Privacy Policy

This privacy policy sets out how Turtle Fit (hereinafter referred to as “we”) collects, uses, discloses, handles and protects the information you provide to us when you use our products and services. If we ask you to provide certain information in order to verify your identity when using Turtle Fit products and services, we will only use this information in strict compliance with this privacy policy and/or our user terms and conditions.

This privacy policy was formulated with full consideration of your needs; it is very important that you fully understand our personal data collection and use practices and are confident that you can ultimately control the personal information provided to Turtle Fit .

In this privacy policy, “personal information” refers to the information itself or data that can identify a specific individual after contacting other information of individuals that Turtle Fit can access. Such personal information includes your name, address, telephone number and email address.

By using Turtle Fit products and services, it means that you have read, approved and accepted all the terms in this privacy policy, including any changes we make at any time. We are committed to complying with applicable laws (including the data protection laws of your location) to protect the privacy, confidentiality and security of your personal information. At the same time, we promise all our employees and agents to fulfill these obligations.

Finally, what we want is to bring the best experience to our users. If you have any questions about the data processing practices outlined in this privacy policy, please contact our data protection officer at info@turtlefit.co.uk so that we can deal with your special needs. We are happy to deal with your problem directly.

What information is collected and how is it used?

1.    Set up Turtle Fit account. When creating a Turtle Fit account through Turtle Fit , the information filled in will be used to create your Turtle Fit account and display relevant data in Turtle Fit .

2.    Calculate exercise and health results. We will use personal body data and/or data recorded by the device to calculate exercise and health results, which are used to show you in the APP and/or device, such as:
BMI, PAI, muscle, body fat, moisture, protein, basal metabolism, internal organs Fat, bone mass, body size, body age, stress, calorie consumption, maximum oxygen uptake, training effect, training load, recovery time.

3.    Physical condition analysis. Based on the personal physical data provided by you and the data recorded by the device, we will provide you with analysis related to your physical condition for your reference. For example: to provide you with an interval value of ideal weight for your reference; to show you your current and/or all-day stress value and/or stress change trend.

4.    Provide Turtle Fit services. After the related device is synchronized with Turtle Fit , the data recorded in the device will be synchronized to Turtle Fit and displayed to the user.

5.    Display incoming call information. When you receive a call or text message, some devices that support this function will display the
call or message data.

6.    Display music information. When you use the music control function, some devices that support this function will display music information (for example: song name, album name, artist, playing topic, song status).

7.    Off- wrist locking function is provided. Your bracelet’s unlock password will be used to lock the bracelet away from your wrist. If you enable this function, when the bracelet detects that the device is not worn, the password lock screen will be activated. After entering the wrong password more than a certain number of times on the wristband , the user will be prompted to change the password on the Turtle Fit App or choose to restore the factory settings on the wristband .

8.    Determine whether the phone is supported. The information related to your mobile phone will be used to determine whether your
mobile phone can use Turtle Fit .

9.    Provide world clock function: You can Turtle Fit add clocks around the world based on your needs, we will calculate your time out of your phone corresponding to the area of your choice and local time in Turtle Fit and some support from the World clock function On your device.

10.  Provide alarm clock reminder function: We will collect your mobile phone alarm clock information, and when you turn on the mobile phone alarm reminder, you will be reminded by the vibration of the device in time.

11.  Bluetooth camera: You can control the phone’s camera with some devices that support this function. To this end, the device will perform Bluetooth pairing with the mobile phone so that it can be used to control taking pictures. During the Bluetooth pairing process, it will also apply for mobile phone Bluetooth permissions.

12.  Provide women’s health function: When you choose to use the women’s health function, you can record and view information related to menstrual period on some devices that support this function or in Turtle Fit ; we will predict the menstrual period for you based on the information you fill in. Make a reminder. We may also recommend suitable training courses for you based on your menstrual time and your physical condition during menstruation.

13.  Provide network-related services. Turtle Fit will prompt users to download sports-related videos based on different network types, network signals and other information, and determine whether there is a new version of Turtle Fit that can be updated.

14.  Statistical analysis: We will conduct statistical analysis on our services or equipment, and may share these statistical data with the public or third parties to show the usage trends of our products or services, optimize products and services, and provide you with Display rankings, friend PK, etc., for example, by counting your steps, showing you the results that are relevant to you (such as users in the same area), but these statistics do not contain any identifying information about you.

Types of information collected

In order to provide you with our services, we will ask you to provide the personal information necessary to provide you with the services. If you do not provide personal information, we may not be able to provide you with our products or services.

We collect the following types of information (whether it is personal information or not):

1. About your information: We may collect and use WeChat account, mobile phone number, avatar, personal signature, nickname, gender, time zone, language, your sports preferences and regional data.
2.  
3. Shopping-related information: We will not collect your order-related information when shopping using the mall in the APP.
4. Personal physical data: After starting Turtle Fit , we need you to provide birthday, height, weight, and gender data.
5. Data recorded by the device: When you use Turtle Fit to synchronize the data of related devices, we will record personal information, including activity information, sleep information, heart rate information, weight, standing measurement time with closed eyes, number of strokes, stroke rate, Number of swimming trips, impedance value, distance, swimming style, pace, exercise time.
6.  
7. Behavior marking information: When you choose to mark related behaviors, Turtle Fit will collect, including but not limited to, activity information, heart rate data, etc. to provide you with the corresponding service marking function.
8. Incoming call information: When you use the incoming call, SMS reminder function, Turtle Fit will get the data related to the incoming call, SMS, and address book. With your permission, the relevant caller, text message, address book and other data are used for the display of devices such as wristbands and watches, but Turtle Fit will not store your relevant call, text message, address book related data.
9.  
10. Mobile phone information: When you use Turtle Fit , we need to obtain your mobile phone operating system version and mobile phone brand model, mobile phone hardware identifier (such as IDFA, IMEI), mobile phone system time, mobile phone alarm clock.
11.  
12. Network usage data: We may collect network types, network signals, etc. related to specific functions of Turtle Fit .
13. Music control information: When you use the music control function, we will collect the music information in your phone (for example: song name, album name, artist, playing topic, song status) and synchronize it to the device. This information is only displayed on the device, and we will not store the aforementioned information.
14.  
15. Location data: When you use location-based program services or features, we may collect your location data.
16. Feedback information: When you submit relevant feedback, relevant user feedback logs, contact information and other information will be collected according to your choice.
17.  
18. Device information: When you use Turtle Fit to connect to a hardware device, including but not limited to the device’s unique identifier, firmware version, approximate geographic location data (non-personal data) and related function usage statistics (non-personal data) Will be transmitted to the server. The above data collection may also apply to your system or software update, restoration of original factory settings, etc.
19.  
20. Wristband unlocking information: When you use the Turtle Fit bracelet to unlock the off-wrist lock, we will collect your bracelet unlock password for this function.
21.  
22. Information that you actively submit when you use related functions: If you choose to publish your status in the Turtle Fit community, the pictures, texts and other related information you actively send to the community will be collected for you to share; if you choose to participate in Turtle Fit events Events or events, the information generated by these events and events will be collected and used to judge whether the event is up to the standard; if you have set your goals and heart rate reminders in Turtle Fit , you will fill in your own sports goals, weight goals, and heart rate The reminder value will be collected so that you can be reminded or warned when the goal is reached. If you choose to use the women’s health function, you voluntarily fill in the number of days of menstruation duration, the number of days between the start of menstruation, the date of the most recent menstruation, and the start date and end date of menstruation submitted every time you use this function The physical condition and mood during menstruation will be collected. If you choose to make the watch face yourself, the pictures you upload yourself will be collected by us to serve as your watch face background.
23. Relatives and friends information: When using the function of relatives and friends, you can choose to add other users as your relatives and friends. After your relatives and friends are authorized, your relatives and friends’ data (such as activity data, sleep data, weight data, etc.) will be used to show you .
24.  
25. Visitor information: When using the visitor function, a third party can experience our products and some services. The third party’s data (gender, height, birth date) will be collected and used to calculate and display the measurement of the service experienced by the visitor As a result, we will not save the aforementioned data.

Special Note

The content of the service provided by Turtle Fit is only for users to exercise and understand their own conditions as an auxiliary reference, and cannot be used for medical purposes. If you have any physical discomfort, please consult a doctor, Turtle Fit is not responsible for related direct or indirect damages. The service content of Turtle Fit is for general reference only, it may not be suitable for specific users, especially for:

1. People with a history of heart disease, stroke, high blood pressure, hyperlipidemia, diabetes, asthma and other circulatory and respiratory diseases.

2. Turtle Fit is responsible for insufficient food intake, weight loss or weight gain, fainting, malnutrition or other consequences caused by calorie consumption after wearing a Turtle Fit bracelet or watch.

3. Although the Turtle Fit bracelet or watch can monitor heart rate, blood pressure, blood oxygen, sleep quality, exercise capacity, etc., it cannot be used for any medical purposes. Before starting any exercise and diet plan, consult your doctor.

How this personal information will be used

The purpose of collecting personal information is to provide you with products and/or services and to ensure that we comply with applicable laws. You hereby agree that we process personal information for the purposes specified in this privacy policy and disclose personal information to our affiliates (which involve communications, social media, technology and cloud business), and third-party service providers (defined below).

We may use your personal information for the following purposes:

Direct promotion

· We may use your email address, Turtle Fit account number, mobile hardware identifiers (such as IDFA, IMEI) to provide you with products and services of Turtle Fit companies and business partners (providing networks, mobile applications, and cloud products and services) Related promotional materials. In order to provide a better user experience, we will recommend the above products, services and activities based on your purchase history, website browsing history, birthday, age, gender, and geographic location. We strictly abide by the data protection laws of your location and require independent explicit permission, so we will only use your personal information when we have your consent or when you express no objection.

· You have the right to terminate our use of personal data planned for direct marketing. If you want us to stop direct promotion to you or no longer want to receive certain types of promotion content, you can turn off this feature in Turtle Fit . We will not transfer your personal information to our business partners for direct marketing purposes.

Cookies and other technologies

lWhat data do we collect and how will it be used? Both Turtle Fit and third-party service providers use technologies such as cookies, tags and scripts. These technologies are used to analyze trends, manage websites, track website user dynamics, and collect demographic data about our overall user base. We will receive reports on the use of the above technologies prepared by relevant companies individually and as a whole.

lRecord files: As with many websites, we will collect certain data and store them in the record files. Such data reports include Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or click traffic data. We will not associate such automatically collected data with other data we collect about you.

lAdvertisement : We cooperate with third-party service providers to display advertisements on our website or manage our advertisements on other websites. Our third-party service providers may use cookies and other technologies to collect information about your activities on this website and other websites in order to provide you with advertisements based on your browsing activities and interests. If you do not want your personal information to be used to provide you with interest-based advertising, you can send an email to info@turtlefit.co.uk .

lMobile analysis: We use mobile analysis software in some mobile applications to let us know more about the mobile software functions on your mobile phone. This software can record the frequency of your use of the application, events that occur in the application, comprehensive usage, performance data, and application failure information. We will not associate the data stored in the analytics software with any personal data you submit in this mobile application.

lRegional Storage – HTML5/Flash: We use Local Storage Objects (LSO), such as HTML5 or Flash to store content and preferences. Third parties that cooperate with us and provide certain features on our website, or display advertisements based on your web browsing activities, also use HTML5 or Flash cookies to collect and store information. Various browsers will provide their own management tools to delete HTML5 LSO.

Who do we share your information with?

We will not sell any personal information to third parties.

We may sometimes disclose your personal information to third parties (see below for definitions) in order to provide the products or services you request.

We may disclose to the third-party service providers and affiliates listed below in this section. In the various situations described in this section, you can rest assured that Turtle Fit will only share your personal information based on your authorization. You should understand that in any of the situations described below, when Turtle Fit shares your personal information with third-party service providers, Turtle Fit will stipulate the practices and obligations of the third party through contracts and comply with applicable local data protection laws. Turtle Fit will contract to ensure that third-party service providers comply with the privacy standards applicable to them in your jurisdiction.

Sharing information with our group and third-party service providers

We may integrate SDKs (software development kits) provided by third-party services in our devices or apps to provide you with all the functions of the products and services. We may from time to time provide you with other Turtle Fit affiliates (which involve communications, social media , Technology or cloud business) or our third-party service providers (our mailing shops, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and promotion service providers, representatives of Turtle Fit ‘S agent) related companies and/or other third parties (collectively referred to as “third-party service providers”) to disclose your personal information. Such third-party service providers may process your personal information on behalf of Turtle Fit or for one or more of the above items. If you no longer wish to allow us to share this information, please send an email to info@turtlefit.co.uk to contact us.

Currently, our third-party service providers include the following two types:

1) Analyze service providers in the service category. Unless we have your permission, we will not use your personally identifiable information (referring to information that can identify you, such as your name or email address, through which you can be contacted or identified) with the provision of advertising and analysis services Of partners share. We will provide these partners with information about advertising coverage, advertising click-through rates and effectiveness, but will not provide your personally identifiable information, or we will aggregate this information so that it does not identify you personally) to help them understand Its audience or customers.

2) Suppliers, service providers and other partners. We send information to suppliers, service providers, and other partners who support our business worldwide. These supports include providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, and providing customers Services, product features, payment convenience, or academic research and surveys.

We guarantee that we only share personal information necessary to provide you with services for legitimate, legal, necessary, specific, and clear purposes. If we share your personal information with these third parties, we will adopt encryption and other means to protect your information. For companies and organizations with which we share personal information, we will conduct reasonable review of their data security environment, and sign strict data processing agreements with them, and require third parties to take adequate protection measures for your information and strictly abide by relevant laws Regulations and regulatory requirements. You should understand that our authorization includes sub-processors for third-party service providers.

Share information with others

When required by applicable laws, Turtle Fit may disclose your personal information without further consent.

Information that does not require consent

· We may share anonymous information with third parties (such as advertisers on our website) in an aggregated form for commercial purposes; we may share general usage trends of our services with them, such as purchasing certain products or engaging in certain transactions The number of customers in a specific demographic.

· For the avoidance of doubt, Turtle Fit may collect, use or disclose your personal information without your consent within the circumstances and scope expressly permitted by local data protection laws (for example, to comply with subpoenas), and when we may be in good faith Believe that when disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to government requests, disclose your information without your consent.

Security

Turtle Fit ‘s safety measures

We promise to keep your personal information safe. In order to prevent unauthorized access, disclosure or other similar risks, we have implemented reasonable physical, electronic and management measures and procedures to protect the information we collect from your device. We will take all reasonable measures to protect your personal information.

All your personal information is stored on a secure server and protected in a controlled facility. We classify your data based on importance and sensitivity, and ensure that your personal information has a reasonable level of security. Similarly, we have special access control measures for cloud-based data storage. In summary, we regularly review information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.

We will strictly select business partners and service providers, and implement the requirements for personal information protection into the business contracts or audits, assessments and other activities of both parties. We guarantee that employees and third-party service providers who access this information to help provide you with products or services have strict contractual confidentiality obligations. If they fail to perform these obligations, they will be disciplined or terminated.

We will organize security and privacy protection training courses, testing and publicity activities to strengthen employees’ awareness of the importance of protecting personal information. We will take all feasible measures to protect your personal information. However, you should be aware that the use of the Internet is not always secure, and therefore, we cannot guarantee the security or integrity of any personal information during two-way transmission over the Internet.

We will promptly notify relevant regulatory agencies regarding personal data leakage, and notify data subjects of relevant data leakage incidents in accordance with applicable legal requirements (including data protection regulations in your location).

What can you do!

· By not disclosing your login password or account information to anyone (unless this person is formally authorized by you), you can set a unique password for Turtle Fit to prevent other website password leaks from endangering your account security. At any time, please do not disclose the verification code you received to anyone (including those who claim to be Turtle Fit customer service). Whenever you log in, especially when logging in on another person’s computer or public Internet terminal, you should always log out at the end of the session.

· We are not responsible for security omissions caused by third parties accessing your personal information due to your failure to maintain the privacy of your personal information. Notwithstanding the above provisions, if any other Internet users use your account without authorization or any other security breach, you should notify us immediately.

· Your assistance will help us protect the privacy of your personal information.

Retention policy

We retain personal information based on the period necessary for the purpose of information collection described in this privacy policy and the privacy policy of specific services, or in compliance with applicable legal requirements. After completing the collection purpose, or after we confirm your deletion or cancellation application, or after we terminate the operation of the corresponding product or service, we will stop retaining it and delete or anonymize it. If it is for public interest, scientific, historical research or statistical purposes, we will continue to retain relevant data based on applicable laws, even if further data processing has nothing to do with the original collection purpose.

Access other functions on your device

Our app may access certain functions on your device, such as Wi-Fi network status, and other functions. This information is used to allow these applications to run on your device and allow you to interact with them. At any time, you can revoke the permission by closing the app at the device level or contacting us via info@turtlefit.co.uk

You can control your information!

Control settings

Turtle Fit recognizes that everyone has different concerns about privacy. Therefore, we have provided some examples to illustrate the various methods provided by Turtle Fit for you to choose to restrict the collection, use, disclosure or processing of your personal information, and to control your privacy settings:

· Turn on or off the user experience plan and location access function;

· Login or logout of Turtle Fit account;

· Click “Settings-Menstrual Period Reminder” to turn on/off

· Turn on or turn off other services and functions that handle sensitive or personal information.

If you have previously agreed to our use of your personal information for the above-mentioned purposes, you can change your decision by contacting us in writing or sending an email to info@turtlefit.co.uk at any time .

Access, update or correct your personal information

· You have the right to request access to and/or correction of any personal information we hold about you. When you update your personal information, we will ask to verify your identity before we process your request. Once we have sufficient information to process your request to access or correct your personal information, we will respond to your request within the time specified by the applicable data protection law.

· We usually provide these services for free, but reserve the right to charge a reasonable fee for your data access request.

· If you wish to request access to the personal data we hold or if you believe that any information we hold about you is incorrect or incomplete, please write to us as soon as possible or send an email to the email address provided below to contact us . Email: info@turtlefit.co.uk .

Withdraw consent

· You can revoke your consent to collect, use and/or disclose your personal information that we hold or control by submitting a request. This can be undone by sending an email to info@turtlefit.co.uk . We will process your request within a reasonable time after you make the request, and will no longer collect, use and/or disclose your personal information in accordance with your request.

· Please note that your withdrawal of consent will cause certain legal consequences. Depending on the scope of your withdrawal of consent to allow us to process your personal information, this may mean that you cannot enjoy Turtle Fit ‘s products and services.

Logout

· You can log out your account directly in Turtle Fit , the specific path is “Settings-Help-Logout Account”.

· Before you cancel your account, we will verify your account information. You know and understand that the act of canceling your account is irreversible. After you cancel your account, we will delete your personal information, unless otherwise provided by laws and regulations.

Transfer personal information outside of your jurisdiction

We will store the personal information collected and generated during operations in the mainland of the People’s Republic of China in a data center in the mainland of China.

If cross-border transmission is permitted under applicable laws, your data may still be transferred to other data centers based on the purpose described in the privacy policy and on the basis of ensuring that applicable laws are met, and we may also transfer your personal information To third-party service providers, your data may also be transferred to other countries or regions. The jurisdictions in which these global facilities are located may or may not provide data protection laws similar to those in your jurisdiction. You have understood that the risks under different data protection laws are different, and we may transfer and store your personal information to overseas facilities. However, this will not change all our commitments to comply with this privacy policy and protect your personal information. Currently, we have data centers in China and the United States.

Other regulations

Minor

· We believe that it is the responsibility of parents and guardians to supervise the use of our products and services by minors. If your child is a minor under the age of 14, before your child uses the products and services we provide, you, as a parent or guardian, must explicitly agree to Turtle Fit ‘s collection of your child’s personal information in accordance with this privacy policy.

· If parents or guardians have reason to believe that minors have submitted personal information to Turtle Fit without their prior consent , please contact us to ensure that such personal information is deleted and to ensure that minors unsubscribe from any applicable services.

Priority

If you agree to the applicable user agreement or other documents, and there are inconsistencies between such documents and this privacy policy, such documents shall prevail.

Update of privacy policy

We will review the privacy policy from time to time. In order to reflect the changes in our information practices, we may update this privacy policy. If we make a major change to this privacy policy, we will announce it through the Turtle Fit website or notify you via a mobile device so that you can understand the information we collect and how we use it. Such privacy policy changes will be applicable from the effective date specified in the notice or website. We recommend that you check this webpage regularly for the latest information on our privacy practices. Your continued use of products and services on the website, mobile phone and/or any other device will be deemed to have accepted the updated privacy policy. When we collect more personal information from you or we hope to use or disclose your personal information for new purposes, we will obtain your consent again.

Do I have to agree to any third-party terms and conditions?

Our privacy policy does not apply to products and services provided by third parties. Depends on the Turtle Fit products and services you use , which may include third-party products and services, involving voice support (including online voice and offline voice), analysis and statistics, social sharing, payment services, map services, push services, security services Some of them will be provided in the form of links to third-party websites, and some will be accessed in the form of SDK, API, etc. When you use these products or services, you may also collect your information. Therefore, we strongly recommend that you take the time to read the privacy policy of the third party, just like reading our policy. We are not responsible for how third parties use the personal information they collect from you and cannot control their use. Our privacy policy does not apply to other websites linked through our service.

The following SDKs are integrated in Turtle Fit . When you use these specific products, your information collected by the SDK, the purpose of use and the applicable third-party privacy policies are listed below:

· Use AutoNavi Maps to collect your device information, network status, location information; provide you with location records when you are outdoors, privacy policy: https://cache.amap.com/h5/h5/publish/238 /index.html

· Use WeChat to collect your network status and provide you with account login and information sharing services according to your specifications; privacy policy: http://weixin.qq.com/agreement

· Use QQ to collect your network status and provide you with information sharing services according to your specifications; privacy policy: http://www.qq.com/privacy.htm

· Use Weibo to collect your network status and provide you with account login and information sharing services according to your specifications; privacy policy: http://weibo.com/signup/v5/protocol

· Use Google Fit to collect your network status and provide you with information sharing services according to your designation; privacy policy: http://www.google.com/policies/privacy

· Use Apple Health to collect your network status and provide you with information sharing services according to your designation; Privacy Policy: https://www.apple.com/legal/privacy/szh/

· In order to provide you with one-click sharing service, our product integrates [Umeng +] U-Share SDK, which will collect your device identification information (such as IMEI/android ID/IDFA, etc.) and the public information of the social accounts you need to share in order to Complete one-click sharing service. For your information security, we have entered into data security and confidentiality agreements with third-party SDK service providers, and these companies will strictly abide by our data privacy and security requirements. Unless with your consent, we will not share your personally identifiable information with them. In order for you to better understand the types and uses of data collected by [Umeng +], and how to protect your personal information, you can log on to https://www.umeng.com/policy to understand the [Umeng +] privacy policy .

Social media (features) and gadgets

Our website contains some social media features, including Facebook Like buttons and widgets, such as the “Share” button or interactive mini programs running on this website. These functions may collect your IP address and the pages you browse on our website, and may set cookies to make the corresponding functions work properly. Social media features and gadgets are either hosted by a third party or directly on our website. Your interactions with these functions are subject to the privacy policy of the company they provide.

Sign in

Depending on your jurisdiction, you can use the login service provided by Facebook Connect or Open ID to log in to our website. These services will verify your identity and allow you to choose whether to share certain personal information with us (such as your name and email address) to pre-fill our registration form. Services such as Facebook Connect allow you to choose whether to publish information about your personal activities on this website on your profile page for sharing with others on the network.

Turtle Fit email: info@turtlefit.co.uk

Thank you for taking the time to understand our privacy policy!