Lingdu Cloud Control Privacy Policy

This Privacy Policy applies to the Lingdu Cloud Control App products and services of Lingdu (Guangdong) Intelligent Technology Development Co., Ltd. and its affiliates (hereinafter referred to as "Lingdu" or "we"), including how we collect, use, disclose, process and protect information you provide to us through the Lingdu Cloud Control App when using our products and services.

When we ask you to provide certain information in order to verify your identity while using Lingdu Cloud Control products and services, we will strictly use such information in accordance with this Privacy Policy and our user terms.

Last updated: 15 January 2026

Version: v1.14

We have revised this Privacy Policy. From the above date, this Privacy Policy provides details on how we manage the privacy of your personal information disclosed when you use all Lingdu Cloud Control products and services. Please read this Privacy Policy carefully. If you have any questions, comments or suggestions, please contact us via the contact information below:

Email: lingduxiaozhi@gd-ldznkj.com

This Policy will help you understand the following:

1. Rules for the collection and use of personal information

2. How we protect your personal information

3. Your rights

4. How your personal information is transferred worldwide

5. How we handle children’s personal information

6. Retention period of information

7. How this Policy is updated

8. How to contact us

Lingdu understands the importance of personal information to you and will do its utmost to keep your personal information safe and secure. We are committed to maintaining your trust in us and will abide by the principles of responsibility-consistency, clear purpose, informed consent, data minimization, security assurance, data subject participation and transparency when protecting your personal information. At the same time, Lingdu undertakes that we will adopt security protection measures that meet mature industry standards to protect your personal information.

Please read and fully understand this Privacy Policy before using our products or services.

1. Rules for the collection and use of personal information

1. Definitions

In this Privacy Policy, some specific terms are defined as follows:

User personal information: all data relating to an identified or identifiable natural person, either on its own or in combination with other information to which Lingdu has access, and which can be used to identify that person directly or indirectly, hereinafter referred to as "personal information".

Smart terminal: terminal products produced and manufactured by hardware manufacturers with internet access, data transmission capability and human-computer interaction interface, including smart home appliances, smart wearables and smart environmental purification devices. In this Policy, it specifically refers to the smart terminals you purchase and use.

Application: mobile applications (including mobile apps and mini programs) developed by Lingdu that help end users remotely control smart devices and connect them to the Lingdu IoT platform.

2. Personal information we collect

Our Application needs to rely on certain information to function properly.

When you choose to use the login, add-device and device-control functions of the Application, you need to provide or allow us to collect the following necessary information:

(1) Personal account information

Scope: your mobile phone number or email address.

Purpose: to create your Lingdu Cloud Control account.

(2) Handheld terminal or SIM card related information

Scope: information about the handheld terminal on which Lingdu Cloud Control runs, including device serial number, device MAC address, list of installed software, unique device identifiers (MEID / IMEI / IMSI / OAID / Android_ID / OPENUDID / GUID / SIM card IMSI information), sensors, phone model, OS version, system language, device manufacturer, mobile operator information, contacts, and information about processes running in the App.

Purpose: to provide services such as Wi-Fi device networking, Bluetooth device networking and NFC device adding based on your choices and consent.

(3) Smart device terminal information

Scope: information about smart terminals linked to your account, such as MAC address, device ID (DID), serial number, device IMEI, SIM card IMSI, device time zone, device network status (IP / network signal), firmware version and information about processes running in the App.

Purpose: to provide device connection, device control, device status synchronization and device linkage services.

(4) Login information

Scope: information related to your use of other mobile applications and websites, such as cookies and other anonymous identifier technologies, IP address, network request information, temporary message history, standard system logs and crash logs.

Purpose: to provide third-party platform login and third-party authorized login services based on your choice and consent.

(5) Account credentials

Scope: information related to your account credentials, such as passwords, password security questions and answers.

Purpose: to provide the password reset function.

A total of 5 categories of personal information are collected in this section.

3. Information you may choose to provide

(1) Certain personal account information

Scope: some of your Lingdu Cloud Control account information, such as your name, gender, avatar, address-related settings, and information you provide when submitting user feedback and suggestions, including the email/phone number you fill in, feedback content and issue logs.

Purpose: to provide account settings, sync account information and handle your feedback.

(2) Location information (only for specific services/functions)

Scope: various types of information related to your location, such as region and country code, city code, mobile network code, mobile country code, cell ID, area name, latitude and longitude, time zone and language settings.

Purpose: to provide weather services, home address setting and geofencing services.

A total of 2 categories of personal information are optional in this section.

This information is not required for the core functions of the Application, but is important for improving service quality, using specific services/functions and developing new products or services. We will not force you to provide this information. Your refusal will not adversely affect your use of the main functions of the Application.

4. System permissions requested by the Application

When you use the following Application functions, our App will request the following system permissions related to personal information:

(1) Microphone permission

The voice control and lighting rhythm features use your phone’s microphone to obtain sound information for analysis. The raw audio is processed only on your device and is not stored or uploaded to external servers.

(2) Camera permission

The QR code scanning, avatar changing and wallpaper changing features use your phone’s camera to capture images. Avatar and wallpaper images will be stripped of EXIF information and uploaded to our servers. These images will be deleted when you change the avatar or wallpaper again or when you delete your account.

(3) Photo library permission

The avatar and wallpaper changing features use your photo library to obtain image files. The selected avatar and wallpaper images will be stripped of EXIF information and uploaded to our servers. These images will be deleted when you change the avatar or wallpaper again or when you delete your account.

(4) Location permission

The home location editing and geofencing functions request your phone’s location information and upload it to our servers. The previous location information will be deleted when you update home location or edit the scene again.

(5) Contacts permission

The emergency contact function requests your phone’s contacts to help you quickly fill in information. The selected contact will be uploaded to our servers. The previous emergency contact information will be deleted when you update it or delete your account.

(6) Bluetooth permission

The functions of discovering Bluetooth devices, networking for Bluetooth devices, obtaining Bluetooth device status and controlling Bluetooth devices request your phone’s Bluetooth permission and use Bluetooth only in these functions.

(7) Storage permission

To ensure the stable operation of the Application, we need read/write access to your device storage in order to read/write necessary information such as pictures, files and crash logs for providing information publishing and local crash logging functions.

A total of 7 system permissions are requested.

If you do not grant these permissions, the corresponding features cannot be provided. Other than the above, you may choose whether to grant any additional system permissions to the App.

5. Third-party SDK list and third-party information sharing

We conduct strict security checks on third-party SDKs and APIs that we integrate and will disclose the latest integration status to you in a timely manner. For details, please refer to the privacy policies of the respective third parties.

Push / Notification Services

Huawei Cloud (API integration)

Third party: Huawei Cloud Computing Technologies Co., Ltd.

Function: Voice call notifications

Purpose: we use Huawei Cloud Voice as the telephony notification provider to call you for device alarms or scene alarms.

Yunpian (API integration)

Third party: Hangzhou Yunpian Network Technology Co., Ltd.

Function: SMS notification

Purpose: we use Yunpian as the SMS provider to send messages for device alarms or scene alarms.

Map Services

Tencent Map SDK

Third party: Shenzhen Tencent Computer Systems Company Limited

Function: Geofencing, home location

Personal information collected: precise location, background location access.

Purpose: we use Tencent Maps as a map data provider in China for geofencing and device location display.

Tianditu Map SDK

Third party: National Geomatics Center of China (Tianditu)

Function: Geofencing, home location

Personal information collected: precise location, background location access.

Purpose: we use Tianditu as another map data provider in China for geofencing and device location display.

6. How we use your personal information

For necessary personal information, we use it to provide the core functions of the Application, including:

(1) Creating your Lingdu Cloud Control account: personal information collected when you create an account via the web or mobile App is used to create your account and profile.

(2) Device onboarding: devices operated via the App must be verified for authenticity, so we verify factory MAC, DID and other information to confirm the legitimacy of the device. In addition, when devices need network access, you configure Wi-Fi via the App by entering the Wi-Fi SSID and password. This information is only used for device networking. Your Wi-Fi and password are encrypted and stored locally on the device and are not uploaded to our servers. You can delete this information on the device at any time. We also select the optimal connection method based on IP and network signal to ensure stable device connectivity.

(3) Device status display: enabling you to remotely view device status and operating conditions.

(4) Device control: enabling you to remotely control devices.

(5) Automation tasks: event information reported by your devices (depending on your privacy authorization settings for each device and the privacy policy of the device provider) can be used to create your personal automation tasks.

We also use the above information to maintain and improve the Application and to develop new features.

7. How we use non-essential personal information

For non-essential personal information, we use it for the following purposes:

(1) Providing push services: account and IMEI may be used to provide push services and send device notifications. You can disable this feature at any time in “Message Settings”.

(2) Providing location-based services: when you use Lingdu Cloud Control and smart terminals connected to it, we use location information to determine device time zones for accurate time display, login region and to enable certain functions in advance according to your choices. You can disable this feature by changing device settings or stopping use of the Application.

(3) Sending notifications: we may use your personal information from time to time to send important notices, such as notifications about abnormal device status, your customized device notifications (depending on the devices you purchase and add), and changes to our terms, conditions and policies.

(4) Collecting user feedback: feedback you choose to provide is very valuable in helping us improve our services. To track your feedback, Lingdu may use the personal information you provide to contact you and keep records.

8. How we entrust processing, share, transfer and disclose your personal information

(1) Entrusted processing

Certain modules or functions of the Application are provided by external suppliers. We use external service providers to implement specific business functions.

For companies, organizations and individuals that we entrust to process personal information, we require them to process personal information in accordance with our requirements, this Privacy Policy and any applicable confidentiality and security obligations.

(2) Sharing

We will not share your personal information with any company, organization or individual outside of our company, unless we obtain your explicit consent.

(3) Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

a. Transfer with explicit consent: after obtaining your explicit consent, we may transfer your personal information to other parties.

b. In case of merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new entity holding your personal information to continue to be bound by this Privacy Policy; otherwise we will require that entity to obtain your consent again.

(4) Public disclosure

We will only disclose your personal information to third parties as necessary to provide the products or services you request.

a. Depending on the situation, we may provide certain personal information to partners who cooperate with Lingdu in providing products and services or assisting Lingdu in marketing to customers. We only share personal information with third parties for the purposes of providing or improving our products, services and advertising, not for the purpose of their own sales, and we do not sell personal information. We require such partners to strictly abide by confidentiality and privacy obligations.

b. We may provide statistical information on your use of smart terminals to Lingdu’s partners. Such statistical information does not involve your name, account, password, phone number or email address.

c. Where our partners have explicitly informed you of the information they collect and its usage and have obtained your consent, we may disclose your personal information to such third parties in accordance with your authorization. For your security, we will anonymize or de-identify your personal information before disclosure where appropriate.

d. We may disclose your personal information as necessary in response to legitimate requests from government authorities.

e. We may disclose information related to you if we determine that such disclosure is reasonably necessary for enforcing our terms and conditions, protecting our operations or users, or involving matters of significant public interest.

f. In the event of reorganization, merger or sale, we may transfer all personal information we collect to the relevant third party.

In all the situations described above, you can rest assured that Lingdu will only share your personal information under your authorization. Your authorization to Lingdu includes the use of various sub-processors to process your personal information. You should understand that when we share your personal information with third-party service providers, we require them by contract to comply with applicable local data protection laws and privacy standards.

2. How we protect your personal information

1. We use security safeguards that meet industry standards to protect the personal information you provide and to prevent data from being accessed, disclosed, used, modified, damaged or lost without authorization. We will take all reasonable measures to protect your personal information.

2. We have implemented reasonable physical, technical and administrative safeguards to prevent unauthorized access, disclosure or other similar risks. We will take all reasonable measures to protect your personal information collected through your use of Lingdu Cloud Control App.

3. Our data security capabilities: your personal information is stored on secure servers and protected in controlled facilities. We classify your data based on importance and sensitivity and ensure that personal information is granted the highest level of security. Employees and third- party service providers who access such information to help provide products and services are subject to strict contractual confidentiality obligations. Violation of these obligations may result in disciplinary action, termination of cooperation, and in serious cases, criminal liability. We also implement dedicated access controls for cloud-based data storage. We regularly review our information collection, storage and processing practices, including physical security measures, to prevent unauthorized access and use.

4. We take all reasonable measures to ensure that we do not collect or use irrelevant personal information. We only retain your personal information for the period necessary to achieve the purposes described in this Policy, unless an extended retention period is required or permitted by law.

5. The internet environment is not completely secure. We will do our best to ensure or guarantee the security of any information you send to us. However, you should be aware that the use of the internet is not always secure, and we cannot guarantee the security or integrity of any personal information transmitted over the internet. If our physical, technical or administrative safeguards are compromised and result in unauthorized access, disclosure, alteration or destruction of information that harms your legitimate rights and interests, we will take appropriate measures to respond to the data breach, such as notifying relevant regulators and reporting the incident handling in accordance with legal requirements.

6. In the unfortunate event of a personal information security incident, we will inform you in a timely manner as required by laws and regulations of the basic details and possible impact of the security incident, the measures we have taken or will take, suggestions for you to mitigate risk, and the remedial measures for you. We will notify you of relevant information via email, letters, phone calls or push notifications. Where it is difficult to notify individuals one by one, we will issue an announcement in a reasonable and effective manner.

3. Your rights

In accordance with Chinese laws, regulations and standards, as well as common practices in other countries and regions, we guarantee that you can exercise the following rights with respect to your personal information:

1. Right to access your personal information

You have the right to access your personal information, except where otherwise provided by laws and regulations. You can exercise your right of access via: “My” – top right “Settings” icon – “Account details” in our Application.

2. Right to rectify your personal information

If you find that the personal information we process about you is inaccurate, you have the right to request correction. You can submit a correction request via the access path described above.

When you update personal information, we may first verify your identity before processing your request. We will respond to your request within the time limit specified by applicable data protection laws once we have sufficient information to process your request to access or rectify your personal information.

If you wish to request access to personal data we hold about you, or if you believe any information we hold about you is incorrect or incomplete, please contact us as soon as possible in writing or by email at the address below: lingduxiaozhi@gd-ldznkj.com.

3. Right to erase your personal information

You may request that we erase your personal information in the following circumstances:

(1) If our processing of personal information violates laws or regulations;

(2) If we collect or use your personal information without your consent;

(3) If our processing of personal information breaches our agreement with you;

(4) If you no longer use our products or services, or you delete your account;

(5) If we no longer provide products or services to you;

(6) If the data subject deletes the account.

4. You may delete your registered account at any time by going to “My” – “More” – “Delete account”. The personal information deleted includes:

(1) User account information;

(2) User device information;

(3) Device data;

(4) Images/videos captured by cameras;

(5) Feedback information;

(6) Device grouping information;

(7) User scenes (automation/linkage) information.

If we decide to respond to your deletion request, we will also notify entities that have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise required by laws or regulations or unless those entities have obtained your independent authorization.

When you delete information from our services, we may not immediately delete the corresponding information from our backup systems, but we will delete it during backup updates.

For users on client versions earlier than v1.4, you can contact our customer service at lingduxiaozhi@gd-ldznkj.com to deactivate your personal account.

5. Other information for users under the GDPR

(1) If you are an EU user under the General Data Protection Regulation (GDPR), you have the right to request that we erase your personal information. Where relevant provisions exist in the GDPR, we will assess the reasonableness of such a request and take reasonable steps, including technical measures.

(2) If you are an EU user under the GDPR, you have the right to restrict the processing of your personal information. We will assess the reasonableness of such a restriction request. Where relevant provisions exist in the GDPR, we will only process your personal information in ways that comply with applicable GDPR requirements and will notify you before the restriction is lifted.

(3) If you are an EU user under the GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

(4) If you are an EU user under the GDPR, you have the right to receive your personal information in a structured, commonly used and machine-readable format and to transmit that information to another controller.

6. When we may not be able to respond to your requests

We may not be able to respond to your requests in the following circumstances:

(1) Where the request relates to the performance of obligations under laws and regulations by the personal information controller;

(2) Where it is directly related to national security or national defense security;

(3) Where it is directly related to public safety, public health or major public interests;

(4) Where it is directly related to criminal investigation, prosecution, trial or enforcement of judgments;

(5) Where there is sufficient evidence that the data subject has subjective malice or is abusing rights;

(6) Where responding to the request would cause serious damage to the legitimate rights and interests of the data subject or other individuals or organizations;

(7) Where it involves trade secrets.

4. How your personal information is transferred worldwide

This Policy is formulated and governed by the laws of the People’s Republic of China.

Personal information collected and generated within the territory of the People’s Republic of China will be stored within China.

As we provide products and services using resources and servers around the world, this means that, with your authorization and consent, your personal information may be transferred to or accessed from jurisdictions outside the country/region where you use the products or services.

Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your personal information is afforded a level of protection equivalent to that in the People’s Republic of China. For example, we may seek your consent for cross-border transfer of personal information or implement de-identification measures before cross-border data transfers.

5. How we handle children’s personal information

Our products, websites and services are primarily intended for adults. Children should not create their own accounts as data subjects without the consent of parents or guardians.

Where we collect children’s personal information with parental consent, we will only use or disclose this information when permitted by law, with explicit parental or guardian consent, or when necessary to protect children.

Although local laws and customs may define children differently, we treat anyone under the age of 14 as a child.

If we discover that we have collected children’s personal information without verifiable parental consent, we will endeavor to delete the relevant data as soon as possible.

6. Retention period of information

We will retain your personal information for the period necessary to achieve the purposes described in this Policy or as required or permitted by applicable laws.

If there are reasonable grounds to believe that retaining personal information cannot achieve the purpose of collection, we will no longer retain the information or will de-identify it so that it can no longer be linked to a specific individual.

If further processing and archiving of information is required for public interest, scientific or historical research purposes, or statistical purposes in accordance with applicable laws, Lingdu may continue to retain the data even if the purposes of further processing are different from the original purposes.

7. How this Policy is updated

We regularly review this Privacy Policy and will update it to reflect changes in our information practices.

Without your explicit consent, we will not reduce your rights under this Privacy Policy. We will post any changes to this Policy on this page.

For major changes, we will also provide more prominent notice. For certain services, we may send notifications to the email address associated with your account, publish notices in the Lingdu Cloud Control App or send you mobile device notifications so that you can understand what information we collect and how we use it.

Major changes to this Policy include but are not limited to:

(1) Significant changes in our service model, such as purposes for processing personal information, types of personal information processed, or ways in which personal information is used;

(2) Significant changes in our ownership structure or organizational structure, such as business adjustments, bankruptcy or mergers involving changes in ownership;

(3) Changes in the primary recipients with whom personal information is shared, transferred or disclosed;

(4) Significant changes in your rights to participate in personal information processing and how such rights can be exercised;

(5) Changes in the departments responsible for personal information security, their contact information or complaint channels;

(6) Where personal information security impact assessment reports indicate high risks.

Changes to this Privacy Policy will apply from the effective date specified in the notice or on the website. We encourage you to regularly review this page to obtain the latest information about our privacy practices.

Your continued use of products and services on websites, mobile phones and/or any other devices will be deemed as acceptance of the updated Privacy Policy. When we intend to collect more personal information from you or use or disclose your personal information for new purposes, we will seek your consent again.

If you are an EU user under the GDPR, Lingdu will: adopt risk management methods to provide a systematic approach to managing personal data related to our employees, management processes and information systems. In accordance with the GDPR, Lingdu will:

Appoint a Data Protection Officer (DPO) responsible for data protection. DPO contact: lingduxiaozhi@gd-ldznkj.com.

Establish a Data Protection Impact Assessment (DPIA) process.

Priority: If you agree to the applicable user agreement and there is any inconsistency between such user agreement and this Privacy Policy, the user agreement shall prevail.

8. How to contact us

If you have any questions, comments or suggestions about this Privacy Policy, please contact us via:

Email: lingduxiaozhi@gd-ldznkj.com