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    Pavinno App Privacy Policy
    
     Effective Date: Jun 5, 2019
    
    
    At Yuninno Technology Co.,Ltd. we know privacy and security is important to you.
    The privacy of your personal data is also important to us. We will provide you with an experience on our app that is safe and secure.
    
    This Privacy Policy describes (a) the types of information we may collect or that you may provide when you download, install, register with, access or use the Pavinno app (the “App”), and (b) our practices for collecting, using, maintaining, protecting and disclosing that information. This policy applies only to information we collect in the App and in e-mail, text and other electronic communications sent through or in connection with this App.
    This App is for People Over the Age of 18
    
    YOU MUST BE AT LEAST 18 YEARS OF AGE TO USE THIS APP (For some areas, you are required to be 21 years of age, please refer to local laws). We do not knowingly collect personal data from persons under 18. Accordingly, all users will be required to acknowledge in the App that they are 21 or older prior to initial use. Additionally, if we learn we have collected or received personal data from a person under 18, we will delete that information. If you believe we might have any information from or about a person under 18, please contact us (For more information about us, please see Section 14).
    This Privacy Policy DOES NOT Apply to the Following Information
    
    This Privacy Policy does not apply to information that we collect offline or on any other of our apps or websites, including websites you may access through the App.
    Our websites, our other apps and third parties may have different privacy policies, which we encourage you to read before providing information on or through them. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with or use the App.
    The Pavinno Product Can be Used without this App
    
    You can use the Pavinno product alone, by apps locally or by apps without your personal account.
    If you only use the Pavinno product alone or by apps without a personal account, we do not ask you to provide your email address or other personally identifying information as part of the App installation process or otherwise. However, to use the App with our cloud service to record your personal information, you must create a personal account.
    Who We are and What We Need
    
    Our Privacy Policy governs the use and storage of your personal data which relates to a living individual who can be identified from that data. “Personal data” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Identification can be by the information alone or in conjunction with any other information in our possession or likely to come into such possession. We will collect your personal data either directly from you when you provide them to us or automatically when you use the App. Our processing of personal data of individuals in the European Union is governed by the General Data Protection Regulation 2016/679 (the “GDPR”).
    
    We, Yuninno Technology Co.,Ltd, are a controller of the personal data you (data subject) provide us. This means we decide how your personal data is processed and for what purposes. We collect the following types of personal data from you:
    
    *User info, including your email, phone number, signature, nickname, avatar, gender, photographs, etc.
    *Pavinno product usage records, including usage time, time length, parameter configuration information, etc.
    *When you use the app to share your published content and sent information. 
    *Pavinno product info, including device identifier, firmware version, device registration activation time, device type, device power.
    
     
    In addition, we collect the following types of personal data that may constitute special category personal data (i.e., sensitive personal data about an individual that reveals his or her racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data or biometric data for the purpose of uniquely identifying such individual, data concerning health):
    
     
    *The puff duration and frequency of smoking, and the preferences when using Pavinno product.
    Purpose and Legal Basis for Processing Your Personal Data
    
    We comply with our obligations under GDPR by keeping personal data up to date; by storing and destroying it securely; by not collecting or retaining excessive amounts of data; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.
    We need your personal data for the following purposes:
    
    *To provide and improve our services;
    *To provide you with a personalized experience on our App;
    *To enable you to login to our system and to access your personal history data at any time;
    
    When you register to use the App, we will require you to provide your email address or phone number , a photograph and a nick name, which will be stored on our servers, and we will provide you with a unique anonymous identifier at the same time.
    
    In addition, if you want to use the App with our cloud service to record your history data, we will need to collect such data. Such data may constitute special category data as described in Section 4. We collect such data for the purpose of providing you with personalized service and improve our services. In addition, we may also process your personal data for:
    
    *Compliance with a legal obligation to which we are subject;
    *Protecting your vital interests or that of another natural person;
    *The performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
    
    The purpose of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data.
     
    If you request that we stop processing some or all of your personal data or if you withdraw your explicit consent for our use or disclosure of your personal data for purposes set out in this Privacy Policy, we may not be able to provide you all of the services and customer support offered to our users and authorized under this Privacy Policy.
    Upon your request, we will close your account and remove your personal data from view as soon as reasonably possible, based on your account activity and in accordance with applicable national laws.
    Where We Do with It
    
    Your personal data will be processed in Room 605, No.2071 Hongmei Road, Xuhui District, Shanghai located in China. Hosting and storage of your data takes place at the facilities of Alibaba Cloud, which is located in China.
    Safeguarding and Retention of Personal Data
    
    We have implemented administrative, technical and physical measures designed to safeguard your personal data in our custody and control against theft, loss and unauthorized access, use, modification and disclosure.
    We restrict access to personal data on a need-to-know basis to employees and authorized third party service providers who require access to fulfill their job requirements.
    
    We keep your personal data for no longer than reasonably necessary for [Time Period] in order to provide you with a personalized experience and improve our services.
    
    After the relevant retention period, your personal data will be irreversibly destroyed. Any personal data held by us for marketing and service update notifications will be kept by us until such time that you notify us that you no longer wish to receive this information.
    Sharing Your Personal Data
    
    Your personal data will be strictly confidential. We will only share your data with third parties outside of us after you grant explicitly consent.
    We may disclose your non-personal information to other members of the Yuninno Technology Co.,Ltd. corporate family or to third parties. This disclosure will improve the user experience of our products and build some statistic data.
    Non-personal Identified Information We Collected
    
    We use third party service providers to collect certain analytical information to help us improve our products and the quality of the App. These third parties have stated to us that they will collect such data in an aggregate, anonymous form that does not personally identify any individual user. Such anonymous analytical data include the App features used and time spent on the App. As part of our commitment to privacy, you also have the option within the App to opt-in to the collection of anonymous data regarding the usage of your device ("Product Usage Data”) anonymously, such as  mode selection, and product model. You can opt-out of Paivnno's Collection of your Product Usage Data (if you previously opted in).
    What are Your Rights
    
    Unless there is an exception under the GDPR, you have the following rights with respect to your personal data:
    
    *To request a copy of your personal data that we hold about you;
    *To request that we correct any personal data if it is found to be inaccurate or out of date;
    *To request your personal data be erased where it is no longer necessary for we to retain such data;
    *To withdraw your consent to the processing at any time in case where consent is relied upon as the condition for processing;
    
    To request that we provide you with your personal data and where possible, to transmit such data directly to another data controller (where applicable), in cases where we process your data by automated means and the processing is either (a) based on consent or (b) necessary for the performance of a contract with you;
    Where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
    To object to the processing of personal data (where applicable), in case where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority), and in case where the personal data are processed for direct marketing, scientific/historical research and statistics purposes;
    To lodge a complaint with the relevant supervising authority.
    Transfer of Your Personal Data Abroad
    
    Your personal data will be transferred to mainland China where we are situated. Such transfer of your personal data will be protected by our undertaking made in accordance with the Standard Contractual Clauses adopted by the European Commission as appropriate safeguards.
    Further Processing
    
    If we wish to use your personal data for a new purpose not covered by this Privacy Policy, we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.
    Changes to the Privacy Policy
    
    We may update this Privacy Policy to reflect changes to our privacy and data practices. We encourage you to periodically review this notice. We may notify you the changes to this Privacy Policy by posting a notice at https://app.pavinno.com/privacy_en.html
    Contact Details
    
    In the event that you wish to complain about how we have handled your personal data, please contact us at dataservice@yuninno.com or in writing at Room 605, No.2071 Hongmei Road, Xuhui District, Shanghai, China. We will look into your complaint and work with you to resolve the matter.
    
     For Data Subjects in the EU:
    
      We appointed GDPR-Rep.eu as representative according to Art 27 GDPR. If you want to
      make use of your GDPR data privacy rights, please visit: https://gdpr-rep.eu/q/14216770
    
      Contact GDPR-Rep.eu
    
      GDPR-Rep.eu
      Maetzler Rechtsanwalts GmbH & Co KG
      Attorneys at Law
      c/o Yuninno Technology(Shanghai) Co.,Ltd
      Schellinggasse 3/10, 1010 Vienna, Austria
    
      Please add the following subject to all correspondence:
      GDPR-REP ID: 14216770
    
    Information according to Art 27 EU GDPR 
    Yuninno Technology(Shanghai) Co.,Ltd is a company located outside of the European Union. In order to comply with Art 27 EU GDPR, GDPR-Rep.eu has been nominated as our represenative in the European Union. If you want to make use of your data privacy rights, please visit: Our public Privacy dashboard.