Personal Data Protection and Privacy Policy

NGTeco AIoT APP

 

This Policy applies exclusively to NGTeco's NGTECO AIoT APP products or services.

Last Updated: July 2026.

If you have any questions, comments, or suggestions, please contact us through the following contact information:

Email: ngtime@ngteco.com

Phone: +1 770 800 2321

 

This Policy will help you understand the following:

1. Personal Data Collection and Use Rules

2. How We Protect Your Personal Data

3. Your Rights

4. How We Process Personal Data of Minors

5. How We Transfer Your Personal Data Cross-Border

6. How This Policy Is Updated

7. How to Contact Us

 

Introduction This Privacy Policy describes how NGTECO (hereinafter referred to as "NGTECO," "we," or "our") collects, uses, discloses, and protects personal information in the course of providing the NGTECO AIoT APP and platform, related websites, cloud services, and hardware devices (collectively, the "Services"). We fully recognize the importance of personal data to you and will make every effort to protect the security and reliability of your personal data. We are committed to maintaining your trust in us and, in protecting your personal data, adhere to the following principles: the principle of consistent rights and obligations, the principle of specified purposes, the principle of choice and consent, the principle of minimization, the principle of ensuring security, the principle of subject participation, and the principle of openness and transparency, among others. At the same time, we undertake that we will adopt corresponding security protection measures in accordance with mature industry security standards to protect your personal data.

Before using this product (or service), please be sure to carefully read and thoroughly understand this Policy, and use the relevant product or service only after confirming that you have fully understood and agreed to it. Once you begin using this product or service, it signifies that you have fully understood and agreed to this Policy.

I. Personal Data Collection and Use Rules

(1) What Personal Data We Collect from You

1. When you use the NGTECO AIoT APP, we will collect the following data from you:

The business functions we provide rely on certain data to operate. If you choose to use such a business function, the necessary data that you are required to provide to us or permit us to collect includes:Username (name/nickname/alias/code), telephone number, and email address.

Depending on the software product you select, you may optionally entername/nickname/alias/code.

2. You may voluntarily choose to provide us with or permit us to collect the following data:

Such data includes:Personal photos, IP address data, MAC address data, SIM card data, and date and time of access.

Such data is not necessary for the operation of the business function, yet it is of great significance for improving service quality and developing new products or services. We will not compel you to provide such data, and your refusal will not adversely affect your use of the business function.

3. When you use the business function, our software will request the following system permissions related to personal data from you:

Including:Enabling camera capture, enabling audio and video recording, and obtaining location.

 

Permission Type

Function Scenario

Purpose of Use

Camera

To capture photos or videos of faults when submitting user feedback.

Used to capture manifestations of device faults so that we can accurately locate and resolve the issues you report.

Album/Storage

To select existing photos or videos from the album for upload when submitting user feedback.

Used to upload captured fault images or videos so that we can better understand and process your feedback.

 

The aforementioned permissions will not be enabled by default or compulsorily. We will request your authorization when you use a specific function, and you may voluntarily choose to consent or decline. After declining authorization, you will be unable to use the corresponding camera capture or image upload function, but this will not affect your use of other App functions.

 

Platform

Required Permissions

Purpose of Use

Android

Location information (Location) and Nearby Devices (Bluetooth)

The system requires location permission to be granted when using Bluetooth to scan for and connect to devices. We use this permission only when discovering and connecting to devices, and will not obtain your specific geographic location.

iOS

Bluetooth

An independent permission used solely to establish a Bluetooth connection, involving no location information whatsoever.

 

If you decline to provide the aforementioned permissions, you will be unable to use the Bluetooth connection-related device functions, but this will not affect your use of other App services.

To ensure the basic and normal operation of the App, troubleshoot faults, and conduct data analysis and optimization, we will collect your device information such as hardware model, operating system version number, software version number, device identifier, IP address, and network information. Such information is necessary for providing the service and ensuring secure operation. If you do not grant authorization, we will be unable to provide the business function. Apart from the aforementioned permissions, you may voluntarily choose whether to additionally grant other system permissions to the software.

When you contact us, we may retain data such as your communication/call records and content, or the contact information you leave, in order to contact you or assist you in resolving issues, or to record the handling plans and results of related issues.

(2) How We Use Your Personal Data

1. For personal data required for basic functions, we will use it to provide the business function, and we will also use the following data to maintain and improve this business function and to develop new business functions, among others.

 

Data Type

Purpose of Use

Username (name/nickname/alias/code)

Used for displaying your account identity, community interaction/friend identification, distinguishing different user entities within the platform, and providing you with a personalized account experience.

Telephone Number

Used for account registration, real-name authentication, login verification, security risk control (such as abnormal login alerts), service-related notifications (such as order activities, activity reminders, and after-sales feedback), customer service communication, and providing verification channels for you to recover your account/password.

Email Address

Used for account registration, real-name authentication, login verification, security risk control (such as abnormal login alerts), service-related notifications (such as order activities, activity reminders, and after-sales feedback), customer service communication, and providing verification channels for you to recover your account/password.

Device SN Code (Device Serial Number)

Used for device identity recognition and binding, after-sales and fault troubleshooting, and compliant device management.

Device Operation Records

Used for service function optimization, abnormal behavior monitoring, fault tracing, and problem localization.

 

2. Data Destruction

2.1 For biometric data stored locally on NGTECO devices, the data will be automatically destroyed when the device is decommissioned, factory-reset, or configured in accordance with the customer's retention policy.

(3) How We Use Cookies and Similar Technologies

1. Cookies

Cookies and similar technologies are commonly used technologies on the Internet. To ensure the normal operation of the website, we will store small data files called Cookies on your computer or mobile device. A Cookie typically contains an identifier, a site name, and some numbers and characters. With the help of Cookies, a website can store data such as your preferences. We will not use Cookies for any purpose other than those described in this Policy. You may manage or delete Cookies according to your preferences. You can clear all Cookies stored on your computer, and most web browsers have a function to block Cookies. However, if you do so, you will need to manually change user settings each time you visit our website.

2. Other Similar Technologies

In addition to Cookies, we will also use other similar technologies such as web beacons and pixel tags on the website to help us understand your product or service preferences and improve your service.

(4) How We Share, Transfer, and Publicly Disclose Your Personal Data

1. Sharing

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

We may share your personal data externally in accordance with the provisions of laws and regulations, or pursuant to mandatory requirements of competent government authorities.

2.    Transfer

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

a) Transfer upon obtaining explicit consent: after obtaining your explicit consent, we will transfer your personal data to other parties;

b) In the event of a merger, acquisition, or bankruptcy liquidation involving the transfer of personal data, we will require the new company or organization holding your personal data to remain bound by this Personal Data Protection Policy; otherwise, we will require such company or organization to re-seek your authorization and consent.

3. Public Disclosure

We will publicly disclose your personal data only in the following circumstances:

After obtaining your explicit consent;

Disclosure based on law: we may publicly disclose your personal data where required by law, legal proceedings, litigation, or mandatory requirements of competent government authorities, including:

(1) Those related to the performance by the personal data controller of its obligations prescribed by laws and regulations;

(2) Those directly related to national security and national defense security;

(3) Those directly related to public security, public health, and major public interests;

(4) Those directly related to criminal investigation, prosecution, trial, and judgment enforcement;

(5) Those aimed at safeguarding the vital legitimate rights and interests such as the life and property of the personal data subject or other individuals, where it is difficult to obtain the subject's own authorization and consent;

(6) Where the personal data involved has been publicly disclosed by the personal data subject themselves to the public;

(7) Those necessary for entering into and performing a contract at the request of the personal data subject;

(8) Those collected from lawfully publicly disclosed data, such as through lawful news reports and government data disclosures;

(9) Those necessary to maintain the safe and stable operation of the products or services provided, such as discovering and handling faults in products or services;

(10) Where the personal data controller is a news organization and such data is necessary for its lawful news reporting;

(11) Where the personal data controller is an academic research institution, the data is necessary for conducting statistical or academic research in the public interest, and the institution de-identifies the personal data contained in the results when providing academic research or descriptive results to the outside.

Please note that, in accordance with the law, when de-identifying, pseudonymizing, or anonymizing data, we will determine its legal nature in accordance with applicable law based on its processing method and identifiability, and adopt corresponding management measures. Sharing or transferring de-identified personal data, where it is ensured that the data recipient cannot restore and re-identify the personal data subject, does not constitute external sharing, transfer, or public disclosure of personal data, and the storage and processing of such data will not require separate notification to or consent from you.

II. How We Store and Protect Your Personal Data

(1) Data Storage Location

To provide the Services, your personal data will be transferred to and stored in a data center in Singapore (AWS).

(2) Security Measures

We attach great importance to the security of personal data. We adopt appropriate physical, administrative, and technical safeguards to protect your personal data against unauthorized access, disclosure, use, modification, damage, or loss. For example, we use encryption technology to ensure the confidentiality of data; we use protection mechanisms to prevent data from malicious attacks; we deploy access control mechanisms to ensure that only authorized personnel can access personal data; and we conduct security and privacy protection training to enhance employees' awareness of the importance of protecting personal data. We will make every effort to protect your personal data; however, please note that no security measure can be absolutely infallible.

(3) Retention Period

We will retain your personal data for the period necessary to achieve the purposes described in this Policy, unless an extended retention period is required or permitted by law. Because the storage period may vary depending on different scenarios and different products and services, our criteria for determining the retention period include: the time needed to retain personal data to fulfill the business purpose, including providing products and services, maintaining corresponding transaction and business records, controlling and improving the performance and quality of products and services, ensuring the security of systems, products, and services, and addressing possible user inquiries or complaints and localizing problems; whether the user agrees to a longer retention period; and whether laws, contracts, etc., impose special requirements for retaining data. We will retain your registration data for as long as your account is necessary for providing you with the Services. You may also choose to cancel your account; after you cancel your account, we will cease to provide products and services based on that account and, absent any special legal requirement, delete your corresponding personal data.

(4) Notification of Security Incidents

In the unfortunate event of a personal data security incident, we will, in accordance with the requirements of laws and regulations (no later than within 30 calendar days), notify you of: the basic circumstances of the security incident and its possible impact, the measures we have taken or will take to address it, suggestions for you to independently prevent and mitigate risks, and remedial measures for you, among others. We will notify you of the relevant circumstances of the incident by email, letter, telephone, push notification, etc.; when it is difficult to notify each personal data subject individually, we will issue a public announcement in a reasonable and effective manner. At the same time, we will also report the handling of the personal data security incident to the regulatory authorities as required.

(5) Statement on the Internet Environment

The Internet environment is not 100% secure. Despite these security measures, please note that there is no "perfect security measure" on the Internet, and we will make every effort to ensure the security of your data.

(6) Third-Party Links

To ensure a smooth browsing experience, you may receive content or web links provided by third parties outside us and our partners (hereinafter referred to as "third parties"). We have no control over such third parties. You may choose whether to access links, content, products, and services provided by third parties. We cannot control the privacy and data protection policies of third parties, and such third parties are not bound by this Policy. Before submitting personal data to a third party, please refer to that third party's privacy protection policy.

III. Your Rights

In accordance with relevant Chinese laws, regulations, and standards, as well as the prevailing practices of other countries and regions, we guarantee that you may exercise the following rights with respect to your own personal data:

(1) Accessing Your Personal Data

You have the right to access your personal data, except as otherwise provided by laws and regulations. If you wish to exercise the right of data access, you may access it yourself through the following method: https://ngteco.com

If you are unable to access such personal data through the aforementioned link, you may contact us at any time using our Web form, or send an email to ngtime@ngteco.com.

For other personal data generated during your use of our products or services, we will provide it to you as long as doing so does not require excessive effort on our part. If you wish to exercise the right of data access, please send an email to ngtime@ngteco.com.

(2) Correcting Your Personal Data

When you discover that the personal data we process about you is erroneous, you have the right to request that we make corrections. You may submit a correction request through the methods listed in "(1) Accessing Your Personal Data."

If you are unable to correct such personal data through the aforementioned link, you may contact us at any time using our Web form, or send an email to ngtime@ngteco.com.

(3) Deleting Your Personal Data

In the following circumstances, you may submit a written request to us to delete your personal data:

1. If our processing of personal data violates laws and regulations;

2. If we collect or use your personal data without having obtained your consent;

3. If our processing of personal data violates our agreement with you;

4. If you no longer use our products or services, or you have cancelled your account;

5. If we no longer provide you with the products or services.

(4) Right to Withdraw Consent to the Processing of Your Personal Data

Where required by applicable law, when we process your personal data based on your consent, you have the right to withdraw your consent to our processing of your personal data at any time. To protect your rights, you may contact us directly (VII. How to Contact Us) so that you can easily exercise this right. Withdrawing consent will not affect the lawfulness and validity of our processing of your personal data based on your consent prior to the withdrawal, nor will it affect our processing of your personal data based on other appropriate legal bases.

(5) Responding to Your Above Requests

To safeguard security, you may need to provide a written request or otherwise prove your identity. We may first require you to verify your identity before processing your request.

We will respond within 15 business days.

In principle, we will not charge a fee for your reasonable requests; however, for repetitive requests that exceed reasonable limits, we may charge a certain cost fee as appropriate. We may decline requests that are unreasonably repetitive, require excessive technical means (for example, requiring the development of a new system or a fundamental change to current practices), pose risks to the legitimate rights and interests of others, or are highly impractical (for example, those involving data stored on backup tapes).

In the following circumstances, we will be unable to respond to your request:

1. Those related to the performance by the personal data controller of its obligations prescribed by laws and regulations;

2. Those directly related to national security and national defense security;

3. Those directly related to public security, public health, and major public interests;

4. Those directly related to criminal investigation, prosecution, trial, and judgment enforcement;

5. Where the personal data controller has sufficient evidence that the personal data subject acts with subjective malice or abuses rights;

6. Those aimed at safeguarding the vital legitimate rights and interests such as the life and property of the personal data subject or other individuals, where it is difficult to obtain the subject's own consent;

7. Where responding to the request of the personal data subject would cause serious harm to the legitimate rights and interests of the personal data subject or other individuals or organizations;

8. Those involving trade secrets.

(6) Service Termination and Personal Data Processing

1. Termination scenarios: Termination of this Service includes circumstances such as your proactive application for termination, expiry of the service agreement without renewal, and our termination of the service in accordance with laws and regulations.

2. Methods of data disposal:

(1) Before termination, you may export or back up your personal data (including account data, usage records, etc.) through the service function;

(2) After the Service is terminated, we will permanently delete or anonymize your personal data within 30 calendar days, unless otherwise provided by laws and regulations.

(3) Termination process description: If you proactively terminate the Service, we will respond within 15 business days after you submit the application, and provide feedback on the result after completing the termination and data disposal.

3. Exceptional circumstances: For the purpose of complying with our statutory obligations (including but not limited to taxation, auditing, and network security), resolving disputes, enforcing the terms of the agreement, or cooperating with investigations by competent authorities, we have the right to continue retaining certain necessary personal data for the period prescribed by law or otherwise reasonably necessary. In such cases, we will strictly restrict access to such retained data and ensure that it is used solely for the specific, lawful purposes mentioned above.

IV. How We Process Personal Data of Minors

1. Our products, websites, and services are primarily intended for adults. We do not actively provide direct services to minors (as defined under the laws of your jurisdiction, generally individuals under the age of 18) or collect their personal data.

2. If you are a minor, you must, under the guidance of your parents or guardian (hereinafter collectively referred to as the "guardian"), have them carefully read and understand all contents of this Policy, and may use our services or provide us with any personal data only upon obtaining the guardian's explicit consent. Without the consent of a parent or guardian, a minor should not create their own personal data subject account. If you are a minor, we recommend that you ask your parents or guardian to carefully read this Policy and use our services or provide us with data only with the consent of your parents or guardian.

3. For personal data of minors collected with parental consent, we will use or publicly disclose such data only where permitted by law, where the parent or guardian has given explicit consent, or where necessary to protect the minor.

4. If we discover that we have collected personal data of a minor without first obtaining verifiable parental consent, we will immediately take the following actions:

(1) Cease processing the relevant personal information;

(2) Permanently delete such information from our systems as soon as reasonably practicable;

(3) Notify the relevant guardian as appropriate.

V. How We Transfer Your Personal Data Cross-Border

1. NGTeco is a global organization. We undertake that any transfer of personal data from your jurisdiction to another jurisdiction will strictly comply with applicable law and adopt adequate protective measures.

2. NGTeco will always take reasonable measures to transfer or process your personal data in accordance with applicable law, so as to protect your privacy and provide a level of personal data protection equivalent to that of your country/region, including by implementing Standard Contractual Clauses approved by the relevant regulatory authorities.

3. Your personal data may be received and processed by our affiliated companies or service providers in the following principal regions:

 

Data Recipient Information

Principal Country/Region

Types of Data Transferred Cross-Border

Purpose of Processing

AWS

Singapore

Account identity data: user nickname, email address, mobile phone number, device SN code (device serial number), etc.

Used to provide account services

AWS

Singapore

Transaction and consumption data: user consumption records, order details, and other payment-related information (de-identified data)

Used to provide order transaction and inquiry services

AWS

Singapore

Device and operation data: device operation records, device model, system version, operation path, etc.

Used for service optimization and security risk control data

AWS

Singapore

Other necessary data: other personal data necessary to realize core service functions and perform the user agreement

Used to provide authorized additional services

 

(We will enter into strict data protection agreements with all data recipients and require them to adopt security measures consistent with this Policy.)

4. If you would like to learn more about cross-border data transfers, please send an email to

(ngtime@ngteco.com)

We will properly handle your reply; however, please note that if you decline cross-border data transfers, we may be unable to provide you with our Services.

VI. How This Policy Is Updated

Our Personal Data Protection and Privacy Policy may change.

Without your explicit consent, we will not reduce the rights you are entitled to under this Policy. We will publish any changes made to this Policy on this page.

For material changes, we will also provide more prominent notice (including, for certain services, sending notice by email describing the specific changes to the Personal Data Protection Policy).

Material changes referred to in this Policy include, but are not limited to:

1. A significant change in our service model, such as the purposes of processing personal data, the types of personal data processed, and the ways personal data is used;

2. A significant change in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy, or mergers and acquisitions;

3. A change in the principal recipients with whom personal data is shared, transferred, or publicly disclosed;

4. A significant change in your rights regarding participation in personal data processing and the ways to exercise them;

5. A change in the responsible department, contact information, and complaint channels for handling personal data security;

We will also archive previous versions of this Policy for your reference.

VII. How to Contact Us

NGTECO Unit B, 20/F, COS Centre, 52-56 Tsun Yip Street, Kwun Tong, Kowloon, Hong Kong SAR, China

Support Email: ngtime@ngteco.com Support Phone (USA): +1 770 800 2321