Privacy Policy for Cozio App

Updated Date: March 10, 2026

Effective Date: March 10, 2026

Introduction

This "Privacy Policy for Cozio App" (hereinafter referred to as "this Privacy Policy") sets out the terms regarding the platform (or service) operated by Cozio Robotics Inc and its affiliated companies (hereinafter referred to as "Cozio" or "we") that provides you with intelligent hardware device control and management services. We are well aware of the importance of your personal information to you and will do our utmost to protect the security of your personal information. We are committed to maintaining your trust in us and promise to abide by the following principles to protect your personal information: the principles of legality, propriety, necessity and good faith, the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum necessary, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. Meanwhile, we commit to adopting corresponding security protection measures in accordance with mature industry security standards to protect your personal information. This Privacy Policy sets out how we collect, use, disclose, share, transfer and store the information you provide to us when using our products and services, as well as the rights you enjoy.

This Privacy Policy only applies to the circumstances of processing your personal information when you use the Cozio App (hereinafter referred to as the "App"), which is the supporting online application for Cozio intelligent devices (hereinafter referred to as "devices"). It does not apply to any other Cozio products, services, websites, features or content with independent privacy policies. For example, the processing of your personal information when using a device shall be subject to the corresponding privacy policy of that device. Please note that our products and services may contain third-party products, services and links to third-party websites. When you use these products or services or access third-party websites via links, third parties may also collect your personal information. This Privacy Policy does not apply to the personal information processing activities of any third-party-provided products, services or other third-party websites linked via the App, and we shall not be liable for any third party's personal information processing activities. We strongly recommend that you carefully read the third party's privacy protection policy to make prudent decisions.

[Special Reminder] Please carefully read and fully understand this Privacy Policy (we have bolded the key content for your special attention) and make corresponding choices before using the products and services we provide. Once you use or continue to use our products and services, it means that you agree to our processing of your relevant information in accordance with this Privacy Policy. If you have any questions, opinions or suggestions regarding the content of this Privacy Policy, please contact us through the means described in Chapter VII of this Privacy Policy, and we will reply to you within the time specified by law.

This Privacy Policy will help you understand the following:

I. How We Collect and Use Your Personal Information

II. How We Entrust the Processing, Share, Transfer, and Publicly Disclose Your Personal Information

III. How We Store and Protect Your Personal Information

IV. Your Rights

V. Protection of Minors

VI. Updates to This Privacy Policy

VII. Contact Us

I. How We Collect and Use Your Personal Information

(1) Personal information we need to collect and use to provide App functions

To provide you with App-related services, we will collect and use the personal information necessary for providing the basic functions of the App. You are not legally obligated to provide the following personal information, but without such information, we may not be able to provide you with the basic functions of the App.

1. Account Creation and Login

To help you successfully create a Cozio account, you need to provide us with your mobile phone number and set a password for your Cozio account.

When you log in to your Cozio account, we will collect your account credential information, including (1) account name, password, mobile phone number and verification code, and email address, which are used to verify your identity; (2) Token (login token) to help you maintain the login status. In addition, when you create or log in to a Cozio account, we will also collect the region and country code you select to assist in determining the data center to which the device and mobile device are connected. If you log in to the App using a third-party account, including national network identity authentication information, WeChat account (including WeChat account, nickname, avatar, subject to the scope of your authorization), Apple ID, Facebook account, Google account, etc., we will collect your third-party account information, subject to the scope of your authorization.

When you register or log in to Cozio using a third-party account, we need to use your app installation list information. Please rest assured that such information will not be uploaded to our server, and we will not process such information in any way. Such information is only directly retrieved by third-party SDK providers and used to realize the function of registering and logging in to Cozio using a third-party account. If you do not provide the above information, you may not be able to use this function.

Since your mobile phone number and email address are important information for logging in to the App, such information will be stored in the mobile device running the App. If you want to delete the Cozio account information, you can choose to delete your Cozio account through the method described in Chapter IV below. If you have deleted your Cozio account and wish to further delete the local cache, you need to delete the App from your mobile device.

2. Account Profile Maintenance

To help you manage and maintain your Cozio account, you can independently choose to set your avatar and nickname, and independently choose to bind other account information in addition to your registration information, including mobile phone number, email, or third-party account (national network identity authentication information, WeChat account, Apple ID).

Your avatar will only be used for display on the profile page and member center. When you upload/change your avatar, we will request to enable your album permission and permission to read external storage, and collect the image information you upload/change. If you refuse the above permissions, you will not be able to set your avatar independently, but it will not affect your use of other functions of our products and/or services.

You can independently fill in the basic information and family environment information in your personal profile. If you fill in your birthday information, we will provide you with birthday-specific benefits. If you choose not to fill in your personal profile, it will not affect your use of other functions of our products and/or services.

3. Device Network Connection and Binding

When the device needs to be used with a network connection, to support you to securely connect and control the device through the App, you need to connect your Cozio account, mobile device, and the device to the WiFi network you are in for network configuration, so as to bind your device in the App. In this process, we will collect your (1) Cozio account information; (2) mobile device information, including device model, device identifiers (Android ID/OAID/GUID/IDFV/OPEN UDID), network card (Mac) address, operating system and its version; (3) your device information, including device model, SN code, network card (Mac) address; (4) time zone setting information for executing cloud timing tasks and implementing intelligent scenarios; (5) WiFi network information, including the name of the currently connected WiFi, WiFi mode (local area network mode, remote mode), IP address, WiFi signal strength indicator received by the device (i.e., device RSSI), and the WiFi password you actively provide. Your password information will only be stored on the device side and will not be uploaded to our backend server. You can clear the WiFi name and password at any time by deleting the device and deleting the App.

4. Device Information Display

To help you better understand your device status, we display the device name you edited by yourself and your device status information on the App. For details on how we collect such device information, please refer to the respective privacy policies of the devices you have bound.

5. Device Firmware Upgrade

We may collect the firmware version information, device model of the devices bound to your Cozio account through the App, and the information of the bound devices to provide you with the device firmware version upgrade function. If you choose to enable the auto-update function, we will select the update time based on your region to complete the update at night without disturbing you.

6. Maintaining Stable and Secure Operation of the App

In the process of your using the App, to maintain the stable and secure operation of the App, we need to collect your App crash information and mobile device-related information, including the system version, language settings, mobile device model of your mobile device, and the model of the connected device.

7. Device Usage

When you use the device bound to your Cozio account, your Cozio device (such as a sweeper, subject to the actual product you purchased) will collect image data of the surrounding environment to provide cleaning services. Such image data is only stored on your device terminal and will not be uploaded.

When you use the smart speaker control function, you need to add our device on a third-party platform. In such cases, we will collect user ID, robot device nickname, device ID, and device model information and provide them to third parties. The relevant third parties include Google Home and Amazon Alexa as mentioned in "Third-Party Partners".

(2) Personal information we may collect and use to provide additional functions

To provide you with more convenient and high-quality services and enhance your App usage experience, we may collect and use your personal information when providing you with the following additional services. If you choose not to provide the information required for the additional services, you can still use the basic functions of the above-mentioned App, but you may not be able to use these additional services that can bring you better services.

1. Member Center

When you register as our user, you automatically become a member. We do not collect any additional personal information during the registration process itself. Once you become a member, you can participate in member activities, which are subject to the page displayed to you. When you actively participate in member activities, we will collect additional information about you; the specific information collected will be as shown on the member activity page.

After becoming a member, you can participate in our member activities (the specific activity content is subject to the actual page displayed). Please note: When you actively participate in these member activities, we may collect specific information about you according to the activity requirements. The specific information collected will be clearly stated on the member activity page you participate in.

To provide you with member benefits (such as points, coupons, etc.) according to platform rules, we need to collect and use the following information: your account level; your usage log information (including but not limited to browsing history, click history, interaction behavior, time of behavior, pages or product information visited; the specific content may vary depending on the type of behavior); and information you actively submit (e.g., the device serial number (SN) and shipping address required for binding an electronic warranty card; the mobile phone number, shipping address, and name required for redeeming points for prizes). Your membership benefits information (such as points balance, coupon status, etc.) will be displayed to you in the Member Center. You can check the changes to these benefits at any time.

To provide membership growth system services and issue task badges to you, we need the following information: App usage logs: Including your browsing history, click history, interaction behavior, time of occurrence of the behavior, and page or product information visited (specific content may vary depending on the type of behavior). Device log information: Including cleaning data of the devices you connect to (such as cleaning area, duration, time, area), obstacle crossing/avoidance data, base station related data, number of function uses, sharing and interaction data, etc. (specific content may vary depending on the different cleaning device models).

2. Device sharing

To support you in sharing your device with other Electra account users for joint control and use, when you choose to share a specific device with others, we may collect your account (phone number or email address), the recipient's account, and the information of the shared device. This information is used to enable the device sharing function and display the sharing status on the device list page. You can cancel sharing through the App's "My > Device Sharing". The user who initiated the sharing is solely responsible for any damage caused by improper operation of the device by the controlled account holder after sharing device control permissions with another user's account.

3. Feedback on Issues and Suggestions

Your feedback is very important for us to improve services and help solve the problems you encounter in using the App and devices. To track and handle the feedback you provide, we will collect the UID you actively provide, feedback information (including text and pictures), device identifiers, the model name and system version of your mobile device. In addition, if you encounter problems when using the App, you can choose to upload your App log information to help us solve daily usage issues.

4. Widget functionality and auto-start

When you use the app's home screen widget, the app will automatically start at a certain frequency to ensure you receive and understand your device's status information in a timely manner. This behavior is necessary for the widget's functionality. If you do not use the app's home screen widget, the app will not start automatically.

5. Information Display and Push

We may send you device notifications and system notification messages in the App. For this purpose, we will collect and use your Cozio account information, device ID, mobile device system information, and device model. You can contact us at any time through the method described in Chapter VII of this Privacy Policy to request to stop information push.

6. User Experience Improvement Program

To continuously improve products and services and enhance your service experience, we specially invite you to participate in Cozio's "User Experience Improvement Program". If you agree to participate in this program, we will collect your device attribute information, operation information, configuration information, and special event information. You can view the details through "My > About Us > User Experience Improvement Program".

6.1 Improving the Object Recognition and Obstacle Avoidance Capability of Sweeping and Mopping Robots

To improve the object recognition and obstacle avoidance capability of sweeping and mopping robots and provide you with a more comfortable usage experience, we will collect:

(a) Ground item information, including ground obstacles (such as shoes, trash cans, toilet wiring harnesses, etc.), ground transition markers (such as floor mats, carpets, etc.), and ground dirt (such as stubborn stains, pet feces, etc.);

(b) Relevant environmental data when negative events such as malfunctions and collisions occur;

(c) Obstacle model data actively labeled by users or information about negative events actively reported by users that are beyond the scope of the sweeping and mopping robot's object recognition model.

6.2 Improving the Path Planning Capability of Sweeping and Mopping Robots

To improve the path planning capability of sweeping and mopping robots and provide you with a more comfortable cleaning experience, we will collect your furniture environment information, including furniture information recognized by the sweeping and mopping robot and furniture information you actively set and add in the map, such as beds, sofas, tables, chairs, etc.

6.3 Live Photo and Video Viewing Feature for Mopping Areas

To provide you with the ability to view live and playback footage of corresponding areas during or after the mopping robot's cleaning sessions, and to facilitate your personalized improvement of the robot's cleaning capabilities, we will utilize the various built-in cameras of the mopping robot to take photos and recordings of various corners within the mopping area at any time during operation. This process may potentially capture your private items or personal activities. We assure you that the shooting angles of all cameras on the mopping robot will not exceed the scope necessary for mopping purposes. Furthermore, the recorded photos and videos are solely for your personal viewing and are used exclusively for the service functions described above. Without your separate written authorization, this data will not be used for any other purposes. You may also request the deletion of this data at any time. Data stored locally on your mobile device is under your own control for management. Please note, however, that after deletion, you will no longer be able to use the live viewing and playback features.

6.4 Updating and Improving the Intelligent Obstacle Avoidance Model

To continuously update and improve the intelligent obstacle avoidance model of our sweeping and mopping robots and enhance their operational performance and user experience, we will collect, count, and further analyze all the data from the User Experience Improvement Program provided by users.

We promise to use the data you provide in strict accordance with the requirements of laws and regulations and take strict protection measures to ensure the security of your data. You can opt out of the User Experience Improvement Program at any time through "My" > "About Us" > "User Experience Improvement Program".

7. Others

7.1 If the information you submit contains the personal information of others, you must ensure that you have obtained the legal authorization of that individual before providing such information to us.

7.2 If we need to use your personal information for other purposes not explicitly stated in this policy, unless otherwise stipulated by laws and regulations, we will obtain your separate consent before conducting relevant processing.

7.3 If we cease to operate this product, we will promptly stop activities of continuing to collect your personal information, notify you of the cessation of operation by means of individual notification or public announcement, and delete or anonymize the personal information we hold.

7.4 Except for the situations where personal information is explicitly collected as mentioned above, in accordance with applicable laws, we will use data that has been processed through technical measures and other necessary means, cannot be re-identified as a specific individual, and cannot be restored (i.e., anonymized data) for statistical analysis, data mining, product optimization, and business decision support (including but not limited to using such anonymized data for algorithm model training in intelligent customer service scenarios). Cozio will independently determine the purposes and methods of collecting, using, processing, transferring, or disclosing such anonymized data in accordance with applicable laws. Please note: If such anonymized data can identify you when combined with your other personal information, we will still treat it as personal information and protect it in accordance with the rules described in this Privacy Policy.

(3) Circumstances of Invoking Mobile Device Permissions

To provide you with specific service functions, we will, when you trigger relevant business functions and with your consent, invoke relevant permissions and obtain your personal information (if applicable). You may refuse or withdraw authorization for such permissions at any time. As a result, you may not be able to use the corresponding service functions, but this will not affect your normal use of other functions of the App. The specific circumstances of mobile device permissions that the App may invoke are as follows:

Device Permission Purpose of Use Whether to Ask for Consen Whether It Can Be Turned Off
Location Information Used for device network configuration, discovering nearby devices, obtaining WiFi information currently connected to the mobile device, and helping users quickly enter the delivery address. Yes Yes
Read External Storage Allows the App to read information such as pictures/videos stored on your device to enable avatar upload/replacement and upload of user feedback information. Yes Yes
Write to External Storage Stores information such as pictures/audio-visual files and crash logs in the App to the external storage space of your device. Yes Yes
Camera Permission Used to scan the QR code on the device body during device network configuration for easy quick connection to the device; used for uploading user feedback information. Yes Yes
Album Permission Used for user avatar replacement and upload of user feedback information; for some devices that support downloading of live photos and screenshot/recording of real-time videos, used for storing photos or videos. Yes Yes
Microphone Permission Used for some devices that support video call functions to enable video calls or voice transmission. Yes Yes
WLAN Permission Used to connect to the WiFi emitted by the device during device network configuration for device communication and thus connection to the device. Yes Yes
Bluetooth Permission Used to connect to the Bluetooth emitted by the device during device network configuration for device communication and thus connection to the device. Yes Yes
Notification Permission Used to send you device notifications and system notification messages. Yes Yes
Local Network Permission Used to enable the local network on the iOS side and connect to the WiFi emitted by the device during device network configuration for device communication and thus connection to the device. Yes Yes
Siri & Search Permission Used on the iOS side to interact with Siri voice through setting up Siri (based on the shortcut commands previously set in the mobile device) to control the device's activation or movement. Yes Yes
Access to Clipboard Permission Read when the user actively copies other information, used for quickly pasting the copied content in scenarios such as feedback submission and nickname modification. Yes Yes

(4) Exceptions to Obtaining Consent

You should be fully aware that in the following circumstances, we do not need to obtain your authorization and consent for collecting and using personal information:

Those related to our fulfillment of obligations stipulated by laws and regulations.

Those directly related to national security and national defense security.

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

Those directly related to criminal investigation, prosecution, trial, and execution of judgments.

Those for the purpose of safeguarding the major legitimate rights and interests such as life and property of the subject of personal information or other individuals, but it is difficult to obtain the authorization and consent of the person concerned.

The personal information involved is publicly disclosed by you to the public.

Collecting personal information from legally publicly disclosed information, such as through legal news reports, government information disclosure and other channels.

Those necessary for signing and performing a contract at your request.

Those necessary for maintaining the safe and stable operation of the provided products or services, such as detecting and handling faults of products or services.

Those necessary for news organizations to carry out legal news reporting.

Those necessary for academic research institutions to carry out statistical or academic research based on public interests, and when providing the results of academic research or descriptions to the public, the personal information contained in the results has undergone de-identification processing.

Other circumstances stipulated by Chinese laws.

(5) How We Use Cookies and Similar Technologies

A Cookie is a plain text file stored on a mobile device by a web server. The content of a Cookie can only be retrieved or read by the server that created it. Each Cookie is unique to your mobile application. Cookies usually contain an identifier, the name of the site, and some numbers and characters. With the help of Cookies, we can remember your operations and preferences over a period of time (such as login status, language settings, font size, shopping cart content, and other display preferences), so that you do not need to repeatedly enter such information when revisiting the App or jumping between pages. We only use Cookies to support relevant functions when necessary, and Cookies will be automatically cleared after you log out or delete the App. Cozio will not use Cookies for any purposes other than those stated in this Privacy Policy.

II. How We Entrust the Processing, Share, Transfer, and Publicly Disclose Your Personal Information

(1) Entrusted Processing

We may entrust third-party service providers (including mail order stores, delivery service providers, telecommunications companies, data storage service providers, technical support providers, customer service providers, IOT service providers, advertising and marketing service providers, data analysis service providers, and large model service providers) to process your personal information to provide you with corresponding products or services. The aforementioned third-party service providers will only process your personal information on our behalf for the purposes stated in this Privacy Policy. For companies, organizations, and individuals that we entrust to process personal information, we will sign strict confidentiality agreements or other data protection-related agreements with them, requiring them to process personal information in accordance with our requirements, comply with applicable privacy protection requirements in your jurisdiction, and take other measures that can ensure the confidentiality and security of personal information.

(2) Sharing

We will not sell any personal information to third parties. We will not share your personal information with any third parties (including companies, organizations, and individuals) except in the following cases:

1.Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with third parties;

2.Sharing under statutory circumstances: We may share your personal information with third parties in accordance with the provisions of laws and regulations, the needs of resolving litigation disputes, or mandatory requirements put forward by administrative or judicial authorities in accordance with the law.

3. Sharing with affiliated companies and third-party partners: To provide you with better services, your information may be shared within Cozio's affiliated companies (involving production and manufacturing, product sales, after-sales services, etc.) where it meets the data protection legal requirements of your jurisdiction. In addition, some functions in the App are provided by third-party partners through software development kits (SDKs). Where it meets the data protection legal requirements of your jurisdiction, we will share your personal information with third-party service providers to provide the services you need. However, we will only share necessary personal information, which is also subject to the purposes stated in this Privacy Policy. You can view the third parties involved in our products and services in the Annex: List of Cooperating Third Parties. Please note that for companies, organizations, and individuals with whom we share personal information, we will sign strict data protection agreements with them, or require them to process personal information in accordance with this Privacy Policy and any other relevant confidentiality and security measures.

(3) Transfer

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

Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties; In cases involving merger, division, dissolution, acquisition, or declaration of bankruptcy: If personal information transfer is involved, we will inform you of the name and contact information of the recipient of the personal information. We will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy; otherwise, we will require that company or organization to separately seek your authorization and consent.

(4) Public Disclosure

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

1.After obtaining your separate consent;

2.We may publicly disclose your personal information in cases required by law, legal procedures, litigation, or mandatory requirements of government authorities;

3. Other circumstances permitted by laws and regulations that are necessary to respond to sudden public health incidents or, in emergency situations, to protect the life, health, and property safety of natural persons.

(5) Exceptions to Obtaining Prior Authorization and Consent for Sharing, Transferring, or Publicly Disclosing Personal Information

For the avoidance of doubt, to the extent explicitly permitted by applicable laws, we may share, transfer, or publicly disclose your personal information without your consent, including the following specific circumstances:

1. It is necessary for concluding or performing a contract at your request.

2. It is necessary for performing statutory duties or obligations: We may share your personal information in accordance with the provisions of laws and regulations, the needs of litigation and dispute resolution, or requirements put forward by competent authorities such as administrative, judicial, and supervisory authorities in accordance with the law, as well as for the performance of other legal obligations.

3. It is necessary to respond to sudden public health incidents or, in emergency situations, to protect the life, health, and property safety of natural persons.

Processing personal information within a reasonable scope for the purpose of conducting news reporting, public opinion supervision, etc., for the public interest.

Processing your voluntarily disclosed personal information or other legally publicly disclosed personal information (such as personal information legally disclosed through legal news reports, government information disclosure, etc.) within a reasonable scope.

4. Other circumstances stipulated by laws and regulations.

4. Other circumstances stipulated by laws and regulations. Pursuant to legal provisions, where personal information that has undergone de-identified processing is shared, transferred, or publicly disclosed, and it is ensured that the data recipient cannot restore or re-identify the subject of the personal information, we will not need to separately notify you or obtain your consent for the processing of such data.

III. How We Store and Protect Your Personal Information

(1) Storage Location of Your Personal Information and Cross-Border Transfer

1. Cozio uses globally deployed cloud services to process and back up personal information. Currently, Cozio uses data centers located in China, Germany, the United Kingdom, France, Italy, Spain, Ireland, South Korea, and the United States. Based on the country or region you select when registering your Cozio account, we will store your information in a nearby location.

2. If you choose to use the App within the territory of the People's Republic of China (excluding Hong Kong, Macao, and Taiwan regions) during registration, your personal information will be stored in data centers in China (excluding Hong Kong, Macao, and Taiwan regions). We will not transfer your personal information outside the territory of the People's Republic of China. If cross-border transfer of personal information is involved in the future, we will only transfer your personal information outside your jurisdiction with your explicit consent or after implementing appropriate security protection mechanisms in accordance with applicable data protection laws. However, regardless of where your personal information is processed, it will not change our commitment to protecting your personal information as stated in this Privacy Policy.

(2) Storage Period of Your Personal Information

We will store your personal information for the period necessary to achieve the purposes of collecting the personal information, or within the period specified or permitted by applicable laws. For example, the "E-Commerce Law of the People's Republic of China" requires that information on goods and services as well as transaction information be kept for no less than three years from the date of completion of the transaction. After the retention period expires, we will delete your personal information or anonymize it in accordance with the requirements of applicable laws. When you take the initiative to cancel your account, we will process the data in accordance with the requirements of laws and regulations.

Our criteria for determining the storage period of personal information mainly include the following:

1. Completing the transaction purposes related to you and maintaining corresponding transaction and business records to respond to your possible inquiries or complaints;

2. Ensuring the security and quality of the services we provide to you;

3. Whether you have agreed to a longer retention period;

4. Based on the relevant needs of the statute of limitations;

5. Whether there are other special agreements or legal provisions regarding the retention period. Once we reasonably determine that continuing to store personal information no longer serves its collection purpose, we will immediately stop storing and delete the personal information or anonymize it. In the event of termination of operations, we will notify you at least 30 days in advance, and after termination of operations, we will process your personal information in accordance with the requirements of laws and regulations.

If personal information processing activities are for the purposes of public interest, scientific, historical research, or statistics, we may continue to retain relevant data where permitted by applicable data protection laws, even if further data processing is not related to the original collection purpose.

(3) Protection Measures We Take

1. We promise to ensure the security of your personal information. To prevent unauthorized access, disclosure, or other similar risks, we have adopted reasonable physical, electronic, and organizational measures to protect the personal information we collect through the App. We will take all reasonable measures to protect your personal information.

2. All your data is stored on secure servers and protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We ensure that employees and third-party service providers who access this information to help provide products and services to you have strict contractual confidentiality obligations; if they fail to fulfill these obligations, they will be subject to disciplinary action or have their cooperation terminated. Similarly, we have adopted specialized 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.

3. We will take all feasible measures to protect your personal information. However, you should be aware that internet use is not always secure. Therefore, we cannot guarantee the security or integrity of any personal information during two-way transmission over the internet. We shall not be liable for any leakage, loss, damage, or other consequences of personal information caused by uncontrollable factors such as force majeure, system failures, hacker attacks, or third-party reasons.

4. In accordance with the requirements of applicable laws, including the personal information protection legislation of your jurisdiction, if a personal information leakage incident occurs, we will promptly notify the relevant regulatory authorities; in some special cases, we will also notify you of personal information leakage incidents related to you.

(4) Protection Measures You Can Take

To protect your personal information, please do not disclose your account information to anyone unless the person is formally authorized by you. Cozio shall not be liable for any security breaches caused by your failure to keep your personal information confidential, resulting in third-party access to your personal information. Nevertheless, if you discover any unauthorized use of your account by other internet users or any other security vulnerabilities, you must notify us immediately. Your assistance will help us protect the confidentiality of your personal information.

IV. Your Rights

You or other authorized subjects may exercise relevant rights with respect to any personal information we hold that is related to you. Cozio guarantees your right to exercise the following rights over your own personal information and provides you with relevant control settings.

Pursuant to applicable data protection laws, upon receiving your request, we may first require you to verify your identity. After successful identity verification, we will respond to your request within 15 working days. In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed a reasonable limit, we may charge a certain cost fee as appropriate. Pursuant to applicable data protection laws, we may refuse requests that are frivolously repetitive, require excessive technical means, pose risks to the legitimate rights and interests of others, or are highly impractical. However, if we are unable to respond to your request, we will explain the corresponding reasons to you.

(1) Deleting Your Personal Information

Pursuant to applicable data protection laws, you have the right to delete your personal information. You may request us to delete your personal information in the following circumstances:

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

2. If we collect or use your personal information without obtaining your explicit consent;

3. If our processing of personal information seriously violates the agreement with you;

4. If you no longer use this product or have proactively canceled your account;

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

You may independently delete your personal information through the following methods:

Select "Clear Cache" in the App to delete the cached information from the App.

If you wish to delete the personal information stored on our servers, you can log in to the App, enter the "My" section, click the business card at the top to enter the profile interface, and click "Delete Account" in the profile interface to perform the corresponding operation.

You can also delete all your personal information from the App terminal by revoking authorization; for specific operations, see "Withdrawing Consent" below.

In addition to the above methods, you may also contact us through the means described in Chapter VII of this Privacy Policy to request the deletion of your personal information. We will process your request within 15 working days. If we decide to respond to your deletion request, we will also, to the extent possible, notify the subjects that have obtained your personal information from us and require them to delete it promptly (unless otherwise stipulated by laws and regulations, or these subjects have independently obtained your authorization).

Please understand that after you or we assist you in deleting relevant personal information, due to applicable laws and security technologies, we may not be able to immediately delete the corresponding information in the backup system. However, we will securely store your personal information and isolate it from any further processing until the backup is cleared or anonymization is completed.

(2) Accessing, Copying, Correcting, and Supplementing Your Personal Information

You can view and manage your personal information through "My > About Us > Personal Information Collection List". If you cannot manage this personal information through the above path, you can contact us at any time through the means described in Chapter VII of this Privacy Policy. We will respond to your access request within 15 working days.

When you find that the personal information we process about you is incorrect, you have the right to request us to correct or supplement it. You can enter the "My > Click Nickname or Avatar > Personal Profile Page" section, click the business card at the top to enter the profile interface for direct correction, or contact us through the means described in Chapter VII of this Privacy Policy to submit a correction or supplement application. We will process your request within 15 working days.

You have the right to request access to and/or correction of any personal information we hold about you. Based on your request, we can provide a free copy of the record of your personal information that we have collected and processed. If you wish to request access to the personal information we hold or if you believe any information we hold about you is incorrect or incomplete, please contact us as soon as possible through the means described in Chapter VII of this Privacy Policy.

(3) Restricting or Objecting to the Processing of Your Personal Information

Pursuant to applicable laws, you may have the right to restrict or object to our use of your personal information in specific scenarios. You can contact us through the means described in Chapter VII of this Privacy Policy to request the exercise of this right.

(4) Withdrawing Consent

When we process personal information based on your consent, you can submit a request through the means described in Chapter VII of this Privacy Policy, or independently in the App through "My > About Us > Privacy Policy" in the App at any time to withdraw your consent to our Privacy Policy, thereby withdrawing your consent to our collection, use, and/or disclosure of your personal information that we hold or control in accordance with this Privacy Policy. After you withdraw your consent, we will stop collecting your personal information and will no longer use and/or disclose your personal information.

Please note that withdrawing your consent may have certain legal consequences. Depending on the scope of your withdrawal of consent, you may not be able to enjoy some of the services we provide through the App, but your decision to withdraw consent will not affect the personal information processing activities carried out based on your previous authorization.

(5) Transferring Your Personal Information

Pursuant to applicable data protection laws, you have the right to request the transfer of your personal information to other personal information processors in the manner stipulated by law. You can contact us through the means described in Chapter VII of this Privacy Policy to exercise this right.

(6) Canceling Your Account

You can apply to cancel your account through the following methods:

Log in to the App, enter the "My" section, click the business card at the top to enter the profile interface, and click "Delete Account" in the profile interface to perform the corresponding operation;

Contact us through the means described in Chapter VII of this Privacy Policy to apply for canceling your account.

After you proactively cancel your account, we will stop providing you with products or services and delete or anonymize your personal information within 15 working days after you apply for cancellation and complete identity verification. Please note that the account cancellation operation is irreversible, and your data cannot be recovered after deletion, so please consider your choice carefully.

(7) Other Rights

In addition to the rights listed above, pursuant to applicable laws, you also enjoy other rights related to personal information.

In the following circumstances, in accordance with the requirements of laws and regulations, we may be unable to respond to your request:

1. Those related to national security or national defense security;

2. Those related to public security, public health, or major public interests;

3. Those related to criminal investigation, prosecution, trial, or execution of judgments;

4. There is sufficient evidence to show that the subject of personal information has subjective malice or abuses rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6. To fulfill our legal obligations;

7. Those involving trade secrets.

In addition, we will protect the personal information of the deceased in accordance with the relevant provisions of the "Personal Information Protection Law". After a user passes away, their close relatives may, for their own legitimate and proper interests, exercise rights such as accessing, copying, correcting, and deleting the relevant personal information of the deceased user through the contact information publish‌ in Chapter VII of this Privacy Policy, unless the deceased user made other arrangements during their lifetime.

If you are dissatisfied with our response, especially if you believe that our personal information processing activities have harmed your legitimate rights and interests, you may also, in accordance with applicable legal provisions, file a lawsuit with a competent court or resolve your claims through external channels such as complaining to a regulatory authority.

V. Protection of Minors

We attach great importance to the protection of minors' personal information. We believe that it is the responsibility of parents or legal guardians to supervise children's use of our products and services. However, our policy does not require obtaining personal information from minors or sending any promotional materials to such groups. If we find that we have collected a minor's personal information without first obtaining the consent of the minor's parents or legal guardians, we will take steps to delete the relevant data as soon as possible. If a parent or guardian has reason to believe that a minor has submitted personal information to us without their prior consent, we strongly recommend that you contact us promptly through the means described in Chapter VII of this Privacy Policy. We will delete the relevant personal information as soon as possible and ensure that the minor unsubscribes from any applicable Cozio services. The consequences resulting from a user's false declaration of age or impersonation of others shall be borne by the user themselves and their guardian; we shall not bear any responsibility for this.

VI. Updates to This Privacy Policy

We will regularly review and may update this Privacy Policy to reflect changes in our personal information processing practices. Without your explicit consent, we will not reduce the rights you are entitled to under this Privacy Policy. If we make material changes to this Privacy Policy, we will notify you through the App so that you can promptly understand the latest version of this Privacy Policy. Such changes to the Privacy Policy will take effect from the notification date or the specified effective date. We recommend that you review this page regularly to obtain the latest information about our privacy practices.

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

1. Significant changes in our service model, such as the purpose of processing personal information, the type of personal information processed, or the way personal information is used;

2. Significant changes in our ownership structure or organizational structure, such as changes in ownership due to business adjustments, bankruptcy, or mergers and acquisitions;

3. Changes in the main recipients of personal information sharing, transfer, or public disclosure;

4. Significant changes in your rights regarding participation in personal information processing and the way to exercise such rights;

5. Changes in the responsible department for personal information security, contact information, or complaint channels;

6. When the personal information security impact assessment report indicates high risks.

VII. Contact Us

If you have any comments or questions about this Privacy Policy, or if you have any questions about Cozio's processing of your personal information, please contact us through the following information and indicate that your inquiry or comment is related to the "Privacy Policy" in the relevant message:

Cozio Robotics Inc.

Contact Address: 1500 N Grant St Ste N Denver CO 80203 US

Contact Information for Cozio's Personal Information Protection Officer: support@coziobot.com

List of Cooperating Third Parties

I. List of SDKs

For the purposes of ensuring the stable operation of the product, implementing product functions, etc., we will integrate SDKs provided by third parties. We will monitor the data collection behaviors of third parties to protect your rights regarding personal information and data security. We shall not be liable for any leakage, abuse, or other acts of personal information caused by the third parties or partners themselves, but we will actively assist users in safeguarding their legitimate rights and interests. To meet user needs, product functions may be added or changed; if such changes lead to adjustments to the integrated third-party SDKs, we will update this list in a timely manner to show you the latest status of third-party SDKs. Currently, the details of the third-party SDKs we have introduced are as follows:

Name of Third-Party SDK Provider Data Type Purpose of Use Privacy Policy Link
Jiguang Push SDK Shenzhen Hexun Huagu Information Technology Co., Ltd. Device identifiers (including Android ID, GAID, OAID, UAID, IDFA, AAID, Boot ID), device hardware information (including device model, device screen resolution, device hardware manufacturer, device product name, device storage space), operating system information (including operating system version, system name, system language), network information (including network type, operator information, IP address, DHCP, WIFI status information), push message logs To provide information push services for APP users https://www.engagelab.com/zh_CN/license/privacy
rtsa Shanghai Shengwang Technology Co., Ltd. Device identification information, application information To provide video interaction services for APP users https://www.shengwang.cn/compliance/
IotLinkKit Alibaba Cloud Computing Co., Ltd. Device identification information, application information To provide MQTT communication services for APP users https://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud202107091605_49213.html

II. Third-Party Partners

To implement relevant product functions, your personal information may be shared with the following third-party partners. Details of the specific sharing are as follows (for data sharing via SDK, please refer to Point I above, which will not be repeated here):

Partner Sharing Provider Data Type Purpose of Use Privacy Policy Link
Google Home Google LLC User ID, robot device nickname, device ID, device model To enable Google Home voice https://cozio.booleanclouds.com/agreement/czen/privacy/
Amazon Alexa Amazon.com, Inc. User ID, robot device nickname, device ID, device model To enable Amazon Alexa voice control for devices https://cozio.booleanclouds.com/agreement/czen/privacy/
IPinfo.io IPinfo.io User ID, robot device nickname, device ID, device model To check the country associated with an IP address https://ipinfo.io/privacy-policy