NEXRING PRIVACY STATEMENT

ABOUT THIS PRIVACY STATEMENT

At Linktop, we take the protection of your personal data seriously. This privacy statement applies to processing of personal data by Xiamen Linktop Technology Co.,LTD (collectively, "Linktop").

 

Our products, like the NexRing, enable you to track your lifestyle choices and the quality of your sleep. We understand that data does not get much more personal than this, and the protection of your personal data is of paramount importance to us. Please take a moment to carefully review this statement.

 

WHY DOES LINKTOP PROCESS YOUR PERSONAL DATA?

Through the headings below, we will explain the categories of personal data we collect and process, as well as the reasons we do so, such as to provide you with services when you visit our website, make purchases on our Site, and use your ring and app. You will also find information on our legal basis for processing your data, and our data sources.

 

Device & Application Users

Linktop collects and processes the personal data of Device & Application Users ("Users") only for the following purposes:

 

• To provide NexRing services

We process personal data to provide NexRing services and app features, such as to provide you with daily insights about your readiness and sleep.

 

• To provide customer service

We process personal data for the purpose of providing customer service and managing our customer communication. If you contact our support with questions regarding your app data, we may use the provided information to answer your questions and for solving any issues you may have.

 

• To develop our products and services

We process data regarding your use of the NexRing and platform to improve our services and features, such as in the NexRing app. When possible, we will do this using only pseudonymized, aggregated, or non-personally identifiable data.

 

• To market our products and services

We process marketing-related data to provide online advertising and Linktop marketing communications. For example, as explained more fully in our Cookie Policy, we use cookies on our website in order to create targeted audiences for online advertisement. You can always opt out of marketing communications, and we will only send you our newsletter if you have requested it.

 

• To enable third party integrations

We process data to provide Users who request that we share their data with certain third parties, such as research partners. This is only done with your express consent.

 

• To comply with statutory obligations

In certain cases, we must process certain data when it is required by applicable laws and regulations. Such statutory obligations are related, for example, to accounting and tax requirements, legal claims, or other legal purposes.

 

Legal Basis For Processing

Data protection law in Europe requires a "lawful basis" for collecting and retaining personal information from residents of the European Economic Area. Our lawful bases for processing your data depends on the particular processing purposes, including:

 

Contract: when processing personal data for the purpose of providing NexRing services we process it on the basis of a user contract, which is formed when you create your account and accept of our terms and conditions.

 

Consent: we process your health-related data only with your consent. In some cases, you can provide your consent to us for processing your data through your actions, such as by inserting health data into your notes, or by adding health related tags in the NexRing app.

 

Legitimate Interest: we process your personal data based on our legitimate interests when we process it for the purposes of marketing our products and services, providing our customer service and improving our products and services. When choosing to use your data on the basis of our legitimate interests, we carefully weigh our own interests against your right to privacy, in compliance with applicable law.

 

Legal obligation: Linktop must process certain information to comply with statutory obligations which may vary in each country. For example, such obligations can relate to consumer protection or tax laws.

 

Processed Data and Data Source

In most cases, Linktop collects personal data directly from you, such as when you register for an account or use your ring to collect measurement data via the tracking functions of Linktop ring. We may also process data that is produced from the information you provide to us.

 

Linktop processes the following personal data categories about device and application Users:

 

Contact information such as email address or physical address.

User information such as gender, height and weight, User ID, and other information you may provide to us about yourself or your account.

Device information such as IP address and location data.

User context information such as notes and tags.

Measurement data such as heart rate, movement data, and temperature data.

Calculated user sleep data such as sleep phases (deep, light, REM, awake), readiness level, body mass index (calculated based on height and weight).

Please note that some of the personal data we process, including any data concerning your health, is considered special or sensitive personal data. Under applicable law, such data is processed only if you have given your consent for processing. If you access or use any of NexRing's location-based services, such as by enabling GPS-based activity tracking through your app, NexRing may process the approximate or precise location of your device while the service is active. This data may be obtained via your device's service provider network ID, GPS, and/or Wi-Fi data. Linktop does not process such location data without first obtaining your consent. You may disable such location processing at any time using your device's location permission settings.

 

DATA SHARING AND DISCLOSURES

Personal Data Sharing

Linktop does not sell or rent your personal information, and only shares your personal data with certain trusted service providers so that we can provide you with our services and operate our business. Whenever we share data with third-party service providers, we require that they use your information only for the purposes we've authorized, and for the limited reasons explained in this Privacy Statement. We also require these service providers to protect your personal information to at least the same standards that we do.

 

Like most companies, Linktop uses service providers for purposes such as:

 

• providing and improving our online service platform.

• storing our users' data.

• providing customer services.

• managing and organizing our marketing activities. Linktop only shares website usage data with our advertising network partners for the purposes of analyzing and optimizing our marketing. Linktop does not share the NexRing app data with 3rd party advertisers).

• analyzing information regarding the use of our online service to improve our service quality.

Linktop stores personal data primarily within the geographic region where it is collected. In cases where personal data is processed outside of the area in which it was collected, we always ensure your personal data is protected with appropriate safeguards in accordance with applicable privacy laws. We also use industry standard data protection measures to safeguard all international transfers of personal data through data protection agreements with our service providers.

 

Personal Data Disclosures

We also reserve the right to disclose personal information under certain specific circumstances, including:

 

• When we have your express consent to do so.

• When it is reasonably necessary for our legitimate interests in conducting our business, such as in the event a merger, acquisition, or sale.

• To protect Linktop's legal rights and property.

• To comply with the law or law enforcement.

Otherwise, your personal information is never shared with any individual or other organization.

 

SAFEGUARDING YOUR DATA

Linktop uses technical and organizational safeguards to keep your data safe and secure. Where appropriate, these safeguards include measures such as anonymization or pseudonymization of personal data, strict access control, and the use of encryption to protect the data we process.

 

We also ensure that our staff receives adequate training to ensure personal data is processed only in accordance with our internal policies, consistent with our obligations under applicable law. We also limit access to your sensitive personal data to personnel that have specifically been granted such access.

 

We update the NexRing app and the ring firmware regularly. We recommend that you make sure that you always have the latest app and firmware versions installed in order to maximize protection of your data.

 

DATA RETENTION

The retention period for your personal data generally depends on the duration of your NexRing account lifecycle. Your personal data will be deleted when it is no longer needed for the purpose it was originally collected, unless we have a legal obligation to retain data for a longer period of time. For example, your measurement data regarding your sleep and readiness is stored only so long as your NexRing account is active.

 

Linktop also has legal obligations to retain certain personal data for a specific period of time, such as for tax purposes. These required retention periods may include, for example, accounting and tax requirements, legal claims, or for any other legal purposes. Please note that obligatory retention periods for personal data vary based on the relevant law.

 

If you wish, you may request deletion of your NexRing account by contacting service@linktop.com

 

YOUR RIGHTS AS A DATA SUBJECT

Whenever Linktop processes your data, you have certain rights that enable you to control how your personal data is being processed. This section provides you with information about each of those rights. If you wish to exercise your rights as a data subject, please contact service@linktop.com with your request to do so.

 

Right to access data

You have the right to know what personal data is processed about you. You may contact us to request access to the personal data we have collected about you, and we will confirm whether we are processing your data, and provide you with information about the personal data we have collected and processed about you.

 

Please note that by using the NexRing App, you can easily access the sleep and readiness data that we process about you.

 

Right to erasure

You have the right to request the deletion of your personal data in certain circumstances. We will comply with such requests unless we have a valid legal basis or legal obligation to preserve the data.

 

Right to rectification (of inaccurate data)

You have the right to request correction of any incorrect or incomplete personal data we have stored about you.

 

Please note that you can correct and update some of your basic information via the NexRing App.

 

Right to data portability

You have the right to request receipt of the personal data you have provided to us in a structured and commonly used format. The right to data portability only applies when we process your personal data for certain reasons, such as by contract or by your consent.

 

Right to object to processing

You have the right to object to the processing of your personal data under certain circumstances. In the event that we do not have legitimate grounds to continue processing such personal data, we will no longer process your personal data after we have received and verified your objection. You also have the right to object processing of your personal data for direct marketing purposes at any time.

 

Right to restrict processing

You have the right to request that we restrict processing of your personal data under certain circumstances. For example, if you contest the accuracy of your data, you can make a restriction request that we do not process your data until Linktop has verified the accuracy of your data.

 

Right to withdraw consent

If we have requested your consent in order to process your personal data, you have the right to withdraw your consent for such processing at any time. It should be noted, however, that withdrawing your consent may lead to issues or restrictions on your ability to fully utilize NexRing services.

 

Please note that you can always unsubscribe from receiving our newsletter and other marketing emails by using the ‘Unsubscribe'-link provided in the emails you receive from us.

 

Linktop strives to address your privacy concerns. If you have contacted Linktop about your issue and are still unhappy with our response, subject to applicable law, you may contact your local supervisory authority regarding your issue. However, we urge you to first contact us at service@linktop.com so that we can more quickly resolve your issue before escalating the issue.

 

CONTROLLER CONTACT INFORMATION

Linktop is the data controller of user personal data processed for marketing purposes. The controller of personal data processed for all other processing purposes is NexRing. Please find our contact details below:

 

NexRing and Xiamen Linktop Technology Co.,LTD

Address: No.56-58,North 5F, Huoju Plaza, Huoju Road, Xiamen, China

Data Protection Officer: service@linktop.com

 

CHANGES TO THIS PRIVACY NOTICE

This Privacy Statement is effective as of July 20, 2022. We reserve the right to update this Policy from time to time at our sole discretion, but if we do, we'll let you know about any material changes either by notifying you on the website or by sending you an email or push notification. If you keep using NexRing services after a change, your continued use means that you accept any such changes.