Privacy

Neutron Smart Mobile Privacy Policy

Updated Date: 2021-08-03

NEUTRON GUVENLIK TEKNOLOJILERI A.S., its affiliates and subsidiaries (“we”, “us”, “our”, “NEUTRON”) are committed to protecting your privacy. This Mobile Privacy Policy (“Policy”) describes our practices in connection with information privacy on Personal Data we process through your individual use of the following services, products, and related mobile applications (collectively, the “Products”):

NEUTRON Smart Mobile Application

You may still use numerous NEUTRON services when you are signed out or without creating an account at all, such as searching and browsing any features on the Products.

In this Privacy Policy, “Personal Data” means information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual. “Smart Devices” refers to those nonstandard computing devices produced or manufactured by hardware manufacturers, with human-machine interface and the ability to transmit data that connect wirelessly to a network, “Apps” refers to those mobile applications developed by NEUTRON that provide end users remote control to Smart Devices and with the ability to connect to NEUTRON Cloud Platform.

What Personal Data Do We Collect

In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

1. Information You Voluntarily Provide Us

• Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.

• Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

2. Information We Collect Automatically

• Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.

• Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.

• Log Information: When you use our app, the system and exception log may be uploaded.

• Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as robot cleaner and weather service.

3. Smart Devices Related Information:

•Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.

Purposes and Legal Basis for Processing Personal Data

The purpose for which we may process information about you are as follows:

• Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,

• Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.

• Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on our Products and Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. The legal basis for this process ing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.

• Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to Participate in surveys relating to your use of our Products. The legal basis for this processing is your consent.

• Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

If there is any change in the purposes for processing your personal data, we will inform such change to you via email and/or a prominent notice on our website of such changes of purposes, and choices you may have regarding your Personal Data.

Who does We Share Personal Data with?

At NEUTRON, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients: • To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.

• To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.

• To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.

• As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• To subsidiaries or affiliates within our corporate family, to carry out regular business activities.

Except for the third parties described above, to third parties only with your consent.

International Transfer of Information Collected To facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live. Laws in these countries may differ from the laws applicable to your country of residence. When we do so, we will ensure that an adequate level of protection is provided for the information by using one or more of the following approaches: agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information, see here.

If you would like further detail on the safeguards we have in place, you can contact us directly as described in this Privacy Policy.

Children's Privacy

NEUTRON does not intend that any portion of the Site will be accessed or used by children under the age of 18, or equivalent minimum age in the relevant jurisdiction, and such use is prohibited. The Site is designed and intended for adults. By using the Site, you represent that you are at least 18 years old or above the equivalent minimum age in the relevant jurisdiction, and understand that you must be at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction, in order to use the Site. If we have collected or received personal information from a child under 18 or equivalent minimum age in the relevant jurisdiction without verification of parental consent, we will promptly delete such information. If you are a parent or guardian of a child under the age of 18 or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us, please contact us. A parent or guardian of a child under the age of 18 or older equivalent minimum age in the relevant jurisdiction may review and request deletion of such child's personal information as well as prohibit the use thereof.

Your Rights

Subject to limitations in applicable law, you have certain rights in respect to your personal information, such as a right of access, rectification, restriction, opposition, deletion, etc. In order to exercise your rights please contact us. You also have the right to withdraw your consent at all times, free of charge. You can do this by opting out from direct marketing and e-newsletters and by rejecting the use of cookies through your browser settings.

Securing and Retaining Your Information Security. We have implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We have a team dedicated to keeping your information secure and testing for vulnerabilities. We also conduct periodic reviews and assessments of the effectiveness of our security controls.

Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, NEUTRON cannot guarantee that your personal information is under absolute security with the existing security technology. If you have any questions about the security of the Site, please contact us.

Retention Generally, we store your information on NEUTRON's servers which is established upon third-party servers until you delete or edit it, or for as long as we need it to support your use of our Site, unless a longer retention period is required or permitted by applicable law

Dispute Resolution If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us.

Changes to this Policy Policy

We may modify this Privacy Notice at any time. If we make material changes to this Privacy Notice, we will notify you prior to the update's effective date by posting the notification on the Site.