Welcome to the {Bluetooth Headphone App Name} (hereinafter referred to as "App") developed by {Guangzhou Backwin Technology Co., Ltd.} (hereinafter referred to as "we" or "company"). We highly value your privacy rights and are committed to protecting your personal information. This privacy policy will help you understand how we collect, use, store, and protect your information.
We pledge to strictly protect your personal privacy in accordance with the requirements of the "Cybersecurity Law of the People's Republic of China," the "Personal Information Protection Law of the People's Republic of China," the "Data Security Law of the People's Republic of China," and other relevant laws and regulations. When using our App, you will share your information with us, and we hope to help you understand how we handle this information through this policy.
This privacy policy applies only to the relevant services of our Bluetooth headphone App. Please read this privacy policy carefully before using our services and confirm that you fully understand our approach to processing your personal information. If you do not agree with any content in this privacy policy, you should immediately stop using our products and services. Your continued use will be deemed as acceptance of the entire content of this privacy policy.
The information we collect is limited to that necessary for the functions of the Bluetooth headphone App and strictly follows the principles of legality, legitimacy, and necessity. We collect information through the following channels:
1.1 Information You Actively Provide
When you register an account, pair Bluetooth headphones, or use specific features, you may need to provide us with certain personal information. This information includes but is not limited to:
Account Registration Information: Such as phone number, email address, login password, etc. When necessary, we may also require you to provide identity verification information to ensure account security. If you choose to log in through a third-party platform (such as WeChat, QQ, Weibo, etc.), we will obtain public information from that platform, such as your avatar and nickname, to simplify the login process and provide you with a personalized service experience.
User Feedback Information: When you contact us or submit feedback, you may provide additional contact information and problem descriptions. We will keep these records for subsequent support and product improvement.
1.2 Information We Automatically Collect
When you use our App, we automatically collect technical information related to devices and application usage. This information helps us provide a better service experience and ensure the security of your device. Such information includes:
Device Information: We collect information about your Bluetooth headphones and mobile devices, including device name, model, operating system version, device unique identifiers (such as MAC address, IMEI code, IDFA, etc.), firmware version, battery level, Bluetooth connection status, etc. We use this information to ensure compatibility between the headphones and the App, and to optimize audio transmission quality.
Location Information: If you enable the location feature, we may obtain your location information based on your Bluetooth device signal, GPS, WiFi, and other technologies to provide functions such as "Find My Headphones." We will not collect your precise location data unless you authorize us to do so.
Usage Logs: When you use our App, we automatically collect and store certain log information, including but not limited to the function modules you use, audio settings, playback duration, Bluetooth connection status, system crash reports, and fault logs. This data helps us analyze product performance and fix issues promptly.
1.3 Information Shared by Third Parties
Third-Party Platform Sharing: If you log in through a third-party platform or use third-party integrated services (such as music streaming services), we will obtain your public information on that platform and link it to your App account.
Information Provided by Partners: In some cases, we may obtain part of your information from our partners, such as headphone manufacturers or technical service providers. They may share information about your headphone status, firmware version, etc., with us to provide service support or security upgrades.
Relevant Legal Basis:
According to Article 13 of the "Personal Information Protection Law of the People's Republic of China" (hereinafter referred to as the "Personal Information Protection Law"), we will only collect and use your personal information in the following situations:
You have given prior consent.
It is necessary for the performance of a contract or contract-related obligations.
It is necessary for the fulfillment of statutory duties.
It is necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations.
It is necessary to carry out news reporting, public opinion supervision, and other acts in the public interest, and the processing is within a reasonable scope.
Other situations stipulated by laws and regulations.
We strictly adhere to legal and regulatory requirements and use the collected information for the following purposes:
2.1 Core Function Support
Bluetooth Headphone Connection and Pairing: To help you smoothly connect Bluetooth headphones, we use device information and Bluetooth connection data to help you quickly pair devices and maintain stable connections during use. By detecting the strength and quality of Bluetooth signals, we can optimize the audio transmission experience.
Sound Effect Settings and Synchronization: Based on your headphone model and usage preferences, we provide you with various sound effect modes (such as noise cancellation mode, ambient sound mode) for selection and synchronize these settings across your different devices. We also automatically adjust sound effect modes based on environmental noise and your location to optimize your auditory experience.
Firmware Updates: We use headphone device information and version information to regularly push the latest firmware updates to ensure your headphones maintain optimal functionality and fix known bugs or vulnerabilities.
2.2 Personalized Services
Personalized Recommendations: By analyzing your audio usage habits (such as volume adjustment frequency, usage duration, commonly used modes, etc.), we will recommend suitable sound effect configurations for you. For example, if you often use headphones in noisy environments, the App may recommend that you enable the noise cancellation feature.
Intelligent Adjustment: Some high-end Bluetooth headphones have intelligent sound effect adjustment features. The App will automatically adjust the headphone's sound effect mode based on your usage scenario (such as sports, commuting, office work).
2.3 Security Protection
Account Security: To protect your account security, we may monitor abnormal login behavior through device information, login logs, and IP addresses. If we detect abnormal activity (such as logins from unfamiliar locations), we will promptly notify you and take necessary measures to ensure account security.
Bluetooth Connection Protection: We continuously monitor the security of Bluetooth connections to prevent unknown devices from attempting to connect or interfere with your headphone use.
2.4 Service Improvement and Troubleshooting
Fault Analysis: We use collected device logs and error reports to analyze and fix system faults. By recording crash logs and usage anomalies, we can quickly identify and resolve issues affecting user experience.
Product Optimization: Through analysis of usage data and feedback information, we continuously optimize the performance of the App and headphones. For example, user-reported connection issues and sound quality problems will be used to adjust Bluetooth transmission protocols or develop new sound effect modes.
2.5 Other Purposes Stipulated by Law
According to Article 13 of the Personal Information Protection Law, we may use your personal information without obtaining your authorized consent in the following situations:
Using your information as required by laws and regulations.
For the needs of maintaining public safety, social interests, and national security.
To protect your health and safety in emergency situations such as sudden public health events.
We promise not to sell or rent your personal information unless you authorize otherwise. We will only share, transfer, or publicly disclose your information to third parties in the following situations:
3.1 Sharing
After obtaining your explicit consent or authorization, we may share your personal information with the following third parties:
Technical Service Partners: To provide services such as headphone pairing, firmware upgrades, and cloud storage, we may share your device information and usage data with partners providing technical support. These partners can only process your information on the premise of providing services to us and must comply with our privacy policy.
Third-Party Platforms: If you log in to our App through a third-party platform (such as WeChat, QQ, Weibo, etc.), we will share part of your account information, such as login tokens, with these platforms to ensure smooth account login and service synchronization.
3.2 Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following situations:
Business Merger or Restructuring: In the event of a company merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will notify you and require the new company to continue to comply with this privacy policy. Otherwise, the new holder will need to re-obtain your authorized consent.
3.3 Public Disclosure
We will only publicly disclose your personal information in the following situations:
Obtaining Your Explicit Consent: With your explicit consent, we can publicly disclose the personal information you specify.
Legal Requirements: We may publicly disclose your personal information according to relevant laws and regulations, government departments, or judicial authorities' requirements. For example, in response to a court order or legitimate request from a government department, we will disclose necessary information in compliance with legal procedures.
Relevant Legal Basis:
According to Articles 29 to 31 of the Personal Information Protection Law, we will not share, transfer, or publicly disclose your personal information to third parties without your explicit consent, unless it complies with legal and regulatory requirements or is necessary for public interest.
4.1 Security Technical Measures
We have adopted industry-standard security measures to protect the personal information you provide. Specifically, these include:
Data Encryption: We use advanced encryption technologies (such as SSL/TLS protocols) when transmitting and storing data to ensure data confidentiality and prevent illegal acquisition or tampering during transmission.
Access Control: We strictly control access permissions to data, ensuring that only authorized employees or partners can access your personal information under legally necessary circumstances.
Anonymization Processing: In some cases, to conduct data analysis and research, we will de-identify or anonymize your personal information to ensure your privacy security.
4.2 Data Storage and Retention
We will store your personal information in accordance with legal and regulatory requirements and will only retain your information for the time necessary to achieve the purposes stated in this privacy policy. Generally:
Account Information: Your account information will be retained during your period of service use. If you actively delete your account or stop using our services, your personal information will be deleted or anonymized from our systems within 36 months.
Log Information: Log information and usage data are usually retained for a longer period to facilitate product optimization and security analysis.
4.3 Emergency Response
The internet environment is not absolutely secure, but we will strive to ensure information security. In the event of data breaches, tampering, or other security incidents, we will promptly notify you as required by law and take reasonable and effective remedial measures. We will inform you of the basic situation of the incident, possible impacts, and response measures through email, SMS, or App push notifications.
Relevant Legal Basis:
According to Article 42 of the "Cybersecurity Law of the People's Republic of China" and Article 45 of the Personal Information Protection Law, in the event of major data breaches or security incidents, we will take emergency measures and report the incident to relevant regulatory authorities.
You have the right to manage and control your personal information. We will ensure your following rights in accordance with legal requirements:
5.1 Accessing and Correcting Your Information
You have the right to access the personal information we hold about you and correct inaccurate or outdated information. You can view and modify your personal profile, Bluetooth device settings, etc., through the personal settings page in the App. If you find errors in the personal information we collect and use, you have the right to request us to make corrections.
5.2 Deleting Your Information
In the following situations, you can request us to delete your personal information:
We have collected or used your personal information in violation of laws, administrative regulations, or our agreement.
You no longer use our products or services, or you actively cancel your account.
After your deletion request is approved, we will delete your personal information as soon as possible within the legally prescribed period, unless laws and regulations require retention of this information.
5.3 Withdrawing Consent
You have the right to withdraw your consent for us to process your personal information at any time. You can revoke authorization for certain permissions (such as location information, microphone permissions, etc.) through the App's privacy settings page. Please note that withdrawing consent may affect the normal use of certain functions.
5.4 Data Portability
According to legal provisions, under certain conditions, you have the right to request that we provide your personal information in a portable format or transfer it to another data controller.
Relevant Legal Basis:
According to Articles 44 to 47 of the Personal Information Protection Law, you have the rights to access, correct, delete, and withdraw consent regarding your personal information. We will process relevant requests within a reasonable time based on your requirements and ensure the security of your personal information.
We highly value the protection of minors' personal information, especially in the use of digital products and services. Our Bluetooth headphone App is primarily intended for adult users, but we understand that some minors may use our products accompanied by parents or guardians. Therefore, we have taken special measures in protecting minors' personal information.
6.1 Principles for Protecting Minors' Personal Information
In accordance with the relevant provisions of the "Law of the People's Republic of China on the Protection of Minors" and the "Personal Information Protection Law of the People's Republic of China," we will adhere to the following principles when processing minors' personal information:
Principle of Minimum Necessity: We only collect personal information of minors that is necessary to provide products or services, avoiding excessive collection or personal information beyond the scope of service needs.
Principle of Guardian Consent: For minors under 16 years of age, we will obtain the consent of their parents or legal guardians before collecting, using, and storing their personal information, and provide clear explanations to ensure that guardians understand how we will process the minor's personal information.
Security and Privacy: We will adopt technical measures such as encryption and anonymization to ensure the security of minors' personal information, preventing illegal access, leakage, tampering, or destruction of information.
6.2 How We Collect and Use Minors' Information
When minor users use our Bluetooth headphone App, we may collect the following categories of personal information:
Account Information: When minor users register an account accompanied by parents or guardians, they may need to provide information such as phone number, username, and password. This information is used to create accounts, ensure account security, and provide related services.
Device Information: When using headphone pairing and App functions, we may collect device information such as the Bluetooth headphone's device name, model, connection status, etc.
Usage Logs: We will record minor users' headphone usage, including volume adjustments, usage duration, sound effect modes used, etc., to improve service experience.
All information collection and processing strictly comply with the principle of minimum necessity, and minors' information will be processed with the explicit knowledge and consent of guardians.
6.3 Information Management Rights for Minors
Guardians of minor users enjoy the following rights:
Right to Access and Correct: Guardians have the right to access and view the personal information of minors that we collect, and can request us to promptly correct the information if found to be incorrect.
Right to Withdraw Consent and Delete: Guardians can withdraw previous consent at any time and request us to delete the minor's personal information, unless relevant laws and regulations require us to continue retaining this information.
Right to Restrict Information: Guardians can limit the permissions for minors to use the App, such as turning off location information and audio setting permissions, to avoid information collection beyond necessary scope.
6.4 Legal Support and Basis
According to Article 72 of the "Law of the People's Republic of China on the Protection of Minors," providers of network products and services shall not obtain minors' personal information through deception, inducement, or other means, and shall take technical measures to ensure the security of minors' information.
According to Article 31 of the "Personal Information Protection Law of the People's Republic of China," when processing personal information of minors under 14 years of age, the consent of their parents or other guardians shall be obtained, and special protective measures shall be taken.
According to Article 40 of the "Cybersecurity Law of the People's Republic of China," network operators shall not disclose, tamper with, or destroy personal information they have collected, and shall not provide personal information to others without the consent of the person whose information was collected. They shall also take special security protection measures for minors' personal information.
To adapt to changes in laws and regulations or business development, we may update this privacy policy. Each update to the privacy policy will follow the principles of transparency and openness. We will inform users of policy modifications in advance and provide sufficient time for users to understand and accept these changes.
7.1 Notification Mechanism for Significant Changes
When significant changes occur to the privacy policy, we will notify users through various methods, including but not limited to:
In-App Notifications: We will notify users of privacy policy updates through App pop-ups or message notifications. Users can choose to continue reading the full content of the privacy policy.
Email Notifications: If you have registered an account and provided an email address, we will notify you of policy updates via email.
Official Website Announcements: We will also post announcements on the company's official website to inform users of privacy policy updates.
7.2 What Constitutes a Significant Change?
Significant changes include but are not limited to the following situations:
Major changes in the purpose or method of processing personal information: For example, if we introduce new technologies or features that significantly alter how we process information.
Changes in the way we share, transfer, or publicly disclose personal information: Such as when new third-party partners join and need access to user information.
Significant changes in user rights: For example, if laws and regulations stipulate that users enjoy new rights regarding personal information protection.
Changes in security measures or information processing procedures mentioned in the privacy policy: For instance, if we introduce new encryption technologies or security protection mechanisms that may affect users' information security.
7.3 User's Right to Choose
When significant changes occur to the privacy policy, users have the right to choose whether to continue using our products and services. If you do not agree with the updated privacy policy, you can stop using our services and cancel your account. If you continue to use the services, it will be considered that you agree to the new privacy policy.
7.4 Legal Support and Basis
According to Article 52 of the "Personal Information Protection Law of the People's Republic of China," personal information processors shall take necessary measures to ensure the security of personal information and promptly disclose personal information processing rules to the public. If we modify the privacy policy, we should inform users in advance within a reasonable range and ensure that users have the opportunity to choose whether to accept these changes.
According to Article 41 of the "Cybersecurity Law of the People's Republic of China," when collecting and using personal information, network operators shall disclose their rules for collection and use, and shall ensure that users can learn about and exercise their right to know through multiple channels.
We greatly value user opinions and feedback. If you have any questions, comments, or complaints about this privacy policy, or if you wish to exercise the rights described in this privacy policy, you can contact us through the following methods:
Email: {info@backwin.com}
Customer Service Phone: {020-36610959}
Customer Service Center: You can submit questions or feedback online through the customer service function in the App, or call our customer service hotline for assistance.
We will process your request within 30 days of receiving it, in accordance with relevant laws and regulations. For requests involving personal information access, correction, or deletion, you may need to provide identity verification information to ensure account security and information accuracy.
8.1 Your Rights and Request Processing
According to the "Personal Information Protection Law of the People's Republic of China" and related laws, you have the following rights regarding your personal information:
Right to Know: You have the right to know how we collect, use, share, and protect your personal information. We provide detailed explanations through this privacy policy.
Right to Access: You have the right to view personal information related to you that we have collected at any time. If you find the information inaccurate or outdated, you can request us to make corrections.
Right to Delete: In the following situations, you can request us to delete your personal information:
Information collection or use has exceeded the necessary scope.
You cancel your account or no longer use our services.
We have processed personal information in violation of laws, administrative regulations, or our agreement with you.
Right to Withdraw Consent: You can withdraw your previous consent for us to process your personal information at any time. After withdrawing consent, we will stop continuing to process your information, but this operation will not affect the legitimacy of previous processing actions based on your authorization.
Right to Data Portability: Under qualifying conditions, you have the right to transfer your personal information to other data controllers or request that we provide the information to you in a structured, commonly used electronic format.
8.2 How to Exercise These Rights
You can exercise your rights through the following methods:
Submit Online Application: You can submit applications for access, correction, deletion, or withdrawal of consent through the privacy settings page in our App. We will process your request as quickly as possible based on the content of the application.
Written or Email Application: You can contact our privacy protection department by sending a written application or email. We will respond promptly after receiving your application.
8.3 Complaints and Dispute Resolution
If you are dissatisfied with our processing methods or suspect that we have infringed upon your privacy rights, you can first contact us through the above contact methods. We will investigate and respond as soon as possible. If we cannot reach an agreement through negotiation, you have the right to complain to the competent data protection supervisory authority.
8.4 Legal Support and Basis
According to Articles 49 to 56 of the "Personal Information Protection Law of the People's Republic of China," personal information subjects enjoy rights such as access, correction, deletion, and withdrawal of consent. Personal information processors should process and provide feedback on the processing results as soon as possible after receiving requests from personal information subjects.
According to Article 40 of the "Cybersecurity Law of the People's Republic of China," when processing personal information, network operators must respect users' legal rights and ensure that users can effectively exercise their privacy rights.