Privacy Policy
Release Date: September 14, 2026
[ SVEA(HK) LIMITED ] (the “Company”, “we” or the “service provider”) attaches great importance to your personal data and respects your right to privacy. In the course of providing [MooConnect and the SVEA Unified Management Platform] (the “Application”) to you, we will collect and process your personal data strictly in accordance with applicable laws and regulations, and only within the scope declared in this Privacy Policy (this “Policy”). Before you submit any personal data to us, please read and understand this Policy carefully. Please note that this Policy applies only to the Application; if you use other products or services that we provide, please refer to the privacy policy applicable to that product or service.
Please note that, under applicable local data protection laws, certain privacy rights and obligations may vary by location. We have included in this Policy supplemental information for certain jurisdictions.
This Policy will help you understand the following:
· Who we are
· What personal data we collect from you
· How we use your personal data
· How we use cookies and similar technologies
· How we manage your personal data
· How we share your personal data
· How your personal data is stored locally and accessed across borders
· What rights you have
· How we protect children’s personal data
· How this Policy is updated
· How to contact us
· Supplemental Provisions for Specific Jurisdictions
The Application and the related services are provided by [SVEA(HK) LIMITED] and its applicable affiliates. Depending on your country or region and the specific product or service you use, the entity responsible for processing your personal data may differ.
For those processing activities described in this Policy in respect of which we determine, on our own, the purposes and means of the processing of personal data, we act as the data controller, personal information handler or responsible entity of an equivalent nature under the applicable data protection laws. The specific responsible entities and their contact information are set out in the “How to Contact Us” section of this Policy and in the applicable regional supplemental provisions.
Where we process personal data solely on behalf of, and in accordance with the instructions of, an enterprise customer, partner or other third party, that enterprise customer, partner or third party may be the controller of the relevant personal data, and we will process the relevant data in accordance with our arrangements with it and with applicable law.
When you use the Application and/or the services, you may from time to time be asked to provide personal information to us. The information we request and the reasons for the request will be explained to you at the time the request is made. In order to support the basic functions of the Application, the provision of certain personal information is necessary; if you refuse to provide it, you may be unable to use the corresponding functions. Other personal information collected for the purpose of improving your user experience is provided at your discretion; your refusal does not affect your use of the basic functions, nor will we refuse to provide our services to you on that ground. The following are examples of circumstances in which we directly ask you to provide information to us:
Account and contact information: for example, account ID, account name, password and other authentication credentials, e-mail address, mobile phone number, name, enterprise or distributor name, farm or site name, country or region, service region, and account roles and permissions.
Device and product information: for example, the model and serial number (SN) of livestock equipment, sensors or accessories, device identifiers, software, firmware and hardware versions, connectivity and online status, device configuration, the binding relationships between enterprises, farms, accounts and devices, and the maps, paths, tasks, parameters and device usage information that you actively configure or submit during installation, deployment, demonstration, operations or after-sales maintenance.
In connection with the livestock business, precise location information relating to farms or devices may be involved, as well as on-site photos, videos, audio, logs or other materials that you actively provide during installation and deployment, remote diagnostics or after-sales support; such materials may carry the location, image or voice of personnel, or may incidentally record employees, contractors, visitors, minors and other persons. We do not collect biometric information, health information, financial information or children’s personal data for livestock business purposes. Where the foregoing materials constitute sensitive personal data, special-category personal data or otherwise specially protected data in a specific scenario, we will process them only to the extent necessary to implement the relevant product functions, to safeguard the safety of devices and the site, to troubleshoot faults or to provide after-sales services, and will obtain express consent, separate consent, complete the necessary notifications or take other necessary measures as required by applicable law. Please refrain from submitting such information where it is unrelated to the relevant products or services.
Customer support and after-sales information: information that you provide to us through the application, the UOP device management platform, Feishu, WhatsApp, other instant messaging software, e-mail, telephone, work orders, or distributors, such as contact and farm information, device SNs, problem descriptions, fault or alert times, task and operation status, maps, paths, parameters, screenshots, logs, on-site photos, videos, audio, remote diagnosis or recovery requests, communication records and handling results. We use such information only to the extent necessary to provide installation and deployment, demonstrations, training, fault diagnosis, remote diagnostics, standard recovery, controlled manual recovery, repairs, warranty, safety interventions and other after-sales services.
Any information you provide in connection with the customer support services by which you contact us.
As you use the Application and/or the services, we may also automatically collect various items of information from you. Some of this information is collected on an anonymous basis, while other information is linked after collection to other information that you have already provided. Where such information is linked to your account information, or where the collected information can be used to trace a specific person, we consider such information to be personal data. The following is information automatically collected while you use the Application and/or the services:
· Location and operational data: where the relevant functions so require, this may include the precise locations of farms, barns, feed passages, charging points and devices, GNSS/GPS and base-station information, coordinate systems and positioning quality, maps, operating areas, task paths and waypoints, task plans and execution status, travel or operation tracks, speeds, stop points, abnormal pause locations, and geospatial data related to remote diagnostics and operational recovery.
· Image, video and sensor data: when you use livestock equipment and related services equipped with stereo or other cameras, lidar, scanners, ultrasonic sensors, inertial measurement units or other sensors, on-site photos, videos or video logs, point clouds, scan data, obstacle information, distance and attitude data and other data may be generated. Such photos or videos may incidentally record on-site employees, contractors, visitors, vehicles, animals and the surrounding environment. Whether we receive or store such data depends on the specific product and functions you use and on the relevant settings.
· Network and technical information: for example, the IP addresses of user terminals and livestock equipment, device or terminal types, operating systems, versions of the application and the UOP platform, device software and firmware versions, time zone and language settings, network identifiers, Wi-Fi or mobile network connection status, carriers and signal quality, online or offline status, connection times, network latency, as well as logs of logins, crashes, upgrades, diagnostics, remote access, remote operations and security audits.
· Transaction and service data: including inquiries or quotations, orders, payment and invoicing status, products and services purchased or leased, customer or distributor information, contract and warranty status, delivery, installation and deployment, demonstrations, training, after-sales work orders, spare parts and repairs, remote diagnostics and recovery operations, and the communication records and handling results among customers, distributors or Application Engineers (AEs).
· Information generated by cookies, SDKs and similar technologies: when you use the application or web-based platforms such as UOP, cookies, local storage, SDKs, session tokens and similar technologies may generate or record online identifiers, terminal and application information, login and session status, device binding status, language and function preferences, pages visited, operation buttons, access times, errors, crashes, performance and security events. We will, based on the actual integrations, describe the relevant third parties, processing purposes and information types in a cookie or SDK inventory, in the product interface or in other appropriate locations, and will provide the means of consent, refusal or disabling as required by law; unless there is another lawful basis and the necessary notifications or consents have been completed, we will not use precise operational data of livestock equipment, on-site images, videos or remote operation records for advertising or cross-context profiling.
Some device data may be stored only on your device, on a local terminal or in a storage environment that you control; we receive such data only where you actively upload it, enable the relevant synchronization function, or where this is necessary for the provision of the relevant services.
Certain products may generate operational, mission, positioning, log, image, video or other technical data on the device side. Depending on the specific product and functions, some of this information may be stored only on the device, on a local terminal or in an environment that you control.
For data that we can obtain only after you actively upload it, synchronize it, authorize access to it or enable the relevant functions, we will provide you with the corresponding settings or options in accordance with the specific functions of the relevant product.
The actual scope of data to which we have access depends on the products you use, the functions, your account settings and the choices you have made.
This section provides further details on the types of personal information we collect from you and the reasons for such collection. For users located in the United Kingdom or the European Economic Area (the “Relevant Jurisdictions”), this section also identifies the legal bases on which we rely in processing your data.
Information you provide to us (directly or through third parties)
|
Data Category |
Purpose of Use |
Typical Data |
Primary Processing Basis |
|
Account, enterprise and farm contact data |
Registration, login, identity verification, member and permission management, device binding and customer service |
Account ID, name, e-mail, mobile number, enterprise or distributor, farm, country or region, roles and permissions |
Performance of contract / provision of services |
Personal information automatically collected or generated as part of the provision of the services
|
Data Category |
Purpose of Use |
Typical Data |
Primary Processing Basis |
|
Device, location and operational data |
Device binding and activation, task configuration and execution, map and path management, remote diagnostics and recovery |
SN, model, software, hardware and firmware versions, enterprise or farm binding, GNSS/GPS, base stations, maps, paths, tasks, tracks and positioning quality |
Performance of contract / provision of services |
|
Operational, alert, image and sensor data |
Status monitoring, fault diagnosis, obstacle detection, remote after-sales service and safety interventions |
Device status, alerts, operation and action logs, stereo/radar/scan data, on-site photos, videos or video logs, point clouds, etc. |
Performance of contract / provision of services / legitimate interests (fault diagnosis) |
|
Network, access and security data |
Maintaining device connectivity, account and device security, remote access control, incident response |
IP, network identifiers, online or offline status, signal quality, and logins, upgrades, diagnostics, remote access, remote operations and security audits |
Performance of contract / provision of services / legitimate interests / legal obligations |
We may use cookies and other similar technologies (such as web beacons, log files, scripts and eTags) (“Cookies”) to enhance your service experience. Cookies are small files which, once placed on your device, enable us to provide certain features and functions.
(1) Cookies
We may in the future establish websites through which to provide the Application and/or the services to you. In order to ensure the proper operation of such websites, to provide you with easier access, and to recommend content that may be of interest to you, we will store on your computer or mobile device cookies, Flash cookies, or other local storage provided by the browser or associated applications, typically containing identifiers, site names and certain numbers and characters (collectively, “Cookies”). By means of cookies, websites are able to store your preferences or the items and/or services in your shopping cart and other such data.
Where your mobile device or browser add-on services so permit, you may adjust the level of cookie acceptance or refuse our cookies. However, if you do so, it may in certain circumstances affect your secure use of our products and/or services, and you may need to change your user settings each time you use the Application and/or the services.
(2) Cookie-like Technologies
In addition to cookies, we also use web beacons, pixel tags, ETags and other similar technologies on our websites. For example, e-mails that we send to you may contain links to content on our websites; if you click such a link, we will track that click to help us understand your product or service preferences, so that we may proactively improve the customer service experience. A web beacon is typically a transparent image embedded in a website or an e-mail. By means of pixel tags in e-mails, we are able to learn whether an e-mail has been opened. If you do not wish your activities to be tracked in this manner, you may unsubscribe from our mailing list at any time.
ETags (entity tags) are HTTP protocol headers transmitted behind the scenes between Internet browsers and Internet servers, and may serve as a substitute for cookies. ETags can help us avoid unnecessary server load, improve service efficiency, and save resources and energy; at the same time, we may use ETags to record your identity so that we can better understand and improve our products or services. Most browsers provide users with the ability to clear browser cache data, and you may carry out the corresponding data clearing operations in the browser settings. Please note, however, that if ETags are disabled, you may not be able to enjoy a relatively better product and/or service experience.
Depending on the products and services you use and on your country or region, your personal data may be stored or processed in different countries or regions. We will determine the data storage location in accordance with applicable law and, where cross-border transfers are involved, will take the appropriate measures described in the “How Your Personal Data Is Stored Locally and Accessed Across Borders” section of this Policy.
We retain your personal data only for the period necessary to achieve the processing purposes described in this Policy, except where otherwise required or permitted by laws and regulations.
In determining the specific retention period, we will comprehensively consider: (i) the period required to provide the relevant product or service; (ii) the duration of our business relationship with you; (iii) the form, volume and degree of sensitivity of the data; (iv) the needs of security, fraud prevention and dispute resolution; and (v) applicable legal, tax, accounting, regulatory and limitation-of-actions requirements.
Where the law requires specific categories of data to be retained for specific periods, we will act in accordance with applicable law.
Once we no longer have a legitimate business need to process your personal data and your personal information is beyond its retention period, we will delete or anonymize your personal data or, if deletion or anonymization is not possible, pseudonymize and/or securely store your personal data and isolate it from any further processing until such time as it can be deleted or anonymized.
We will strive to protect your personal data from unauthorized access, use, disclosure, modification, destruction, damage, loss or other forms of unlawful processing by strengthening administrative and technical security measures such as access controls, encryption and employee training. No network environment is absolutely secure. In the event of a personal data security incident, we will fulfill our notification obligations, which may include informing you of: the basic circumstances of the security incident and its potential impact, the disposal measures we have taken or will take, and suggestions for you to independently prevent and mitigate risks. We will endeavor to notify you promptly by telephone, e-mail, push notification or other means, and in certain circumstances we may publish an announcement on the Company’s official website. At the same time, we will proactively report the handling of personal information security incidents to the regulators as required.
If you know, or have reason to believe, that your personal data has been lost, misappropriated or otherwise compromised, or if any actual or suspected misappropriation of your personal data occurs, you may contact us promptly.
We may, within the scope necessary for the provision of global services, account management, technical support, information security, internal management and the other purposes described in this Policy, share personal data among the applicable entities within our group. Where we consider it necessary to share your personal information with third parties, we will set out, in a consolidated inventory, the names and contact details of the recipients, the types of personal information shared, the purposes of sharing, the processing methods and the security measures adopted; you may consult the personal information sharing inventory within the Application. Such circumstances include:
(1) Third parties supporting the provision of services, including payment/logistics processing partners and cloud service providers that process the information specified in this Policy on their servers for the purpose of providing the services and for support-related communications. We will require such service providers, through contracts, data processing agreements and other appropriate measures, to process personal data in accordance with our instructions, the agreed purposes and applicable law.
(2) Companies within our corporate group that process your personal information in order to operate the services around the world. All relevant group companies may use your personal information only in accordance with this Privacy Policy.
(3) Where required to ensure safety or security or to comply with law, we may share your personal information with regulators, judicial authorities and law enforcement agencies, as well as with other third parties upon their request. For example:
In certain circumstances, the law requires us to disclose information about you to the competent authorities, for example in order to comply with legal obligations or proceedings, to enforce our terms, to address issues relating to security or fraud, or to protect our users. Pursuant to the terms of valid legal process such as subpoenas, court orders or search warrants, such disclosures of information may be made with or without your consent, and with or without notice to you. The terms of such legal process typically prohibit us from notifying you of any such disclosure. Where a government authority does not provide the required subpoena, court order or search warrant, we may seek your consent in order to respond to that government authority’s request for the disclosure of information. We may also disclose your information for the following purposes:
· enforcing our terms and conditions and other agreements, including investigating any potential violation of such terms and conditions or other agreements;
· detecting, preventing or otherwise addressing security, fraud or technical issues; or
· as required or permitted by law, protecting the rights, property or safety of ourselves, our users, third parties or the public (including exchanging information with other companies and organizations for the purposes of fraud prevention and credit risk mitigation).
(4) Third parties acquiring all or a substantial part of our business. We may disclose your information to third parties under the following circumstances: (a) we sell, transfer, merge, consolidate or reorganize any part of our business, or merge with, acquire or form a joint venture with any other business, in which case we may disclose your data to any potential buyer, new owner or other third party involved in the change to our business; or (b) we sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and transferred to any potential buyer, new owner or other third party involved in such sale or transfer.
(5) Third-party SDK providers. In order to enable you to properly use the various functions and services of the Application, we embed in the Application the SDKs or other similar applications of the following authorized partners:
|
Name |
Third Party |
Data Type |
Purpose of Use |
Processing Method |
Third-Party Privacy Policy |
|
Tencent Bugly |
Shenzhen Tencent Computer Systems Co., Ltd. |
Application crash information |
Collecting application crash information to resolve faults |
Encrypted |
https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56 |
|
Tencent Push Notification Service (TPNS) |
Shenzhen Tencent Computer Systems Co., Ltd. |
Device information |
Push notifications |
Encrypted |
https://privacy.qq.com/document/preview/8565a4a2d26e480187ed86b0cc81d727 |
|
FCM |
Google LLC |
System messages |
Push notifications |
Encrypted |
https://firebase.google.com/support/privacy |
|
Apple APNs Push |
Apple Inc. |
System messages |
Push notifications |
Encrypted |
https://www.apple.com/legal/privacy/en-ww/ |
|
Tencent COS |
Shenzhen Tencent Computer Systems Co., Ltd. |
Application runtime logs |
Crash analysis and issue resolution |
Encrypted |
https://privacy.qq.com/document/preview/a76038ae5ee242d18d3a45a34cdd744c |
We conduct strict security testing on the application programming interfaces (APIs) and software development kits (SDKs) through which authorized partners obtain personal information, and agree on strict data protection measures with authorized partners, to ensure that they collect and process your personal data in accordance with our arrangements and the provisions of this Privacy Policy.
For the cross-border transfer arrangements applicable to specific countries or regions, please refer to the “Supplemental Provisions for Specific Jurisdictions” of this Policy.
In principle, we store your personal data on local servers or in data centers located in your country or region.
In order to provide you with technical support, after-sales services, system maintenance, security assurance or other necessary services, our affiliates, technical support teams or service providers located in other countries or regions may access the relevant data remotely to the extent necessary.
In certain jurisdictions, such cross-border remote access may be regarded as a cross-border transfer or international data processing. We will take the necessary contractual, technical and organizational measures in accordance with applicable law, and will complete the corresponding notification, consent, filing, certification, assessment or other compliance procedures where required by law.
Unless otherwise required by law or separately authorized by you, the relevant overseas access parties shall not, as a result thereof, separately store your personal data in their own country or region.
The laws of certain jurisdictions grant specific rights to users of services; this section sets them out.
This section applies to users located in the Relevant Jurisdictions. If you are located outside the Relevant Jurisdictions, please refer to the supplemental jurisdiction-specific provisions to understand your rights and how to exercise them.
The sections entitled “Right of Access”, “Right to Rectification” and “Right to Erasure” also apply to users located in Canada.
You have the right to access the personal information we hold about you, to know how we use it, and to know with whom we share it.
You have the right to receive a copy of certain personal information that we process about you. This includes any personal information that we process on the basis of your consent or under our contract with you (such as customer support), as detailed in the “How We Use Your Personal Information” section above. You have the right to receive such information in a structured, commonly used and machine-readable format. Subject to certain exceptions, you also have the right to request that we transmit such personal information to another party. If you make such a request, we will provide you with the relevant further information.
If you wish us to transmit such personal information to a third party, please ensure that you provide details about that party in your request. Please note that we can transmit to a third party only where this is technically feasible. Please also note that we may be unable to provide such personal information to you where providing it would harm the rights of others (for example, where providing the personal information we hold about you would disclose the information of others or our trade secrets or intellectual property).
You may update your account information at any time by logging into the Application. If you consider that the personal information we hold about you is inaccurate or incomplete and needs to be corrected, please notify us through the “How to Contact Us” section below.
You may delete your account and have the right to request that we delete the personal data we store about you. You may also request the deletion of your account and/or your personal data by contacting us. We will process your request within the period prescribed by applicable law. Please note that, once deleted, an account cannot be restored. In order to meet legal requirements or for security purposes, we may retain certain information. Certain information will also be retained in anonymized form.
If the relevant data protection law provides for legitimate grounds for retention, we may be required to retain personal information (for example, in order to defend against legal claims or to protect freedom of expression), in which case we will notify you. If you request that we delete personal information that has been made public on the service, and there are grounds for deletion, we will take reasonable steps to attempt to inform other parties who are displaying such personal information or providing links to it, so that they likewise delete it.
In certain circumstances, you have the right to request that we cease processing the personal information we hold about you and merely store it. Please note, however, that if we cease processing personal information, we may use it again where we have a valid ground for such processing under the relevant data protection law (for example, in order to defend against legal claims or to protect others). As noted above, if we agree to cease processing the relevant personal information, we will attempt to inform any third parties to whom we have disclosed it, requesting that they likewise cease processing.
Certain of our processing may rely on your consent. You may withdraw your consent at any time, without affecting the lawfulness of the data processing activities carried out prior to withdrawal, and without affecting any other existing legal basis for such processing activities.
Where consent is required in order to process your personal information and you do not consent, or you withdraw your consent, we may be unable to provide the intended services.
Where the relevant processing is based on our legitimate interests (rather than on a legal obligation), you have the right, on grounds relating to your particular situation, to object at any time to our processing of your personal data. If you object, we will no longer process your personal data unless there are compelling grounds that override your interests, rights and freedoms, or unless the data is necessary for the establishment, exercise or defense of legal claims. If you do not wish us to process your personal data for marketing activities, you may at any time send an e-mail to [infosec@fjdynamics.com] to request a change.
If you wish to complain about the manner in which we process your personal information, please contact us in the first instance, and we will endeavor to handle your request as promptly as possible. If you consider that we have violated the relevant data protection law, you may lodge a complaint with the data protection authority of the country or region in which you reside or work.
You also have the right to take legal action in respect of any infringement of your rights in the course of processing your personal data.
Where we consider it necessary (for example, where we temporarily suspend access to the services for maintenance, security or privacy reasons), we may from time to time send you announcements or other administrative notices. You may not opt out of receiving such service-related announcements, as they are not promotional in nature.
Where we use automated decision-making to push information to you, to conduct commercial marketing, or to make decisions that have a significant impact on your personal rights and interests, we will ensure the transparency of such decisions and the fairness and impartiality of their outcomes, and will provide you with options or means of refusal that are not based on personal characteristics; you have the right to request that we explain the relevant processing rules, and the right to refuse decisions made by means of automated decision-making alone. You may click here and follow the “opt-out” instructions provided in the “Settings” section of the service to stop receiving our personalized advertisements or promotional messages while using the service, or you may contact us through the means provided in the “How to Contact Us” section below.
You may exercise your rights through the means set out in the “How to Contact Us” section below. We will process your request within the period prescribed by applicable law. Where a request affects the rights and privacy of others, we reserve the right to decline to act upon it. Where your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee or to decline to act upon it.
Please note that we may require you to provide information in order to verify your identity and to determine that you are entitled to such rights.
Our products and services are primarily directed at adults and business users and are not directed at children. We will not knowingly collect children’s personal data in violation of applicable law. Where the relevant products or services necessarily involve the processing of children’s personal data, we will obtain valid authorization from a parent or guardian, or take other necessary protective measures, in accordance with the applicable law of the child’s country or region. If we discover that children’s personal data has been collected without appropriate authorization, we will take deletion or other necessary measures in accordance with law.
We may update this Privacy Policy from time to time. Where this Privacy Policy is revised, we will promptly post the new version in a prominent position on this webpage. Where a material change is made to this Policy, we will notify you through more prominent means, such as e-mail, SMS or website pop-ups.
If you have any comments, suggestions or questions regarding this Policy, or any requests or inquiries regarding your personal data, you may contact us through the following means. In principle, we will respond within 30 days.
Contact person: Data Protection Officer
E-mail: infosec@fjdynamics.com
Address:
Postal code:
Note: This Privacy Policy was updated on [September 11], [2026], and will take effect on [September 12], [2026].
The laws of certain jurisdictions provide for additional provisions applicable to users of services; this section sets out those provisions.
If you are a user located in one of the jurisdictions listed below, then, in addition to the provisions of our Privacy Policy set out above, the provisions set out under the name of your jurisdiction also apply to you; in the event of any conflict, the supplemental provisions under the name of your jurisdiction shall prevail.
This section applies to users in the United Kingdom. Under the Data (Use and Access) Act 2025 (DUAA), our processing of UK users’ personal data is subject to the UK GDPR and the following arrangements under the DUAA: for automated decisions that have a significant effect on you, we will provide for meaningful human intervention, notification, and the right to object; except for strictly necessary and low-risk cookies (such as statistical analysis, storage of user preferences, and security and anti-fraud purposes), we will obtain your consent prior to use; certain processing may rely on recognized legitimate interests; and for data subject access requests, we will respond with the information within a reasonable and proportionate scope.
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (the “CCPA”).
In the past 12 months, we have collected and disclosed the following categories of personal information from you or your devices, or about you or your devices:
· Identifiers, such as your account ID, password, IP address, device ID, e-mail address and mobile phone number;
· Internet or other electronic network activity information, such as information about your use of the Application and/or the services, including logging into the Application and other device information described in the body of this Privacy Policy. This information is collected directly from you and your devices;
· Commercial information regarding any transaction within the Application and/or the services, such as the services purchased and their prices. This information is collected directly from you and your devices;
· Other information as described in Section 1798.80(e). This information is collected directly from you (as our consumer).
We collect your personal information for the following purposes:
· providing you with services and maintaining your account;
· improving our services, including the features of the services;
· security and verification purposes, including preventing and detecting fraudulent activity;
· resolving and correcting technical issues and vulnerabilities.
For additional information regarding the purposes of each type of personal information, please refer to the “What Personal Data We Collect From You” and “How We Use Your Personal Data” sections of the body of this Privacy Policy.
We disclose personal information to the following categories of entities:
· other companies within our corporate group that process your personal information in order to operate the services;
· other companies that provide services on our behalf and that support the provision of services, whose contracts prohibit them from retaining, using or disclosing personal information for any purpose other than providing services to us;
· regulators, judicial authorities and law enforcement agencies;
· entities that acquire all or a substantial part of our business.
In the past 12 months, we have not sold the personal information of California residents for monetary or other valuable consideration, nor have we shared it for the purposes of cross-context behavioral advertising.
If you are a California resident, you have the right to:
· request that we disclose to you, free of charge, the following information collected in the preceding 12 months as you request:
· the categories of personal information we have collected about you;
· the categories of sources from which the personal information was collected;
· the purposes for collecting your personal information;
· the categories of third parties to whom we disclosed your personal information, the categories of personal information disclosed (if applicable), and the purposes for which your personal information was disclosed; and
· the specific pieces of personal information we have collected about you;
· request that we delete the personal information we collected from you, except where an exception under the CCPA applies; and
· request that we correct personal information; opt out of the sale or sharing (for cross-context behavioral advertising) of personal information; restrict our use and disclosure of sensitive personal information (such as precise geolocation, government identification numbers, financial accounts, race or religious beliefs, biometric information, health information, etc.); and receive or transfer personal information in a portable format where technically feasible; and
· not be discriminated against unlawfully for exercising your rights under the CCPA, including by being provided a different level or quality of service, or by being refused goods or services.
Our objective is to respond to all verified requests within 45 days as required by the CCPA. Where necessary, the response period will be extended by a further 45 days, and an explanation for the extension will be provided.
First, you may log into your account and manage your data. If you are a California resident covered by the CCPA, you may also contact us through our website, or send an e-mail to [infosec@fjdynamics.com], to exercise your rights over other data (if any).
Under Nevada law, for monetary consideration, Nevada residents who purchase our goods or services may direct that we not sell “covered information” (as defined under Nevada law) to others for them to license or sell to other persons. “Covered information” includes your name, address, e-mail address and telephone number, or other identifiers that permit the individual to be contacted online or offline. As noted above, we share your information with certain third parties whom we believe may use the other means described above to offer you deals and promotions on products and services that may be of interest to you. We do not consider our information sharing in this respect to constitute a sale under Nevada law. However, if you are a Nevada resident who has purchased our goods or services, you may submit a request by sending an e-mail to [infosec@fjdynamics.com] to have your opt-out preference recorded. Please note that we may take reasonable measures to verify your identity and the authenticity of your request.
We will not collect or use your personal information without your consent, and you may withdraw your consent at any time. Please note that, after you withdraw your consent, we will no longer collect or use your personal information; the personal information processed on the basis of your prior consent remains validly processed.
If you are under the age of 14, please do not use the services for any purpose before obtaining the consent of your parent or guardian to this Privacy Policy (on their own behalf and on your behalf). We will not knowingly collect the personal information of children under the age of 14 without such consent.
We protect your rights as a personal information subject under Chinese privacy law, including the rights to access and copy, correct and delete your personal information; to request, where statutory conditions are met, the transfer of your personal information to a processor designated by you; to request that we explain our personal information processing rules; to withdraw your consent; to request the cancellation of your account; to refuse decisions made solely by means of automated decision-making; and to lodge complaints or reports with the department performing personal information protection duties regarding our personal information processing activities, among other rights. For further information, please refer to the “How to Exercise Your Rights” subsection above.
As a data subject in Hong Kong (China), you have statutory rights in respect of the personal data we hold about you (to the extent permitted by the applicable laws and regulations).
You have the right to make a data access request (to receive a copy of the data we process about you) and a data correction request, and the right to object to the use of your personal data for direct marketing purposes. We may charge a fee for processing a data access request.
The operator that processes your personal information may share the following personal information of yours:
The personal information described in the “What Personal Data We Collect From You” section above.
Companies within the corporate group of the operator (including new companies that join our group after this Privacy Policy is established)
The purposes of use set out in the “How We Use Your Personal Data” section above.
If you are located in Canada and wish to obtain written information regarding our policies and practices in respect of service providers located outside Canada, you may contact us through our website, or send an e-mail to [infosec@fjdynamics.com].
Where the service providers we use may have access to your personal information, we will require them to implement privacy and security standards comparable to our own. Through contracts with our service providers and other measures, we maintain the confidentiality and security of your personal information and prevent it from being used for any purpose other than that set out in this Privacy Policy.
If you use the Application and/or the services in Russia, your use of the Application and/or the services signifies that you agree:
· you confirm that you are at least 18 years of age;
· that, for the purposes of Federal Law of the Russian Federation No. 152-FZ “On Personal Data” of July 27, 2006 (as amended) or any superseding legislation, your information is processed in accordance with this Privacy Policy; where legitimate interests, the optimization of the services or the performance of a contract are involved, you agree that, for the purposes of Russian law, such consent may be deemed a basis for processing (i.e., processing is carried out with your consent); such consent also covers the processing of any Cookies (to the extent such Cookies constitute personal data under Russian law);
· to the cross-border transfer of your information to any country or region in which we maintain databases or branches;
· we will complete the collection and storage of Russian users’ personal information in databases located in Russia; prior to any transfer abroad, we will complete the notification procedure with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) as required by law, and will comply with its regulations on cross-border transfers;
· that, for the purposes of federal law on marketing/advertising, we may share advertising/marketing information with you unless you choose not to receive such information.
The subsections “Right of Access”, “Right to Rectification”, “Right to Erasure”, “Right to Restrict Processing to Storage Only”, “Right to Object” and “Advertising” in the “What Rights You Have” section above also apply to users in the Russian Federation.
We will notify you of any material changes and may request that you accept them. Unless we request your acceptance, if you continue to use the services after notification, we will obtain your separate consent anew to the changes.
You may contact us by sending an e-mail to [ ]. Please include the word “Russia” in the subject line of your e-mail.
In addition to the personal data collected under this Policy, we also process data relating to South African legal persons, which includes data that may constitute personal information under the South African Protection of Personal Information Act. The personal data we process in respect of South African legal persons includes:
Examples: the name, address, telephone number, e-mail address, company registration number and contact person’s name of a company or other legal person.
The purposes of processing the above personal information include:
· identifying customers and potential customers;
· marketing or selling products to customers;
· negotiating and concluding contracts with customers;
Generally, our purposes for processing the above personal information are: performance of contracts with customers, or the consent of the relevant customers or legal persons, or our legitimate interests or the interests of third parties to whom such information is provided for the following purposes; namely, marketing and selling our products and services, supporting customers’ access to and use of our products, providing training to users of our products, responding to inquiries from customers or users, improving products and services, and recommending product features, new versions or maintenance to users.
Personal information of legal persons may be shared with third parties and transferred to countries or regions outside South Africa. Please refer to the relevant provisions of this Policy in this regard.
Legislation that may require the processing of the personal information of individuals or legal persons includes:
the Financial Intelligence Centre Act, 2001; the Income Tax Act, 1962; and the Companies Act, 2008.
Where applicable, information relating to an individual’s religious or philosophical beliefs, racial or ethnic origin, trade union membership, political beliefs, health or sex life, biometric information or criminal conduct, including any photographic or video records, may be treated as sensitive/special personal information under the applicable South African laws and regulations.
Before processing the personal data of children under the age of eighteen, we will obtain the consent of their guardian; children’s personal data is treated as special personal information subject to stricter protection. We will use special personal information for the purposes described in this Privacy Policy or for other purposes notified to you from time to time.
If you have any questions or concerns, you may contact us using the contact details below or the information provided in the “How to Contact Us” section of this Policy. We will respond to your request within a reasonable period, not exceeding 30 days. We may require verification of your identity.
Contact details:
You may not use the services unless you are at least 18 years of age, or have obtained the consent of a parent/guardian to this Privacy Policy (on their own behalf and on your behalf).
For the avoidance of doubt, in Section 2 “What Personal Data We Collect From You” and Section 3 “How We Use Your Personal Data” you may see the full details regarding the personal data we use. Accordingly, for the purposes of the Federal Law on the Protection of Personal Data Held by Private Parties (the Federal Law on the Protection of Personal Data Held by Private Parties (FLPPDHPP), in force since March 21, 2025, which has replaced the former LFPDPPP) and other applicable provisions, the information we provide to you constitutes complete information regarding the personal data we use.
Certain of the above processing purposes are voluntary purposes, including showing you personalized recommendations and advertising. We may also use your personal data for voluntary purposes by sending, to your e-mail address, information that we may consider relevant to you. You may object to the processing of your personal data for voluntary purposes as described in the “What Rights You Have” section below.
Please note that we may also use your personal data for the following purposes: compliance with legal obligations or the requirements of competent authorities, the maintenance or defense of our rights before competent authorities/courts, responses to requests you submit to us in relation to your personal data, and the execution of the transfers of personal data detailed in Section 5 “How We Manage Your Personal Data”, Section 6 “How We Share Your Personal Data” and Section 7 “How Your Personal Data Is Stored Locally and Accessed Across Borders”.
As a general rule, we do not require your consent for the transfers detailed in Section 5 “How We Manage Your Personal Data”, Section 6 “How We Share Your Personal Data” and Section 7 “How Your Personal Data Is Stored Locally and Accessed Across Borders”. However, in order to transfer your personal data to a third party that acquires all or substantially all of our business, we must obtain your consent.
By using the Application and/or the services and providing your personal data to us, you consent to the data transfers described above that require your consent. You may exercise your rights in respect of your personal data as described in the “What Rights You Have” section below.
The subsections in the “What Rights You Have” section above entitled “Right of Access”, “Right to Rectification”, “Right to Erasure”, “Right to Object” and “Right to Restrict Processing to Storage Only”, including the restrictions on the use and disclosure of your personal data, as well as “Advertising”, also apply to users located in Mexico.
You also have the right to withdraw any consent you have given us for the processing of your personal data.
To exercise any of your rights, please contact us through our website, or send an e-mail to [infosec@fjdynamics.com].
To learn more about your rights, and the applicable means, procedures and requirements for exercising any of your rights, please contact us by sending an e-mail to [infosec@fjdynamics.com].
We collect certain information relating to your browsing and your device through cookies, certain of which may be treated as personal data (see the relevant sections above). You may adjust your browser settings to refuse or disable cookies. As browsers differ, please consult the instructions provided by your browser. If you refuse, disable or delete cookies, you may be unable to continue using certain functions of the services. For further information regarding our use of cookies and how to disable them, please refer to the “How We Use Cookies and Similar Technologies” section above.
You have the right to provide us with general or specific instructions regarding the retention, deletion and communication of your personal data after your death.
Specific instructions are valid only in respect of the processing activities they mention, and the processing of such instructions requires your express consent.
You may modify or withdraw your instructions at any time.
You may designate a person responsible for implementing your instructions. In the event of your death, that person will be informed of your instructions and will be entitled to request that we implement them. In the absence of a designation, or unless otherwise provided, where the designated person dies, their heirs will be entitled to be informed of your instructions and to request that we implement them.
If you wish to give such instructions, please contact us through our website or by sending an e-mail to [infosec@fjdynamics.com].
This section applies to users located in Brazil:
Where we use your personal information on the basis of your consent, you may withdraw the consent you previously gave for the collection, use and disclosure of your personal information, subject to any contractual or legal restrictions. To withdraw your consent, you may contact us by sending an e-mail to [infosec@fjdynamics.com] to terminate your account. This may affect our provision of services to you.
If you are under the age of 18, please do not use the services for any purpose before obtaining the consent of a parent/guardian to this Privacy Policy (on their own behalf and on your behalf). We will not knowingly collect the personal information of children under the age of 18 without such consent. If you consider that we have obtained any personal information of a child under the age of 18 without parental/guardian consent, please contact us promptly, and we will immediately investigate (and delete) such personal information.
For processing carried out on the basis of your consent, we will, prior to collection, specifically and expressly inform you of the specific purposes of processing and obtain your free, informed and unambiguous consent; you may withdraw your consent at any time, and such withdrawal does not affect the validity of the processing carried out prior to withdrawal.
This section applies to users located in Colombia:
In accordance with applicable law, you have the right to:
· freely access your personal data;
· know, update and rectify your personal data where it is inaccurate, incomplete, fragmented, misleading, or processed without authorization or in a prohibited manner;
· request proof of the authorization granted for the processing of your personal data, unless exempted under applicable law;
· file complaints with the Colombian Superintendence of Industry and Commerce;
· revoke your authorization and/or request the deletion of your personal data where there is no legal or contractual ground for its retention; and
· refuse to authorize the processing of sensitive personal data. In principle, the personal data of minors (persons under eighteen) is not processed; it is processed only where the data is of a public nature, the authorization of the legal representative has been obtained, and the best interests of the child have been considered. The provision of sensitive personal data is not mandatory.
This section applies to users located in Australia:
We take reasonable steps to ensure that third parties located outside Australia handle your personal information in a manner consistent with Australian privacy law when they receive it. However, you acknowledge that we have no control over, and bear no liability for, the acts and omissions of such third-party recipients.
You have the right to access the personal information we hold about you, how we use it, and with whom we share it. You may log into your account to access the personal information you provided for your account. If you consider that we hold any other personal information about you, please contact us at [infosec@fjdynamics.com].
You have the right to correct any inaccurate personal information we hold about you. You may log into your Application account to access the personal information we hold about you. If you consider that we hold any other personal information about you that is inaccurate, please contact us at [infosec@fjdynamics.com].
In the case of minors under the age of eighteen, we will assess their capacity to consent on the basis of their maturity and understanding; where they lack sufficient capacity to consent, we will obtain the consent of a parent or legal guardian for the registration of an account and the use of the Application.
If you are not satisfied with our response to your request to access or correct your personal information, or with the handling of a privacy complaint you have raised concerning your personal information, you may contact us at [infosec@fjdynamics.com].
The use of the Application by children under the age of thirteen requires verifiable parental or guardian consent; for minors aged thirteen to fifteen, the relevant rules on consent to information society services apply; all persons under the age of eighteen enjoy special protection.
You have the following rights:
· Right to know. In certain circumstances, you have the right to know whether your personal data is being processed or has been processed, including whether automated decision-making and profiling exist.
· Right to object. In certain circumstances, you have the right to object to our processing of your personal information, including processing for direct marketing, automated processing or profiling purposes.
· Right of access. In certain circumstances, you have the right to seek reasonable access to personal information upon request.
· Right to correction. In certain circumstances, you have the right to point out any errors in your personal information and to request that we correct them, unless such request is vexatious or unreasonable.
· Right to block or delete. In certain circumstances, you have the right to disable, revoke or seek the blocking, deletion or destruction of your personal information.
By consenting to this Privacy Policy, you agree that we may:
· collect and process your personal information in accordance with the “How We Use Your Personal Data” section of this Privacy Policy;
· share your personal information with third parties, companies within our corporate group and third parties that acquire all or part of us or our business, in accordance with this Privacy Policy and for the purposes described therein; and
· transfer or store your personal information at destinations outside the Philippines, as described in the “How We Manage Your Personal Data”, “How We Share Your Personal Data” and “How Your Personal Data Is Stored Locally and Accessed Across Borders” sections of this Privacy Policy.
In order to comply with the Turkish Personal Data Protection Law (the “DPL”) and its subsidiary regulations, you may contact us at [infosec@fjdynamics.com]. Please include the word “Turkey” in the subject line of your e-mail.
Pursuant to Article 11 of the DPL, you have statutory rights in respect of the personal data we hold about you. As a Turkish data subject, you are entitled (to the extent permitted by the applicable laws and regulations) to apply to the data controller to:
· learn whether your personal data has been processed;
· where your personal information is transferred abroad, we will rely on an adequacy decision, standard contractual clauses or binding corporate rules and file with the Turkish Personal Data Protection Board as required by law, or fall within a statutory exception;
· request information as to the processing where your personal data has been processed;
· learn the purpose of the processing of your personal data;
· learn the third parties, whether domestic or foreign, to whom your personal data will be transferred;
· request the rectification of incomplete or inaccurate personal data;
· request the deletion or destruction of personal data within the scope of the conditions set out in Article 7 of the (Turkish) Personal Data Protection Law; and
· refuse to consent to the automated processing of data and to seek certain remedies under the (Turkish) Personal Data Protection Law.
You agree that your personal information may be collected, used, disclosed, exported and stored in accordance with the provisions of this Privacy Policy, including (without limitation) for the purpose of displaying personalized advertising to you while you use the services.
We may voluntarily report cybersecurity incidents that constitute crimes under UAE law (for example, under the UAE Cybercrime Law). We may report incidents to the relevant administrative authorities for investigation. Please also note that we may voluntarily report cybersecurity incidents to the UAE Computer Emergency Response Team (the “CERT”). CERT is a security-awareness organization that provides processes for recording incidents and advises on known cybersecurity threats in the UAE.
For users located in the United Arab Emirates, where data processing is involved, we follow the UAE federal Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and the Child Digital Safety Law, effective January 1, 2026; before processing the personal information of children under the age of eighteen, we will obtain the consent of their guardian. (Determined in accordance with the Hijri calendar.) However, minors between the ages of 18 and 21 may obtain a court order permitting them to engage in specific commercial transactions. In addition, minors over the age of 7 may engage in commercial transactions with the approval of their guardian.
Children under the age of 14 may use the Application only after a parent/guardian has consented to this Privacy Policy (including the parent/guardian consenting on their own behalf and on behalf of the child), regardless of the purpose of use. Without the foregoing consent, we will not knowingly collect the personal information of any child under the age of 14. If you consider that we hold any personal information of a child under the age of 14 without parental/guardian consent, please contact us, and we will immediately investigate (and delete) such personal information.
In order to provide the Application, we provide the following personal information to third parties outside South Korea (operations in the Korean region have not yet been launched; the following will apply once they are launched):
|
Identity of the recipient and the contact information of its Chief Privacy Officer |
Location of the recipient (or as specified in the recipient’s privacy policy) |
Purpose for which the recipient uses the personal information |
Items of personal information to be provided |
Date and method of transfer |
Period of retention and use by the recipient |
|
The Company’s after-sales technical support and UOP O&M entities in China |
China |
Device status monitoring, fault diagnosis, remote after-sales service, standard recovery, controlled manual recovery, software upgrades and security incident handling |
Account, enterprise and farm contacts; device SNs and binding relationships; device status, location, maps, paths, tasks, alerts, logs; necessary images, videos, sensor data and remote operation records |
Transferred on demand, or accessed remotely via encrypted UOP, work orders or cloud interfaces, during alerts, faults, after-sales requests or continuous O&M |
Used and retained only for the period necessary to complete the services and security audits |
The statutory retention periods for personal information under South Korean law are as follows:
|
Item |
Relevant Regulation |
Retention Period |
|
Records relating to the conclusion and termination of contracts |
Act on Consumer Protection in Electronic Commerce |
5 years |
|
Records relating to payment and other financial arrangements |
Act on Consumer Protection in Electronic Commerce |
5 years |
|
Records relating to consumer complaints and dispute resolution |
Act on Consumer Protection in Electronic Commerce |
3 years |
|
Records relating to labeling/advertising |
Act on Consumer Protection in Electronic Commerce |
6 months |
|
Service access logs |
Act on Protection of Communications Secrets |
3 months |
|
Telecommunications logs |
Act on Protection of Communications Secrets |
12 months |
We will destroy personal information when the need for it no longer exists (for example, where its retention period expires and the purpose of processing has been achieved), except where laws or regulations require us to retain such personal information. Inactive accounts (not logged into or used for one consecutive year) will be placed in segregated safekeeping or deleted after advance notice.
The procedure for the destruction of personal information is as follows:
· Destruction procedure: We will destroy the personal information that is due for destruction in accordance with our data deletion and retention protocols and other applicable procedures.
· Destruction method: We destroy personal information that is recorded and stored in electronic format by methods such as low-level formatting, to ensure that such data cannot be reproduced; personal information recorded and stored in hard copy is destroyed by means of shredders or incineration.
You may contact us at [infosec@fjdynamics.com]. Please include the word “Korea” in the subject line of your e-mail.