Jackery Privacy Policy

Last Modified:2024/03/21

This Policy

This Privacy Policy describes how Jackery Inc., a Delaware corporation (“Jackery”, “we”, “us” and “our”) collects, stores and uses information from and about users of our mobile application (the “App”). By using our App, you agree to our collection, storage, use and disclosure of information as described in this Privacy Policy. If you disagree with anything in this Privacy Policy, please do not install or use the App. 

This Policy applies only to information we collect in this App, and in email, text, and other electronic communications sent through or in connection with this App. This Policy does not apply to information we collect offline or on any other Jackery apps or websites. In addition, this Policy does not apply to information you provide to or is collected by any third party. Our websites and apps, and these other third parties have their own privacy policies, which we encourage you to read before providing information on or through them.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the collection, storage, use and disclosure of personal information or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy. 

A. Children’s Privacy

B. How Do We Collect Your Information

C. What Information Do We Collect and the Purposes

D. How We Use Your Information

E. Disclosure of Your Information

F. International Transfer of Personal Information

G. Data Security

H. Data Accuracy

I. Data Minimisation

J. Retention of Information

K. Terms of Service

L. Direct marketing

M. Analytics

N. Your Legal Rights

O. Other Rights under General Data Protection Regulation

P. Other Consumer Rights under the California Consumer Privacy Act

Q. Other Consumer Rights under the Virginia Consumer Data Protection Act

R. California’s “Shine the Light” Law

S. Australian Privacy Act

T. Contact Us

(A) Children’s Privacy

Our App is not directed to children under the age of 13 or the equivalent age as specified by law in your jurisdiction. We do not request or knowingly collect personal information from children. If you are a children, you should not visit or use our App. If we learn we have collected or received Personal Information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child , please contact us at [hello@jackery.com]

(B) How Do We Collect Your Information

Sources of Personal Information: We collect or obtain Personal Information from and about you from the following sources:

· Information you provide to us: We collect Personal Information when you provide it to us (e.g., when you register an account with us; when you submit comments, feedback or other data using the App, or in relation to the App; where you contact us via email or telephone, or by any other means, or when you provide us with your business card).

· Automatically when you use the App: We collect or obtain Personal Information when you use any features or resources available on or through our App.

· Third party information: We collect or obtain Personal Information from third parties who provide it to us. For example, we collect and use Personal Information from Facebook, Google, and WeChat if you use your account to log in to this App.   

We may also create Personal Information about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Information from any of our sites, or services, including where those data are collected from different devices.

(C) What Information Do We Collect and the Purposes 

Information You Provide to Us

When you download, register with, or use this App, we may ask you to provide information. This information includes:

Registration Information: Information you provide when you register with the App, including name, email address, nickname, address, and account password. We use this information to verify your identity and create and administer your account to enable you to use the App.  

Relationship Information: If you contact us with feedback or other questions, we collect records and copies of your correspondence (including email addresses, phone numbers, photographs, and video) so that we can respond to your feedback and questions and provide troubleshooting.

Automatically Collected Information

When you download, access, and use the App, it may use technology to automatically collect:

· Usage Details: When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, communication data and the resources that you access and use on or through the App. We use those data to help us improve the quality of our App, and to manage and analyze data in order to better understand our users. 

· Device Information: We may collect information about your mobile device and internet connection, including the device’s model, unique device identifier, IP address, operating system, and mobile network or Wi-Fi information. We use those information to help us understand the activity on the App, to monitor and improve the App, to track and fix errors and problems and to tailor your in-App experience.

· Operational Information: We may collect operational information concerning the App, including user feedback, images, user analytics, including the number of registered users, active users, user retention, user distribution, the number of new users, the conversion of new users from adding devices to using devices; the time intervals between registration and adding devices to the app; and other App usage information the App.We use those information to analyze data in order to improve our Service.

· Parameters of Jackery Products: If you connect your Jackery product to the App, we may collect information about your Jackery product, including battery usage, WiFi strength, input and output power, timing setting, and lighting setting. We use those information to help you remotely monitor and control your devices, including battery charging and other settings, to allow you to share control of your device with others and to provide you with battery notifications.

· Location Information. If granted permission by you, this App collects real-time information about the location of your device to provide services, such as to connect your Jackery Products. 

Please refer to the table below for details regarding the information collected by us.

Sensitive Personal Information

Where it becomes necessary to collect or process your sensitive personal information for any reason, we rely on one of the following legal bases:

· Consent: We may collect or process your sensitive personal information, in accordance with applicable law, obtained your express consent prior to processing;

· Compliance with applicable law: We may collect or process your sensitive personal information where the collecting or processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);

· Establishment, exercise or defence of legal claims: We may collect or process your sensitive personal information where the collecting or processing is necessary for the establishment, exercise or defence of legal claims; or

· Detection and prevention of crime: We may collect or process your sensitive personal information where the collection or processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud).

(D) How We Use Your Information

We use information that we collect about you or that you provide to us for a variety of purposes, including to:

· Provide you with the App and its contents, and any other information, products or services that you request from us.

· Maintain or service customer accounts.

· Verify customer information.

· Fulfill any other purpose for which you provide it, as described to you at the time we collect your information or as you otherwise consent.

· Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

· Notify you when App updates are available, and of changes to any products or services we offer or provide though it.

· Analyze App performance, calculate usage level, help diagnose issues, and to administer the products.

· Perform internal research for technology development.

· Communicate with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested. 

· Manage operations of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

· Detect, investigate and prevent breaches of policy, and criminal offences, in accordance with applicable law.

· Comply with our legal and regulatory obligations under applicable law.

· Ensure the quality and safety of services or devices.

· Identify issues with our App, or our services; plan improvements to our App, or our services; and create new Apps or services.

· Debug information technology assets to address impairments to operational functionality and detect security incidents.

· Manage of legal claims; establish facts and legal claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defend  legal rights and claims, including formal legal proceedings.

We use location information we collect to provide better after-sales service.

(E) Disclosure of Your Information

We disclose Personal Information to other entities within the Jackery group and affiliates, for legitimate business purposes and the operation of our App, or to provide services to you, in accordance with applicable law. In addition, we disclose your information to:

· you and, where appropriate, your appointed representatives;

· legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

· accountants, auditors, consultants, lawyers and other outside professional advisors to Jackery, subject to binding contractual obligations of confidentiality;

· third party service providers, including cloud-based providers (such as email service providers; analytics service providers, vendors that host our data, marketing service providers; venue operators; postal carriers; etc.), located anywhere in the world;

· any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;

· any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

· any relevant third party acquirer(s) or successor(s) in title, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and

· any relevant third party provider, where our App uses third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party  to process your information, the third-party will be subject to binding contractual obligations to: (i) only process the information  in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the information; together with any additional requirements under applicable law.

We do not sell your any information to third parties.

(F) International Transfer of Personal Informatio

Because of the international nature of our business, we transfer Personal Information within the Jackery group, and to third parties as noted in the section above, in connection with the purposes set out in this Policy. For this reason, we transfer Personal Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located, including China.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the UK or the EEA to recipients located outside the UK or the EEA (as applicable) who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses or Binding Corporate Rules. You are entitled to request a copy of our Standard Contractual Clauses

(G) Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Information against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Information, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any personal information that you send to us are sent securely.

(H) Data Accuracy

We take every reasonable step to ensure that:

· your data that we collect or process are accurate and, where necessary, kept up to date; and

· any of your data that we collect or process that are inaccurateare erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your data.

(I) Data Minimisation

We take every reasonable step to ensure that your data that we collect or process are limited to the data reasonably necessary in connection with the purposes set out in this Policy.

(J) Retention of  Information

We take every reasonable step to ensure that your Personal Information is processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain each category of Personal Information collected are as follows:

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

· permanently delete or destroy the relevant Personal Data; or

· anonymize the relevant Personal Data.

(K) Terms of Service

All use of our App or services are subject to our Terms of Use and End User Agreement. We recommend that you review the Terms of regularly, in order to review any changes we might make from time to time.

(L) Direct marketing

We may use your information to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding our products or services that may be of interest to you. We may also use your information for the purposes of displaying content tailored to your use of our App or services. If you use the App or our services, we may send or display information to you regarding our products or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication we send. Alternatively.  You may unsubscribe from other types of direct marketing by contacting us at the contact information provided in the “Contact Us” section below.Please note that it may take up to 2 weeks to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of providing the App or services you have requested

(A) Analytics

When you use our App, we will typically place cookies onto your device, or read cookies already on your device, in accordance with applicable law. We use cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may collect Personal Information through cookies and similar technologies, in accordance with applicable laws.

Certain cookies may be stored on your device by third parties when you use our App. We have no control over these cookies or how the third parties use them. These cookies allow third parties to provide us with a service, for example, analytics about the effectiveness of our marketing activities and user behaviour.

Regular cookies may generally be disabled or removed by tools available as part of most commercial mobile devices, and in some instances blocked in the future by selecting certain settings. Mobile devices offer different functionalities and options, so you may need to set them separately.  If you decide not to accept cookies from our App, you may not be able to take advantage of all of the App features.

(M) Your Legal Rights

Subject to applicable law, you may have the following rights:

· the right not to provide your information to us (however, please note that we will be unable to provide you with the full benefit of our App, products or services, if you do not provide us with your information – e.g., we might not be able to process your requests without the necessary details);

· the right to request access to, or copies of your information, together with information regarding the nature, processing and disclosure of those relevant information;

· the right to request rectification of any inaccuracies in your information;

· the right to request, on legitimate grounds:erasure or restriction of processing of your relevant information;

· the right to have certain relevant information transferred to another party, in a structured, commonly used and machine-readable format, to the extent applicable;

· where we process on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the processing of your information in reliance upon any other available legal bases); and

· the right to lodge complaints regarding the processing of your relevant information with a Data Protection Authority .

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in this Privacy. Please note that:

· in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and

· where your request requires the establishment of additional facts (e.g., a determination of whether any processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

(B)  Other Rights under General Data Protection Regulation（GDPR）

We will deliver a response to you within 30 days of receiving your verifiable  request

(A) Other Consumer Rights under the California Consumer Privacy Act

If you are a Consumer, the CCPA grants you the following rights regarding your information. Generally, in order to verify your requests to exercise your rights, we will compare the information we have about you to pieces of information we will request in the course of processing your request. The information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable consumer request. To exercise your rights under the CCPA, please follow the instructions described in this section.

Right to Know About Personal Information. Consumers have the right to submit a verifiable consumer request that we disclose the following in a readily useable format, covering the 12 month period preceding the verifiable consumer request:

· The categories of Personal Information we collected about you.

· The categories of sources for the Personal Information we collected about you.

· The categories of third parties to whom we disclose Personal Information.

· Our business or commercial purpose for collecting, selling, or sharing Personal Information.

· The specific pieces of Personal Information we collected about you. 

· The categories of Personal Information that we shared, and for each category identified, the categories of third parties to whom we shared that particular category of Personal Information.

· The categories of Personal Information we have disclosed for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of Personal Information.

Verifiable consumer requests to know may be submitted through email at:[ hello@jackery.com].

Right to Non-Discrimination. Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:

Deny you goods or services.

Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.

Provide you a different level of quality of goods or services.

Suggest that you may receive a different rate for goods or services or a difference level or quality of goods or services.

Retaliate against an employee, applicant for employment or independent contractor for exercising their rights.

Authorized Agent. Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

(A)  Other Consumer Rights under the Virginia Consumer Data Protection Act

Under the Virginia Consumer Data Protection Act (“VCDPA”), Virginia Consumers are also afforded additional rights with regard to the information we collect about them. This section of our Privacy Policy describes the  other rights afforded to Virginia Consumers. We also describe the methods by which a Consumer may exercise these rights.

Consumer Requests: Under the VCPDA, we  will deliver a response to you within 45 days of receiving your verifiable consumer request.

Process to Appeal Declined Requests: If we decline to take action on your request, we will notify you within 45 days of receipt of your request. In the event we decline to take action on your request, you may submit an appeal within 30 days of receiving such notice. You may submit an appeal through email at: [hello@jackery.com]. Within 30 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, we will provide you with an online mechanism, if available, or other method through which you may contact the Virginia Attorney General to submit a complaint.

(B) California’s “Shine the Light” Law

Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of Personal Information Jackery shares with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this notice, please submit a written request to [hello@jackery.com].

(N) Australian Privacy Act

Access and correction

We may decline a request for access to or correction of information in circumstances prescribed by the Privacy Act 1988 (Cth), and if we do, we will give you a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons), including details of the mechanisms available to you to make a complaint.

Questions or Complaints

If after this process you are not satisfied with our response, you can submit a complaint to the Office of the Information Commissioner.  To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.

(O) Contact Us

If you have questions or concerns with respect to our Privacy Policy, you may contact us at：

[Information Security Engineer]

 [hello@jackery.com].