Narwal Privacy Policy

Updated on: November 28th, 2024

Effective from: November 28th, 2024

Introduction

Narwal (“Company” or “We”) respects your privacy and are committed to protecting it through our compliance with this Privacy Policy (this “Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide us with when you use our products and services, such as when you visit our websites (including but not limited to narwal.com , collectively our “Website”), when you use our mobile applications (including but not limited to Freo App, collectively our “App”) and when you have nonpublic interactions with us (e.g., via opening a help/feedback ticket) (collectively, our “Service”). It also states our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy is incorporated into and is subject to the Terms of Use for our products and services you use. Certain Narwal products and services may provide separate privacy policies. For any conflicts between this Policy and those separate privacy policies, you understand that the latter shall prevail, while anything not specifically covered is subject to this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using our Service, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Service after we make changes is deemed to be acceptance of those changes. We encourage you to check the Privacy Policy periodically for updates.

1. Information We Collect About You and How We Collect It

We may collect information about you directly from you, automatically through your use of our Service or from third parties. Some information we collect from you is referred to as “personal information” or “personal data” in this Privacy Policy. Personal information or personal data is data that can identify you, or data that we can relate to you, such as your name, email address, credit card number, and shipping address.

1.1 Information You Provide To Us

Depending on the service you choose, you may provide the following types of information to us:

• Account information. When you create a Narwal account, you may provide us with information that includes your username, email address (or phone number, based on the country located in), password or other information for account verification. You might choose to provide us with additional information — like gender, photo and other information which may be shown on your profile page.
• Contact information. When you place an order with Narwal, or contact us for customer service, you may provide us with your contact information including your name, alias, email address, shipping address, billing address and phone number.
• Payment information. When you place an order with Narwal or engage in financial transactions by using our Service (such as receiving refund for your returns), you may provide us with your payment information such as your bank account, credit card number, or debit card number.
• Photos and Videos. Narwal does not automatically collect your photo or video without your consent and affirmative actions. When you enable photos or videos functions (such as Live Photos), request customer service or give feedback to us, you may choose to provide/upload your photos, videos or other content, including text content relating thereto, we may collect and store such content. If such content contains information about others, you should obtain any required or appropriate consent from such persons and inform them about this Privacy Policy before uploading such content to Narwal.
• When you contact us, we may collect information about your communications with us, including your contact information, and the time, topic, and content of your communications.
• Device information and network information. In order to control your IoT Product from our App, your IoT Product must be connected to Wi-Fi network and be associated with your Narwal account. In order to fulfill such purposes, we need to collect your device information, such as Serial Number (SN) and Device ID, Device identifiers (such as MAC address/IMEI/Android ID/IDFA/Open UDID), and your network information, such as Wi-Fi List Information, Wi-Fi SSID, Wi-Fi password, Bluetooth information, IP address, and Mac address. Please rest assured that your Wi-Fi password is only stored locally on your robot device and APP, and will not be uploaded to the cloud server of Narwal.

1.2 Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Service, we may use cookies and other similar automatic data collection technologies (e.g. pixels, etc.) to collect certain information about your equipment, browsing actions, and patterns, including log data, such as your computer or other mobile device’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics. Please visit the page Cookie Policy  to learn more about cookies and our practices.

1.3 Information We Collect From Third Parties

If you access our Service through third parties (e.g., Facebook or Google), or if you share content from our Service to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings with it allow such sharing: the information we receive will depend on the policies and your account settings with the third-party service. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.

2. How We Use Your Information

The purpose of collecting personal information is to provide you with our Service and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:

• To operate and provide features of our Service, to verify and manage Narwal user accounts, to provide you with products, or services that you request from us, and to process and deliver entries and rewards in connection with promotions that we may offer you from time to time. We will process your personal data in accordance with this Privacy Policy and any of your preferences, which are expressed via Narwal products, apps and other types of services.
• To analyze the information you provide to us so as to provide you with tailored content that will be of interest to you.
• To understand and analyze the usage trends and preferences, to improve our Services, and to develop new products, services, features, and functionality.
• To contact you for administrative and informational purposes, including for customer service. For example, to notify you about changes to our Service or any products or services we offer or provide through it.
• To detect, prevent, and respond to fraud, abuse, security risks, and technical issues that could harm our users, us, or the public.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
• To comply with applicable laws, such as laws related to signing up online user accounts.

For EU/EEA Users

If you are located in the European Economic Area, we will only use your information when we have a valid legal ground, including when:

• You have consented to the use of your information, for example, to send you marketing communications.
• We need to use your information to enter into or perform a contract with you, for example to deliver Narwal products, to provide map services, or provide you with customer support and other after-sales services.
• We need to use your information to comply with a legal obligation, for example, to comply with a court order, subpoena, or warrant.
• We or a third party have a legitimate interest in using your information. In particular, we have a legitimate interest in using your information to understand and improve our Service and to monitor for and prevent fraud. We only rely on our own or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.

We may also use your information to send direct marketing such as communications, including updates on promotions and events, relating to products and services offered by us. If you are an individual or consumer we will only send you direct marketing with your consent or as permitted by applicable law. You may send unsubscribe requests or withdraw your consent at any time. Please visit the section Your Rights and Choices to learn more.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Please visit the page Cookie Policy  for information on how you can opt out of target advertising.

3. How We Share, Disclose And Transfer Your Information

3.1 Sharing

We may share your personal information that we collect or you provide as described in this Privacy Policy with third parties (as described below) in order to provide or improve our products or services, including offering products or services based on your requirements. This involves:

• Sharing that you actively choose or request. With your consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you.
• Sharing information within our group. In order to successfully conduct business operations and to provide you with all the functions of our products or services, we may share your personal information from time to time to our parent company, affiliates and subsidiaries globally when permitted by law, and necessary to provide you with our products and services.
• Sharing with third party service providers and business partners. We work with third party service providers to provide payment facilitation, shipping and delivery, application development, traffic monitoring or analysis, electronic messaging, data storage and other services for us. We require these service providers to use or disclose the information they process on our behalf, only as necessary to perform services on our behalf or comply with legal requirements.
• Sharing with third party marketing and advertising organizations. With respect to website cookies, we share your information with third party marketing and advertising partners to market our Services on our Website and other websites that you may visit. Please visit the page Cookie Policy   to learn more about cookies and our practices.

3.2 Disclosure

We will not disclose the information that we collect through our Service to third parties except as described in this Privacy Policy as follows or as we disclose to you at the time the information is collected:

• Any information that you voluntarily choose to make publicly available by uploading it to a publicly accessible site or venue using our Service, or that you otherwise elect to make public, will be available to anyone who has access to that content, including other users.
• We may preserve and disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or enforceable request, or is necessary to enforce or apply our Terms of Use and other types of policies and agreements by which you agreed to be bound.
• We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activities, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of our products and services and any facilities or equipment used to make our products and services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
• Information about our users, including information you provided and any information collected through our Service, may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.
• We may make certain aggregated, de-identified, or non-identifying information about users of our products and services available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) product safety analysis; or (iv) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality of our products and services.

3.3 Transfer

By default, we will not transfer your personal information to any company, organization or individual unless we obtain your express consent. However, we may transfer your data to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Narwal’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Narwal about our Service users is among the assets transferred. In any such transfer of information, your Personal Information will remain subject to this Privacy Policy unless and until changes are made to the Policy, which will be communicated to you in a reasonably timely manner.

3.4 International Transfer

Information we collect from you may be processed in and may be stored, transferred to, and processed in other countries/regions where we have facilities or in which we engage service providers. These countries may be outside your country of residence and may have different data protection laws than your country.

For EU/EEA Users

The European Commission has decided that some countries/regions provide an adequate level of protection. We rely on the Commission’s decision with regard to the transfer; or

For some of these transfers, we are providing appropriate safeguards such as Standard Contractual Clauses, as according to Article 46 of the GDPR.

4. Your Rights and Choices

The GDPR provides consumers (EU/EEA residents) with specific rights regarding their personal information. This section describes your GDPR rights. To exercise any of these rights, you may contact us using the contact details provided in the section Contact Information below.

• Access to Personal Information — You have the right to obtain confirmation from us that we process your personal information and, if so, you may have the right to request access to your personal information.
• Rectification of Personal Information — You have the right to request that we rectify inaccurate personal information concerning you and, depending on the purposes of the processing, you may have the right to have incomplete personal information completed.
• Erasure/Deletion — You have the right to request us to erase some or all of the personal information concerning you. You can delete all your personal information relating to the device stored on the could server of Narwal via “Device Authorization Canceled”. As a Main Account Holder, you can withdraw your consent to your authorization of the IoT Product via “Device Settings”-“Device”-“Privacy Settings”-“Device Authorization Canceled” on Freo APP, after which the data stored on cloud servers will be erased. Please note that such device authorization withdrawal will not lead to deletion of data stored locally on your IoT Product, which you can delete by pressing the RESET button on the Robot.
• Deletion of Account — You have the right to request us to delete your Narwal account. You can log in to the Freo APP and click “Profile”-“Settings”-“Cancel Account”, after which we will stop providing you with products or services and delete your personal information, unless otherwise provided by laws and regulations.
• Restriction of Processing — You have the right to request us to restrict the further processing of your personal information. In such cases, the respective information will be marked as restricted, and may only be processed by us for certain purposes.
• Object to Processing — You have the right to object, on grounds relating to your particular situation, to the processing of your personal information by us, and we may be required to no longer process some or all of your personal information.
• Object to Direct Marketing — You have the right to object to the processing of personal information for direct marketing purposes. If you do not want to receive any of such newsletters, marketing or promotional materials from us, please follow the unsubscribe instructions provided in the email we send, or you can contact us using the contact details provided in the section Contact Information below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).
• Object to Decision Based Solely on Automated Processing — You have the right not to be subject to a decision based solely on automated processing where the decision has a significant legal impact on you.
• Data Portability — You have the right to receive a copy of your personal information which you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to request the transfer of that personal information to another entity without hindrance from us.
• Withdraw Consent — You have the right to withdraw consent you have provided to us where we rely solely on your consent to process your personal information. You can always provide your consent to us again at a later time. Please note that the withdrawal will not affect the processing of data based on prior consent.
• The Right to Complain — You have the right to make a complaint to an applicable supervisory authority or other regulators if you are not satisfied with our responses to your requests or how we manage your personal information. A list of and more information about the EU/EEA Data Protection Authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

We encourage you to first or also reach out to us at privacy@narwal.com, so we have an opportunity to address your concerns directly.

5. Your California Rights and Choices

The CPRA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CPRA rights. To exercise any of these rights, you may contact us using the contact details provided in the section Contact Information below.

5.1 Access to Specific Information and Data Portability Rights

You have the right to request that the Company disclose certain information to you about our collection and use of your personal information over the past 12 months.

Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or sharing that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we disclose your personal information for a business purpose, we will identify the personal information categories that each category of recipient obtained.

5.2 Deletion Request Rights

You have the right to request that the Company delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

5.3 Personal Information Sales Opt-Out Rights

California consumers have the right to opt out of the sale of the consumer’s personal information. Narwal does not sell your personal data to third parties. However, under the CPRA, some sharing of personal information necessary to provide you with personalized ads may be considered a “sale,” even if no money is exchanged, such as our use of cookies and other similar automatic data collection technologies (e.g. pixels, etc.). You may learn more about how to opt out of such personalized ads through our Cookie Policy  .

Please note that if you are 16 or older, you have the right to direct us not to sell your personal information at any time (the “right to opt-out”).

5.4 Processing of Sensitive Personal Information Opt-out Rights

We do not knowingly process your sensitive personal data for purposes other than those listed in this Privacy Policy and part of the provision of our services, which you have authorized.

Please note that if you are 16 or older, you have the right to direct us not to sell your personal information at any time (the “right to opt-out”).

5.5 Non-Discrimination

We will not discriminate against you for exercising any of your CPRA rights. Unless permitted by the CPRA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for like-goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you with a different level or quality of like-goods or services.
• Suggest that you may receive a different price or rate for like-goods or services or a different level or quality of like-goods or services.

5.6 Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website, App, other products, services and platforms that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

6. Third-Party Services

Our Service may contain features or links to websites and services provided by third parties. Any information you choose to provide on third-party sites or services, or any information otherwise collected by such third-party sites or services is collected directly by the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through our Service.

We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through our Service. If you opt in to use such third-party services, please be sure to check the privacy policies of these sites as well as their “Terms of Use” or similar terms before engaging in any business or uploading any information.

7. Data Retention and Security

We will retain your personal data, including any correspondence you have with us, only for as long as necessary for the purpose of this Privacy Policy, including retaining personal data in order to comply with our legal obligations, to resolve disputes, for information security purposes, and to enforce our legal rights, terms and policies.

We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. We implement a variety of security measures to maintain the safety of your personal information when you enter, submit, or access your personal information. For example, when possible, we use encryption to transfer and store data. We further limit access to this data using access controls and confidentiality commitments.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Service, like message boards. The information you share in public areas may be viewed by any user of the Service.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Service. Any transmission of personal information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in the Service.

8. Children’s Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website/App. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacy@narwal.com.

9. Changes to Our Privacy Policy

If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Website home page or through a notice in the first screen of the App. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Service and this privacy policy to check for any changes.

10. Contact Information

If you wish to contact us or have any questions about or complaints concerning this Privacy Policy and our privacy practices, please contact us at the following contact details:

Mail Address: Room A2901, Yunzhongcheng, Building 1, Vanke Yuncheng VI, Dashi 2nd Road, Xili Community, Xili Street, Nanshan District, Shenzhen, Guangdong, China

Attn: Legal & Compliance Department

Email Address: privacy@narwal.com