Privacy Policy

Privacy Policy of Shenzhen Xingyi Intelligent Technology Co., Ltd. (hereinafter referred to as "Xingyi Tech", "Xingyi" or "we"), updated on March 17, 2026. Please take some time to familiarize yourself with our Privacy Policy. If you have any questions, please contact us at zc@smartxy.com.cn.

Introduction

If you use Xingyi's products or services, it indicates that you have read, acknowledged and accepted all the terms in this Privacy Policy, including any changes we may make at any time. We hope to explain through this Privacy Policy how we collect, use, store and share this information when you use our services, as well as the ways we provide for you to access, update, control and protect this information. At the same time, we commit to protecting the privacy, confidentiality and security of your personal information in accordance with applicable laws.

About Personal Information

The purpose of collecting personal information is to provide you with products or services, and to ensure that we comply with applicable laws, regulations and other normative documents. You have the right to choose whether or not to provide this information, but in most cases, if you do not provide it, we may be unable to provide you with corresponding services or respond to problems you encounter.
We understand the importance of personal information protection. Therefore, when collecting your information, we will strictly abide by the requirements of laws and regulations, adhering to the principles of legality, legitimacy, necessity and good faith. The information we collect mainly includes the following categories:
1. Information you actively provide:
1.1 When you register or use our products or services, you may need to actively fill in or upload personal information such as nickname, email, mobile phone number, avatar, and images.
1.2 Information you submit through our customer service or when participating in activities we host will also be collected.
1.3 For certain specific services, we may need you to provide specific personal information to achieve related functions. If you choose not to provide this type of information, it will not affect your use of other functions.
2. Information we obtain when you use our services:
2.1 Personal Information and Permissions
2.1.1 The following information is required for the normal operation and use of the app:
(1) Mobile phone number or email address  
We collect mobile phone numbers or email addresses for account registration, to send verification codes to confirm the authenticity of the phone number or email address (mobile phone real-name verification), and for functions such as recovering account passwords. This information will be stored long-term as a key basis for app login until the account is deleted. To delete your account: Go to the “My” section in the app, then to the “About Us” page, and scroll to the bottom to find “Delete Account.” After clicking, confirm “Delete” in the pop-up window to delete your account, along with any associated personal information and service-related data. Once deleted, this data cannot be recovered, so please proceed with caution!
(2) Device MAC Address and Product Serial Number
We collect device information (such as the “device MAC address” and “product serial number”) to generate a unique device ID. This ID is used for binding and unbinding devices to accounts, determining OTA updates, reporting device logs, and identifying content distribution. This information is reported to and stored long-term on our servers. It is displayed when viewing device information to facilitate device statistics and management.
(3) Device Identifier
We collect the device identifier of the mobile phone (UID for iPhones and Android ID for Android phones) to generate a unique software ID. This ID is primarily used to report error logs generated after the app is installed, using this ID as a unique identifier to assist in analyzing and resolving issues that arise during the app’s operation on a single device.
(4) Images and Audio/Video
We collect images and audio/video data to support specific device functions (e.g., taking photos or videos with smart glasses, recording audio, and transcribing audio to text). This information is stored long-term on the server and linked to your account, allowing you to retrieve historical data from the cloud whenever you switch devices and log in to your account.
2.1.2 Device or software information, such as configuration details provided by your device, web browser, or other programs used to access our services; your IP address; the app version installed on your device; the current firmware versions of various chip platforms; and device identification codes. This information will be used for device compatibility analysis and software adaptation, as well as product optimization and improvement, to provide users with a better product experience;
2.1.3 Information related to searches or browsing while using our services, such as the search terms you use, the URLs of social media pages you visit, and other information and content details you browse or request while using our services;
2.1.4 Information regarding the mobile applications (apps) and other software you have used, as well as details about your usage of such mobile applications and software;
2.1.5 Information collected through permissions necessary for the normal operation of the application and integrated third-party SDKs, including but not limited to the following application permissions:
(1) “Access to device photos or media”: For example, when downloading files, locating files, and installing APKs during APK updates; storage permission is also required when saving error logs locally.
(2) “Installed Apps”: We need to collect the list of installed apps for data storage and installation during app updates and device firmware upgrades; this information is used when the program performs corresponding functions locally.
(3) “Bluetooth Permission”: Used for the app to connect to Bluetooth hardware devices, transmit functional commands, or synchronize data, etc.
(4) “Access to Coarse/Fine Location”: The program includes Bluetooth pairing with third-party devices; this permission is required when retrieving Bluetooth information.
(5) “Camera Permission”: When the app modifies a profile picture, it accesses images by retrieving them from the local photo gallery or opening the camera; this permission is also required for business functions that utilize the camera’s photo-taking capabilities for recognition.
2.2 Location information:
(1) When you use location-related services, we may record your location information to provide you with more accurate services. Please note that GPS location information is sensitive personal information. If you refuse to provide it, it will affect all or part of the functions related to geographic location, and you understand and accept the resulting service limitations. We will not bear any responsibility.
(2) Location information refers to information about your location collected when you enable the device positioning function and use our location-based services. You can stop the collection of your geographic location information by turning off the positioning function.
2.3 Other relevant information: With your authorization, we may collect encrypted information such as contacts to help you better use our services.
2.4 Information shared by other users: Photos posted or videos shared by other users may contain your information. We remind you to pay attention to privacy security.
2.5 Information obtained under circumstances permitted by law: For example, when you log in with WeChat or QQ account to access third-party partner services, we will obtain information such as your login name to facilitate your authorization management.
3. Exceptions to obtaining prior authorization consent for collection and use. Please note: In the following circumstances, there is no need to obtain your prior authorization consent for collecting and using personal information:
(1) Directly related to national security and defense security;
(2) Directly related to public security, public health, and major public interests;
(3) Directly related to criminal investigation, prosecution, trial, and judgment execution;
(4) For maintaining the significant legitimate rights and interests of you or other individuals' lives, property, etc., but it is difficult to obtain personal consent;
(5) The collected personal information is information you have voluntarily disclosed to the public;
(6) Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;
(7) Necessary to provide products or services to you according to your requirements;
(8) Necessary for maintaining the secure and stable operation of the provided products or services, such as discovering and handling faults in products or services;
(9) Other circumstances stipulated by laws and regulations.

How We Use Your Personal Information

When we need to fulfill legal obligations or when we believe it is necessary to protect Xingyi's legitimate interests, we will process your personal information for the purposes described in this Privacy Policy upon obtaining your consent.
1. Using the personal information we collect, we can promptly notify you of Xingyi's latest product releases, software updates, and event announcements;
2. We will also use personal information for the following purposes: to help us create, develop, operate, provide and improve our products, services, content and advertising, as well as for loss prevention and fraud prevention purposes. We may also use your personal information for account and network security purposes, including protecting our services for the benefit of all users;
3. We may use your personal information to verify identity, assist in user identification, and determine appropriate services. For example, we may use a mobile phone number to determine whether a Xingyi account belongs to the holder himself/herself;
4. We may use personal information to send important notifications, such as changes regarding conditions and policies. Since this information is crucial to communication between you and Xingyi, you cannot refuse to receive such information;
5. We will also use personal information for internal purposes such as auditing, data analysis and research to improve Xingyi's products, services and communication with customers.

Storing Personal Information

We retain personal information for the period necessary for the purposes of information collection described in this Privacy Policy, or as required by applicable laws. After completing the collection purpose, or after confirming your deletion or cancellation request, or after we terminate the operation of the corresponding product or service, we will cease retention and perform deletion or anonymization processing. If users request information deletion without completing identity verification according to our guidelines, it will be deemed as waiving the right to request data deletion.
Your information will be stored within the People's Republic of China. Anonymized data processing used for big data analysis, product improvement and other purposes that do not identify specific users is not subject to the aforementioned retention period restrictions.

How You Access and Control Your Personal Information

We will do our best to adopt appropriate technical measures to ensure that you can access, update and correct your registration information or other personal information provided when using our services. When accessing, updating, correcting and deleting the aforementioned information, we may require you to undergo identity verification to ensure account security. Most laws require that requests made by personal information subjects should follow specific requirements. This Privacy Policy requires that your request should meet the following conditions:
1. Through our dedicated request channels, and for the consideration of protecting your information security, your request should be in writing;
2. Provide sufficient information to allow us to verify your identity, ensuring that the requester is the individual themselves or a legally authorized person of the requested information subject;
3. After you or we assist you in deleting relevant information, due to reasons such as system architecture, backup mechanisms, applicable laws or technical limitations, we may not be able to immediately delete the corresponding information from the backup system or there may be information residue. We will securely store your personal information and further isolate it according to the principle of minimization, but we do not guarantee complete clearance and do not assume subsequent liability. We have the right to refuse to process requests that are meaningless/frivolous repetitions, requests that harm others' privacy rights, extremely unrealistic requests, requests requiring disproportionate technical work, violating security policies, affecting our normal operations, exceeding necessary scope, or requests that may pose potential risks according to our judgment, as well as requests that do not need to be granted according to national or local laws. If we believe that certain aspects of requests to delete or access data may cause us to be unable to legally use data for the aforementioned anti-fraud and security purposes, we may also refuse them.

Information Security

We only retain your personal information for the period necessary for the purposes described in this Privacy Policy and the time limits required by laws and regulations.
We use various security technologies and procedures to prevent loss, improper use, unauthorized viewing or disclosure of information. For example, in certain services, we will use encryption technology (such as SSL) to protect the personal information you provide. Users understand that internet transmission has inherent risks, and we cannot guarantee 100% information security. The systems and communication networks you use to access our services may have problems due to factors outside our control. Users confirm that using the service means users voluntarily assume all risks of data leakage, abuse, loss or unauthorized access, including situations caused by technical limitations, third-party attacks, user negligence, failure to update security settings in a timely manner, voluntary disclosure of verification credentials, storing personal information in violation of this policy, or other force majeure factors. Xingyi Technology does not bear any responsibility for information security issues caused by existing technical limitations, force majeure, or user's own reasons.

Limitation of Liability

Under no circumstances shall Xingyi Technology be liable for any direct, indirect, incidental or consequential damages (including but not limited to data loss, business interruption) arising from the use of services, and our total liability for compensation shall not exceed the service fees paid by users in the past 6 months (if any).

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices or other operational, legal or regulatory reasons. If we make changes, we will notify you by modifying the date at the top of the policy. In some cases, we may provide you with additional notices (such as adding a statement on the homepage of our website or sending you a notice). We recommend that you review this Privacy Policy whenever you access the services or otherwise interact with us to stay informed about our information usage practices and the options available to you.

Disclaimer for Policy Updates

Users have the obligation to periodically and proactively review the updates to this policy. Failure to review in a timely manner does not affect the effectiveness of the updated terms. Xingyi Technology does not guarantee the delivery of update notifications. Continued use of the services by users shall be deemed as unconditional acceptance of all changes.