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Our Privacy Policy took effect on February 27, 2024. From this date onwards, this Privacy Policy will provide privacy details on how we manage your personal information for Module21 products and services. Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.
Introduction
MODULE 21 FILTERS & PURIFICATION DEVICES TRADING L.L.C (hereinafter referred to as "Module21", "we", "our", or "us") highly value your privacy. M21 is a smart device control and management platform provided to you by Module21.
We are committed to protecting your privacy. This Privacy Policy sets out the principles on which M21 operates, and constitutes an important part of Module21 Privacy Policy.
This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to us. This Privacy Policy explains how we collect, use, disclose, process, and store any information that you give us when you use M21. Under this Privacy Policy, "personal information" means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information about that individual available to us. We will use your personal information strictly following this Privacy Policy.
Ultimately, what we want is the best for all our users. Should you have any questions about our data handling practices as summarized in this Privacy Policy, please contact us via info@module21.com to address your specific concerns. We will be happy to hear from you.
1. What information we collect and how we use it
1.1 Personal information that we collect and use with your authorization
Personal information is collected in order to provide you with products and/or services as well as to ensure legal compliance on our part with applicable laws, regulations, and other regulatory documents. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our products or services or respond to your queries. Features and services that may need to collect your personal information include:
1.1.1 Connecting smart devices
In order to provide you with M21 services and allow you to securely connect to and manage smart devices, we may collect your Wi-Fi information, location information, account sign-in information, and information related to your mobile phone, smart devices, and M21 Account. This information will be used to provide you with features including pairing with and connecting to smart devices, discovering nearby devices, and device management.
In detail:
— Account sign-in information: M21 Account ID, nickname, and profile photo.
— Mobile phone-related information: Hardware-based identifiers (MAC address, Android ID, Apple ID), phone model, system version, system language, country or region, App Store version, screen size and resolution, CPU, and display-related information.
— Based on the type of the smart device, we may collect the following information when connecting to a smart device:
— Smart devices connected via Wi-Fi: Wi-Fi information (SSID, BSSID, MAC address of Wi-Fi, Wi-Fi password), MAC address of the device, and device ID.
— Smart devices connected via Wi-Fi after the establishment of a Bluetooth connection: Wi-Fi information (SSID, BSSID, MAC address of Wi-Fi, Wi-Fi password), MAC address of the device, and MAC address of Bluetooth on the device.
— Smart devices connected via Bluetooth: MAC address of Bluetooth on the device, and device ID.
1.1.2 Using smart devices for home management
We may collect information that you provide relating to room settings for smart devices in order to facilitate smart home management. This allows you to enjoy greater convenience when using smart devices (for example, when using multiple Module21 products, being able to quickly identify the air quality in a multiple rooms).
1.1.3 Device sharing
We provide support for you to share smart devices with others through your M21 Account. Sharing a smart device with someone else allows them to also control the device. In order to provide this feature, we may collect your M21 Account ID, the ID of the person with whom you wish to share access, and shared device information (including device ID, device name, device verification key, and sharing status of device). We use this information to let you share device control and usage with the accounts of other M21 users as well as to display the device's sharing status on the devices page in the M21 app.
1.1.4 App and smart device updates
To ensure you can continue enjoying the latest M21 services, we may use the version information of your M21 app and phone model in order to provide you with updates to the app. We may also collect a list of your connected smart devices and associated version information in order to provide you with smart device updates, including firmware updates.
1.1.5 Smart scenes (smart device connections)
We provide support for you to configure specific rules to establish connections between devices under specific conditions, thereby creating smart scenes. To provide this feature, we may collect your location information, smart scene rule configurations, and designated device status. This allows specific device functions to be executed according to the commands you give. An example would be allowing a Module21 Product to turn on whenever a sensor detects the air quality is less than defined by you limit. Please rest assured that this feature won't be turned on without your express consent and rule configurations.
1.1.6 Provision of content-related support (in some regions only)
To help you make better use of your smart devices, we will provide you with selected articles and audio about our devices. When you view these articles, we will not collect any information from you.
1.1.7 Dashboard
We've set up a dashboard module on the app's Home page to display the status of your devices. This dashboard will display device security, issues, and consumables, environmental temperature and humidity, and other device-specific information. If your devices don't support the display of this information, your dashboard will display the local weather instead. To provide weather features, we will collect the home location you set or the IP location of your Wi-Fi devices.
1.2 Personal information you may choose whether to authorize us to collect and use
In order for you to enjoy better control and management of smart devices provided by Module21, we may collect and use your personal information to provide the following additional features. If you do not provide these types of personal information, you can still use the basic services of M21, but you may not be able to use additional features. These additional features include:
1.2.1 User feedback
We may collect feedback from you on issues that you report to us, feedback logs, and any phone numbers or email addresses that you provide to us. This information will be used to help us better understand any problems you encounter as well as to allow us to contact you.
1.3 Personal information obtained from third parties
Under certain conditions permitted by law, we may obtain your personal information from a third party. To be able to use this feature, configure rules and add smart scenes. You can also turn this feature on or off on the devices page.
1.4 Non-personally identifiable information
We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service, such as including clicks, page redirects, and browsing time. The purpose of such collection is to improve the services we provide to you.
2. Sharing your personal information with third-party service providers
We do not sell any personal information to third parties. To help us provide you with products and services described in this Privacy Policy, we may, where necessary, share your personal information with our third-party service providers and business partners. Module21 will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. The location-based services component of our services is provided by third party providers. In order to offer you location-based services, we may provide information such as your device identifier information to any of these service providers. If we share your personal information with such third parties, we will take appropriate measures to ensure the security of the processing of your personal information, including but not limited to the encryption of your personal information. We will reasonably examine the data security environment of the companies and organizations with which we share personal information and sign data processing agreements with them. We will require third parties to take sufficient measures to protect your information and strictly abide by the relevant laws and regulations as well as regulatory requirements.
3. Retention policy
We will retain personal information for the period of time needed to fulfill the purpose for which it was collected as described in this Privacy Policy, or in order to comply with applicable legal requirements. We will cease to retain your personal information and will delete or anonymize it once the purpose of collection is fulfilled, or after we confirm your request for deletion or cancellation, or after we discontinue the corresponding product or service. We will continue to retain relevant information in accordance with applicable laws even if further information processing is unrelated to the original purpose of collection, provided that doing so would be in the public interest or for scientific or historical research or statistical purposes.
4. Your rights
4.1 Controlling settings
Module21 recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways M21 makes available for you to choose to restrict the collection, use, disclosure, or processing of your personal information and control your privacy settings: Allow or deny location access and other access permissions on your phone;
— Modify personal information such as your nickname or profile picture;
— Turn connections between smart devices on or off;
— Sign in or out of the M21 Account.
If you have previously agreed to us using your personal information for the aforementioned purposes, you may change your mind at any time by writing to us or contacting us on info@module21.com.
4.2 Your rights to your personal information
Depending on applicable laws and regulations, you have the right to access, rectification, and erasure of personal information that we hold about you (hereinafter referred to as "the request").
You may also access and update the details relating to the personal information in your M21 Account at http://account.module21.com or by signing into your account on your device. For additional information, please write to us or contact us via https://module21.com/support. It will help us to process your request most efficiently if it meets the following conditions:
— The request is submitted through Module21's exclusive request channel detailed above and for the protection of your information security, your request should be in writing (unless the local law explicitly recognizes the oral request);
— You provide sufficient information to enable Module21 to verify your identity and ensure that you are the data subject or legally authorized to act on the data subject's behalf.
— Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws. In detail:
— Based on the requirements of applicable laws, a copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra requests for relevant information, we may charge a reasonable fee based on actual administrative costs according to and if permitted by the applicable laws.
— If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed based on the purpose of use.
— Based on the requirements of applicable laws, you may have the right to request the deletion or removal of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. Please note that we may not be able to immediately remove the information from the backup system due to applicable legal and/or technological limitations. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be deleted or made anonymous.
— We have the right to refuse to process requests that are not meaningful, manifestly unfounded or excessive, requests that damage others' right to privacy, extremely unrealistic requests, and requests that require disproportionate technical work, as well as requests not required under local law, regarding information that has been made public, and regarding information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, the request may also be rejected.
4.3 Withdrawal of consent
— You may withdraw your consent for the collection, use, and/or disclosure of your personal information in our possession or control by submitting a request. You may contact us regarding relevant requests by visiting https://module21.com/support, based on the specific service you are using. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use, and/or disclose your personal information as per your request.
— Please note that your withdrawal of consent may result in certain legal consequences. You may not be able to continue receiving the full benefit of Module21's products and services, depending on how much authority you grant us to process your information when you use M21. The withdrawal of your consent or authorization will not affect the validity of our processing carried out on the basis of the consent up until the point of withdrawal.
4.4 Cancellation of services
If you wish to cancel a specific product or service, you can do so via https://module21.com/support. If you wish to cancel the M21 Account, please note that the cancellation will prevent you from using the full range of Module21 products and services. To protect your or others' legitimate rights and interests, we will judge whether or not to support your request for cancellation based on your use of various Module21 products and services. For example, if there still exist monies outstanding on your account, we cannot immediately support your request.
5. How your personal information is transferred globally
Module21 processes and backs up information through a global operation and control infrastructure. Currently, Module21 runs data centers in United Arab Emirates and Russia. For the purposes of this Privacy Policy, your information may be transferred to these data centers according to applicable laws.
We may also share your personal information with third-party service providers and business partners, and thus your information may also be transferred to other countries or regions. The jurisdiction of these facilities worldwide may not implement the same personal information protection standards as in your jurisdiction. Risk may exist depending on different data protection laws. However, this does not change any of our commitments to comply with this Privacy Policy and safeguard your personal information.
In detail:
— The information that we collect and generate in operations within the territory of the United Arab Emirates is stored in data centers located in the United Arab Emirates, except for cross-border transmissions as permitted by applicable law.
To the extent that we may need to transfer your personal information outside of your jurisdiction, whether to our affiliated companies or third-party service providers, we shall do so in accordance with the applicable laws. We will ensure that all transfers will be carried out in accordance with requirements under your applicable local data protection laws by putting in place consistent and appropriate safeguards. You are entitled to information about the security mechanisms we implement. You can enquire about these mechanisms by contacting us on https://module21.com/support.
If you use our products and services in the area of the European Economic Area (EEA), Module21 shares personal data originating from you in the EEA to a Module21 entity or a third party service provider outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR. You can contact us on https://module21.com/support to request a copy of your personal information that we hold.
6. Third-party websites and services
Our Privacy Policy does not apply to products or services offered by third parties. Depending on your choices, M21 may include third-party products or services, such as location and positioning services. Some will be provided in the form of links to third-party websites, and some will be accessible in the form of SDKs or APIs. Third parties may collect your information when you use such products or services. For this reason, we strongly suggest that you take the time to read the third party's privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.
The following are the examples of which third party terms and privacy policies may apply when you use the specific products or services listed above:
Third-party sharing features:
— Facebook Privacy Policy (only terms regarding shared features)
— WhatsApp Privacy Policy (only terms regarding shared features)
7. Contact us
If you have any comments or questions about this Privacy Policy or any questions relating to Module21's collection, use, or disclosure of your personal information, contact us via https://module21.com/support or at the address below. Please include "Privacy Policy" in your contact message. When we receive privacy or personal information requests about accessing or downloading personal information, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information. If you are not satisfied with the response you received, you can hand over the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.
Address:
United Arab Emirates, Dubai, Al Murar - Deira - Abu Bakr Ahmed Obaid bin Touq Al Marri Bldg. A3 - Office 204