WALTON PRIVACY POLICY

Introduction

Walton Digi-Tech Industries Limited highly values your privacy and is concerned about the confidentiality of personal information. This Privacy Policy (hereinafter referred to as "WALTON PRIVACY POLICY") is intended to explain your rights and how Walton Digi-Tech Industries Limited will collect, use, store, disclose and transfer your personal information. It applies to all services provided by Walton Digi-Tech Industries Limited through its official website, web application, and mobile application in software developed by it, and the functions have been included in these services. "WALTON TICK-V.2" and "we" hereinafter all refer to "Walton Digi-Tech Industries Limited". This policy will explain how and why our organization handles and protects your personal information under the laws & rules of privacy concern and how crucially important your personal information is to us.

This policy will help you understand the following:

This Policy Covers:

We are thoughtful about the personal information as we ask you to provide and the personal information that we collect about you through the operation of our services. As such Walton TICK-V.2 is an application software that accesses, collects, records, analyzes, and displays user sports training and health data of the Users. It is a supporting application based on our smart wearable products.

  1. During the use of this application, to provide a better smartwatch product service experience, we will ask for the following mobile phone permissions:

Under this policy Walton TICK-V.2 APP (or \we) respects and protects user information and treats it with a high degree of responsibility and care as confidential information. When you use the services provided by us, we collect, process, and disclose your information following this Privacy Policy. We want to give you a clear picture of how we handle your information through this Privacy Policy, so we recommend that you read this Privacy Policy in its entirety to help you understand how to maintain your privacy. If you have any questions, comments, or suggestions, you can contact us through the official website.

Why you should abide by this policy?

What kinds of Personal Information do we need & procedures for collection?

We aim for full transparency on how to gather, use and share your personal information. We may access, collect, use, store, transfer, and share, and disclose non-personal information for any justified & legitimate purposes (Subject to the applicable laws of the country). When you create an account on the web app, you must provide us with an entry for your name, email, mobile phone number, third-party login information as the key content of your login, and if you log in with your email or mobile phone number, we will send you a verification code for verification, as well as a verification of your login password. Your submitted email or mobile phone number is used to receive a verification code when you register, log in, bind your account, retrieve your password, and as one of the contact details, you specify with we to receive relevant business notifications (e.g. health reports, service changes, etc.).If you use a third login, such as Google and Facebook, we will apply to the corresponding third-party platform for authorization to obtain your nickname and profile picture with your consent to authenticate you. The content of your data that we obtain from third parties depends on the settings, permissions, and privacy policies controlled by the third party, and you should always take care to check the privacy settings and notifications in these third-party services to understand the data that may be disclosed to us or shared with our services.

After your registration for your web account, you can continue to fill in your information in the next process, including but not limited to your nickname, age, profile picture, height, gender, weight, unit of measure used, etc.

Provide you with technical services

In the course of your usage, you can contact our sales personnel at any time, or through the APP\'s built-in feedback feature, you can give us feedback on your difficulties in our services while filling in the email that can contact you, we will contact you promptly to provide support and services.

The information we collect during your use through APP is:

Please note that individual device information, user-health data, etc. are information that does not identify a particular natural person. If we combine such non-personal information with other information to identify or combine it with personal information, such non-personal information will be treated as personal information during the combined period of use and will be treated as anonymous and unidentified, unless authorized by you or otherwise provided by any specific law and regulation of the country.

Why We Use the user information submitted and collected for the following purposes:

We may use your data for a variety of business purposes, which we have set out below:

Other uses with your permission

If you purchase items products on our website, you will need to contact our sales personnel and may require your basic payment information, including your name, bank account number/debit card number, personal information such as your title, name, gender, date of birth, email address, postal address, delivery address (if different), telephone number, mobile number, payment procedure and another similar kind of information. We do not store this payment information. We store your shipping address to complete your order. Please note that third-party payment processors may retain this information following their privacy policies and terms, which may be different from us.

Why do we share or transfer personal information?

Sharing:

We do not share your user information with other organizations and individuals, except in the following cases:

Share with authorized partners

We may entrust trusted partners with the services, so we may share some of your user information with partners to provide better customer service and optimize the user experience. We will only share your user information for lawful, legitimate, necessary, specific, and explicit purposes, and only the user information necessary to provide the Services. Our partners do not have the right to use the shared user information for any other purpose except specified earlier by us.

Currently, our authorized partners include the following types:

The types of our partners are authorized distributors, service providers, and other partners relating to the products. We send information to authorized distributors, service providers, and other partners who support our business, including basic technical services, consulting, analytics, and other professional services. We may sign strict confidentiality agreements and information protection agreements with companies, organizations, and individuals with which we share user information, requiring them to process user information following our instructions, this privacy policy, and any other relevant confidentiality and security measures.

Transfer

Your personal information will be not transferred to any company, organization, or individual except for the following circumstances:

a. Having obtained your explicit authorization; your information will be transferred to other parties;

b. If Walton Digi-Tech Industries Limited deals with mergers, liquidation, and acquisition, we will require new companies and organizations that hold your personal information to continue to be bound by this policy. Otherwise, we will ask the companies or organizations to seek permission from you again.

Public disclosure

We will only publicly disclose your user information in the following case:

User motion data and public information

Unlike your user information, we will handle user motion data and public information as follows:

Public information

Public information is any information that you share publicly and that anyone can view or access during the use and non-use of our Service, such as the content of third parties where you have taken screenshots of the relevant pages of our App.

Management of user information

For user information management-related operations, to ensure data security and privacy, you need to contact us directly via \we \-\App Management\-\Feedback\. After receiving the information, our personnel will contact you by email and phone to prove your identity after that, we will process your request according to the actual situation.

How long do we relation/keep the personal information?

We generally discard information about you when it's no longer needed for the purposes for which we collect and use it --- described in the section above Why We Use the user information submitted and collected for the following purposes--- and we're not legally required to keep it. Based on our business needs and legal requirements.

Security of user information

We comply with reasonable industry standards to protect personal information both online and offline from loss, misuse, and unauthorized access, disclosure attention on destruction breaching the provisions of the consumer's rights protection act, we take commercially reasonable efforts to protect its value & customers personal data. We strive to protect your user information with reasonable physical, electronic, and administrative security measures. Protect stoic access, public disclosure, use, modification, corruption, or loss of user information. We use encryption to improve the security of user information, we use trusted protection mechanisms to protect user's information from malicious attacks, we deploy access controls to try to ensure that only authorized personnel has rights to access user information, and we conduct security and privacy training courses, to increase employee awareness of the importance of protecting user information.

We will take reasonable and feasible measures to avoid collecting irrelevant user information. After the above user information is retained, we will delete or anonymize your personal information.

Please use a complex password to assist us in keeping your account secured and safe. We will do our best to ensure the security of any information you send us, ensuring that your information is not lost, misused, and altered by security measures such as encrypting user passwords. If our physical, technical, or administrative protection facilities are damaged, resulting in unauthorized access, public disclosure, alteration, or destruction of information, resulting in damage to your legitimate rights and interests, we will be liable accordingly.

In the event of an unfortunate user information security incident (leakage, loss, theft, unauthorized disclosing, etc.), we will promptly inform you of following the requirements of laws and regulations:

the basic circumstances and the possible impact of a security incident, the actions we have taken or will take, recommendations for autonomous prevention and mitigating risk, your remedies, etc. We will promptly inform you of the incident-related situation by email, letter, telephone, push notification and so on, while it is difficult to inform the user information subject, we will take a reasonable and effective way to announce common procedure.

Meanwhile, we will also report the handling of user information security incidents following regulatory requirements.

We store user information collected in the territory of the China Mainland, Asia Pacific, and Europe America region. If personal information is transferred overseas due to business needs following applicable laws, we will obtain your consent in advance and inform you of the user information Purpose of exit, recipient, security measures, security risks, etc.

If our products and services cease to operate, we will take reasonable measures to protect the security of your user information, including timely stopping activities to continue to collect user information; suspension of operations will be notified to users in the form of one-on-one service or announcements; the personal information held will be deleted or anonymized.

We will inform you again and obtain your express consent before using the user information beyond its stated purpose in collecting the user information or beyond a range that has a direct or reasonable association.

Choices

You have several choices available when it comes to information about you:

What are your rights?

Following relevant Bangladeshi laws, regulations, standards, and common practices of other countries and regions, we guarantee that you can exercise the following rights to protect your personal information:

1. The right to access or correct your personal information

You have the right to access your personal information, except for exceptions stipulated by laws and regulations. The data are accessible in the following ways:

Your account information and all personal information uploaded to Walton Digi-Tech Industries Limited can be viewed via [User Information] at the user end of Walton Digi-Tech Industries Limited's products. You can also update your personal information in the same way.

2. The right to delete your personal information

You can request to remove user information from us in the following cases:

3. The right to respond to your mentioned-above requests

You can contact us via support@waltonbd.com in the following situation: If you cannot access, correct, or delete your personal information through the above-mentioned methods, or you need to access, correct, or delete other personal information generated by using our products or services, or you deem that Walton Digi-Tech Industries Limited's deeds are against laws and regulations or agreements regarding personal information collection. For safety concerns, we might need you to provide a written request or verify your identity in other forms. Your requests will be replied to within 30 days after we have received them and verified your identity.

No extra fees shall be charged for your reasonable requests. However, regarding repetitive and unreasonable requests, fees will be charged based on actual costs. Requests that are repetitive, unrealistic, involve too much technical means (for example, a brand new system is requested or radical changes have to be brought in), or might bring risks against others' interests will be rejected.

Your requests will be rejected in the following situations, if;

a. The requests are related to national security and national defense security;

b. The requests are related to public safety security, public health, and major public interests;

c. The requests are related to the criminal investigation, prosecution, trial, judgment execution, and the like;

d. There is solid proof proving that your request contains malice targets or abuse of rights;

e. Your request might result in damages to the interests of other individuals or organizations;

f. Your requests involve trade secrets, business and marketing plan, strategies, IPR Issues, Investment Info, Customer list, product pricing policy, design-software info etc.

Our policy towards children

(a) We attach great importance to protecting juveniles' information. If you are under 18 years of age, please seek your parents' or guardians' written permission before using our products and services. We will protect juveniles' information by following relevant laws and regulations of national & international Arena.

(b) For juveniles' information collected with their parents' and guardians' permission, it will only be used or publicly disclosed if it is permitted by law, with the explicit consent of their parents or guardians, or under conditions necessary for protecting them.

(c) Should we find out any juveniles' information has been collected without their parents' or guardians' permission, immediate measures will be taken to delete relevant data.

Claims about app permission usage

Under this Privacy Policy, Walton TICK-V.2 App uses Bluetooth (BLE) to communicate with the device and is a companion application for a connected device for the phone. In daily use, Walton TICK-V.2 App will apply to users for a phone reading or receiving permissions. The user is reminded to allow these permissions before using them. These permissions are limited to the implementation of the information push function, the phone received by the call, and SMS messages and content, pushed to the smartwatch side, to remind users with new messages for users to view. we solemnly affirm that, we will not upload or process any phone and text message content, and will never abuse these permissions, apply for these permissions only to implement the message push function. You can reject these permissions, only affecting the message push function. Generally for functional integrity and user experience perspective, we recommend that users agree to these permissions.

The Updating of Privacy Policy

We may change modify or amend by way of updating the material issues of this policy from time to time based on the circumstantial necessities. Your rights stipulated in this policy will not be shortened without your consent. Any alterations to this policy will be posted on this website. You will be informed of major alterations through information push service, emails, and announcements. Major alterations herein include but are not limited to:

a. Major changes in our service modes such as targets of personal information processing, types of personal information processing, and use of personal information;

b. Major changes in our company ownership structure and organization structure such as business re-arrangement, ownership changes caused by bankruptcy and acquisition;

c. Major changes in the main targets of personal information sharing, transfer, and public disclosure;

d. Major changes in your rights to and the forms of participation in personal information processing;

e. Changes in departments responsible for personal information security, their contact information, and channels for complaint;

f. Personal information security evaluation form indicates possible high risks.

How to contact us

If you have any questions, comments, or suggestions about this policy, please feel free to send them to 【support@waltonbd.com 】.

We have appointed a commissioner for personal information protection, whom you can reach via 【support@waltonbd.com 】.

We will generally reply within 07 working days.