Privacy policy

Effective date: June 25, 2021

Belun Technology Company Limited (“us”, “we”, “our”, or “Belun”) provide and operate, including but not limited to, the beluntech.com website, products, cloud platform, hardware, software, mobile applications, application program interfaces (APIs), and firmware of Belun.

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy shall have the same meanings as in our Terms and Conditions.

Definitions

In this Privacy Policy, unless the context otherwise requires or expressly provides, the following words and expressions shall have the respective meanings attributed to them:-

Service

Service means the beluntech.com website, products, cloud platform, hardware, software, mobile applications, APIs, and firmware provided and operated by Belun.

 

Personal Data

Personal Data has the meaning ascribed to it under the heading Personal Data herein below.

 

Usage Data

Usage Data is the data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

 

Cookies

Cookies are small files stored on your device (computer or mobile device).

 

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

 

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the Personal Data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your Personal Data more effectively.

 

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Unless the context otherwise requires, words importing the singular only shall include the plural and vice versa; words importing natural persons shall include corporations and unincorporated associations and vice versa; words importing the masculine gender only shall include the feminine gender and the neuter gender and vice versa.


Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • Name
  • Password
  • Gender
  • Nationality
  • Date of Birth
  • Height
  • Weight
  • Time zone
  • Preferred Language
  • Profile Picture (Optional)
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you if you have explicitly allowed us to do so. You may opt-out of receiving any, or all, of these communications from us by contacting us as mentioned in the last section “How to Contact Us”.

Other Personalized Information

To improve your experience on the Service, you may provide us with some additional information, such as whether you snore, whether you often feel tired in the daytime, whether others notice you may stop breathing while you sleep, and some of your habits, like smoking and/or caffeine intake. You may also let us know if you have regular medications or exercises. You may also provide us with information about your workouts and physical training. We collect such information to assist you in monitoring your sleep health.

Information Exchanged with Partners

We reserve our right to partner with any third-party services and/or data providers, including but not limited to Clinical Consultation Services, Belun distributors and insurance companies.

  • Such services and data providers reserve their right to collect and deliver to us your information including but not limited to your Personal Data and a unique identifier. The unique identifier is a string of characters and Belun is unable to use it as an identity.
  • In the event that you access to or obtain our applications, devices, or products, or subscribe Belun Service via any of the third-party service and data providers, the Belun account and information collected from Belun applications and devices are associated to the unique identifier. They are sent back to the service and data providers which you have authorized their access to your information, and not to any others.
  • The third-party services and data providers are entitled to retain the information according to their own privacy policies and terms of use.

 

Data Collected when using our Websites, Applications, Devices, Products, and Services

 

Personal Metrics

Our devices collect data including but not limited to pulse rate, SpO2 level, sleep stage, time to start sleep, sleep duration, and motion intensity.  The data collected may differ slightly depending on the model and type of device used.  We shall use our best endeavor to ensure the accuracy of the data collected in order to assist you in monitoring your daily activities and sleep quality.


Usage Data

We reserve our right to collect all the information that your browser or device sends whenever you visit our Service or access the Service by or through a mobile device (“Usage Data”).

This Usage Data consists of information including but not limited to your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service with a mobile device, this Usage Data, whereas, consists of information including but not limited to the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.  The collection of the Usage Data assists us to provide you with the right setup and services, such as product updates, and device pair-up.

Location Data

We reserve our right to use and store information about your location subject to your permission (“Location Data”).  “Location Data” include, without limitation to, your IP address, GPS, Wi-Fi access points obtained from your signed-in device.  We use this data to provide and update the features of our Service, to improve and customise our Service according to your approximate location, and send you ads or information, including but not limited to, the closest clinical service providers with Belun devices available.

You are entitled to enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activities on our Service.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.
  • Advertising Cookies. Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

Use of Data

Belun uses the Usage Data for the following purposes, including but not limited to:

  • to provide, maintain, and develop our Service;
  • to notify you about changes to our Service;
  • to provide you with a platform to review and monitor your sleep health and related daily activities;
  • to allow you to participate in interactive features of our Service when you choose to do so;
  • to provide customer support and maintain daily operations;
  • to gather analysis or valuable information so that we can improve our Service;
  • to monitor the usage of our Service;
  • to detect, prevent and address technical issues;
  • to provide you with news, events, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  • to comply with legal obligations; and
  • to protect the rights and enforce the Terms of Use of Belun.

 

Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Belun may process your Personal Data because:

  • we need to perform a contract with you;
  • you have given us permission to do so;
  • the processing is in our legitimate interests and it is not overridden by your rights;
  • for payment processing purposes; and/or
  • to comply with the law.

Retention of Data

Belun will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes (if any) and enforce our legal agreements and policies.

Belun will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside Hong Kong and choose to provide information to us, please note that we transfer the data, including Personal Data, to Hong Kong and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Belun will use our best endeavor to take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure of Data

If You Authorize or Ask Us to Share

We shall only share your personal information with parties outside of Belun, only if you have authorized us to do so.  We may share your personal information, such as your name and email, to a third party clinical service provider for the purposes set out in this Privacy Policy only with your explicit consent.  Once your information is shared with the third party service providers, your information will be regulated by their corresponding privacy policies and terms of use.

With Belun Authorized Administrators

If your Belun account is managed by Belun authorized administrators, such as Belun distributors, clinical consulting and insurance companies, they will have access to your Belun account and they may:

  • change your account information, including privacy settings;
  • access and retain information stored in your account, such as your sleep reports;
  • control your access right to delete or update your information and/or privacy settings;
  • suspend or terminate your account; and
  • obtain your account information in order to comply with applicable law, regulation, legal process or governmental request.


For External Service Providers

We send personal information to our business subsidiaries, affiliates, service providers, and other trusted business partners (providing us with services such as software development, marketing, and customer surveys and support) who process the information or work on behalf of us, according to our instructions, and in compliance with this Privacy Policy, and any other appropriate security and confidentiality measures.

Business Transaction

If Belun is involved in a merger, acquisition or asset sale, your Personal Data may be transferred to the relevant new entity or third party. We will ensure confidentiality of your personal information, and provide advance notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Belun may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities, including but not limited to a court or a government agency.

Legal Requirements

Belun may disclose your Personal Data in the good faith believing that such action is necessary:

  • to comply with a legal obligation, litigation, regulation, legal process, or governmental request within or outside of your country of residence;
  • to protect and defend the rights or property of Belun, or to enforce our terms of use;
  • to prevent or investigate possible wrongdoing, fraudulence, or address security issues in connection with the Service;
  • to protect the personal safety of users of the Service, Belun operations, or the public; or
  • to protect against legal liability.

 

Non-personally Identifiable information

We may share non-personal information, which cannot be used to identify any individual or is aggregated, with the public and third parties, such as our business partners.  The information can be used to, for example, show trends in sleep or health-related activities.

 

Security of Data

The security of your data is important to us but as no method of transmission over the Internet or method of electronic storage is 100% secure. While we always strive our best endeavor to protect your Personal Data by various means, technologies and practices, we cannot guarantee its absolute security.

 

Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Belun aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us in writing.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you.

You can access or update your personal information such as your name, email address, password, gender, nationality, date of birth, height, weight, time zone, and preferred language in User Profile under Settings of your account.  You can also remove the optional personal information there any time.

If you need to delete your personal information or account, you can write us an email, indicating clearly your intention and what information you wish to delete, and send it to our email contact as mentioned in the last section “How to Contact Us”.  Please allow us up to 45 working days to process your request upon receiving your email.

If you wish to delete your account, apart from the 45 working days processing time, it may take an addition of up to 90 days to delete your personal information and account completely from our systems due to the complexity of system architecture.  We may retain your data if it is necessary for compliance with a legal obligation or for reasons of public interest, as described in the section “When Your Information is Shared”.

 

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

 

The right to object. You have the right to object to our processing of your Personal Data.

 

The right of restriction. You have the right to request that we restrict the processing of your personal information.  However, this will not affect the lawfulness of the processing of your information before your request.  Please note that we may not be able to provide you with some product features or services after the restriction.

 

The right to data portability. Some of your personal information, such as heart rate, SpO2 level, sleep stage, time to start sleep, sleep duration, and motion intensity can be exported from Sleep Summary Report.  You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

If you need to export personal information other than the above mentioned, or if you need to delete your personal information or account, you can write us an email, indicating clearly your intention and what information you wish to export or delete, and send it to our email contact as mentioned in the last section “How to Contact Us”.  Please allow us up to 45 working days to process your request.  If you require more than one copy of your personal information, Belun may charge a reasonable administration fee.

 

The right to withdraw consent. You also have the right to withdraw your consent at any time where Belun relied on your consent to process your personal information.

For your security concern, if you request Belun to export your information or delete your account, Belun may require you to prove your identity, such as by providing your passport number, or a copy of your identity card issued by your local government, before providing you with the requested information or deleting your account.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Please refer to the last section “How to Contact Us” if you wish to contact us to exercise any of the above rights.  Please note that these data protection rights under GDPR do not apply to you if you are not subjected to the European Union (EU) law.

 

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

Children’s Privacy

Our Service does not address anyone under the age of 13 (“Children”).

Children under the age of 13 are not allowed to create Belun account unless with the consent from their parents.  If Belun becomes aware that a person under 13 has provided Personal Data to us without parental consent, Belun will take steps to remove that information as quickly as possible. If you are a parent or guardian, who realize that your child is using Belun, and you wish to delete your child’s account, please contact us as indicated in the last section “How to Contact Us”.

When your child turns 13, or any higher minimum age as required by applicable law in your country for creating Belun account without parental consent, the child will be eligible to manage his or her own account.  If your child chooses to manage his or her Belun account, you will no longer have access to, or be able to exercise control over his or her account.

 

Changes to This Privacy Policy

Belun has the final discretion over the interpretation of this Privacy Policy. Belun reserves the right to update, revise, supplement, modify or amend this Privacy Policy in the following manner at any time as Belun deems necessary and Users are strongly recommended to review this Privacy Policy frequently. If we decide to update, revise, supplement, modify or amend this Privacy Policy, we will post the changes to this webpage and/or other places we deem appropriate so that Users would be aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

If we make material changes to this Privacy Policy, we will notify Users on this webpage, by email, or by means of a notice on our Service and update the “effective date” at the top of this Privacy Policy.

We may update our Privacy Policy from time to time.  You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.


How to Contact Us

If you have any question about this policy, wish to report a complaint or if you feel that Belun has not addressed your concern in a satisfactory manner, you may contact us:

  • By email: privacypolicy@beluntech.com
  • By visiting this page on our website: https://www.beluntech.com/privacypolicy
  • By mail: Legal Department, Belun Technology Company Limited, Unit 218, 2/F, Core Building 2 No. 1 Science Park West Avenue Hong Kong Science Park, Shatin, N.T., Hong Kong

 

If there are discrepancies between the English version and the versions in other languages, the English version shall apply and prevail.

In the event of dispute, the decision of Belun shall be final.