, unreasonably repetitive or unrealistic requests or those that put others’ privacy at risk may be declined.
- Also, ABN Systems International SRL, as operator in connection with your personal data collected for the after sales function for hardware matters, will respect all rules mentioned above.
- Normally such services are provided for free, but the operator (Tuya Smart Inc.) and ABN SYSTEMS INTERNATIONAL reserve their right to charge a reasonable fee in certain cases.
- If you believe any information regarding your personal data is incorrect or incomplete, please write to or email as soon as possible at the mobile phone number below.
Phone number: 0086-400-881- 8611 - for the requests addressed to the operator
- 0086-400-881- 8611 - for the requests addressed to ABN Systems International SRL (only in respect to after sales of Tellur hardware related matters).
- For details relating to the personal data in your Tellur Account, you may also access and change them at mobile phone 0086-400-881- 8611.

Withdrawal of Consent

- You may withdraw your consent for the collection, use and/or disclosure of your personal data that are in operator's possesion or control by submitting a request. This may be done by accessing your Tellur Account management center at Email: Email . Your request will be processed by the operator (Tuya Smart Inc.) within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal data as per your request.
- Please be aware that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that you will not be able to enjoy Tellur products and services.

Who do we share your information with?

Unless it is mentioned othewise in this privacy policy, your personal information will remain confidential. Your personal data may be disclosed on occasion to third parties in order to provide the products or services that you have requested. Some of these third parties may be located outside your home country.

Disclosure may include the scenarios listed in this section below. In each case described in this section, you can be assured that the operator ( Tuya Smart Inc.) will only share your personal data in accordance with your consent. You should know that when the operator (Tuya Smart Inc.) shares your personal data with a third party under any circumstance described in this section, the operator will ensure that the third party is subject to practices and obligations to comply with the relevant data protection and privacy laws of your country. The operator will contractually ensure compliance by any foreign Third Party Service Providers with the privacy standards that apply in your home jurisdiction.

Disclosure to group companies of the operator and Third Party Service Providers

- In order to conduct business operations smoothly, the operator which collects your personal data may disclose your personal data from time to time to other group companies (in communications, social media, technology or cloud business), or third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centres, data storage facilities, and customer service providers, agents, related corporations, and/or other third parties (together “Third Party Service Providers”). Such Third Party Service Providers would be processing your personal data on the operator’s behalf or for one or more of the purposes listed above.
- Personal data will only be shared by the operator to provide or improve Tellur products or services and will not be shared for use for marketing purposes.

Disclosure to Others

The operator may disclose your personal data without further consent if required or permitted by law in the following cases:

- cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
- cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of the individual or another individual;
- cases in which the disclosure is necessary for the prevention of crime or legal proceedings;
- cases in which the purpose of such disclosure is clearly in the individual’s interests, and if consent cannot be obtained in a timely way;
- cases in which the disclosure is necessary for any investigation or proceedings;
- cases in which the disclosure is to any officer of a prescribed law enforcement agency upon production of written authorisation signed by the head or director of that law enforcement agency, or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer; and/or
- cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.

Information Not Requiring Consent

- Anonymised information and statistics in aggregate form may be shared with third parties for business purposes, for example with advertisers on websites, or can be disclosed to business partners the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.
- For the avoidance of doubt, in the event that the operator is allowed by law to collect, use or disclose personal data without your consent, such permission granted by the law shall continue to apply.

Information Safety Safeguards

The operator (Tuya Smart Inc.) is committed to ensuring that your personal data is secure. In order to prevent unauthorised access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect. Following security procedures and technical and organisational measures to safeguard your personal data were put in place by the operator:

- Your personal data is stored on secure servers that are protected in controlled facilities.
- All data saved in the back-end is classified into different levels based on the importance and sensitivity of the data, e.g. whether the data contains personal data.
- In the data centers, clusters that contain sensitive data are grouped together in the network topology, and will be placed in rooms with additional physical security protection.
- Data exchanged between Tellur devices and servers are encrypted using Secure Sockets Layer (“SSL”).
- There is an optional two-step verification process when users access their Tellur Account.
- There is regular review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
- Access is restricted to operator's employees and Third Party Service Providers who need to know the information in order to process it, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations.
- There are also access controls for all server clusters used for cloud-based data storage and process.
- Most data used for Tellur’s products and/or services is stored in a storage system. By using column family based access control mechanism, operator's employees are only allowed access to the data column families they are granted access to.
- Please note also that for the above, the operator (Tuya Smart Inc.) may use overseas facilities operated and controlled by the operator to process or back up your personal data. Currently, the operator has data centres in Beijing and Singapore. As a result, the operator may transfer to and store your personal data at its overseas facilities. However, this does not change any of our commitments to safeguard your personal data in accordance with this Privacy Policy.

Information safety is very important. The operator (Tuya Smart Inc.) will take all practicable steps to safeguard your personal data. Through the protective measures above, especially encrypted storage and transmission, your data is as secure as it can be. Certain details of encrypted data cannot be accessed by anyone except by you.

Minors

We consider it the responsibility of parents to monitor their children’s use of Tellur products and services. Nevertheless, it is our policy not to require personal data from minors or offer to send any promotional materials to persons in that category. Tellur does not seek or intend to seek to receive any personal data from minors. Should a parent or guardian have reasons to believe that a minor has provided Tellur with personal data without their prior consent, please contact the operator (Tuya Smart Inc.) to ensure that the personal data is removed and unsubscribe them from any of the applicable Tellur services.

Updates To The Privacy Policy

This Privacy Policy is under regular review. If the Privacy Policy will be changed, Tellur will post the changes on all the Tellur websites, so that you may be aware of the information that is collecte and its use. Such changes to the Privacy Policy shall apply from the time that we post the same on the Tellur websites. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal data from you or when we wish to use or disclose your personal data for new purposes.