What Personal Data do we collect

In order to provide our services to you, we will ask you to provide necessary Personal Data that is required to provide those services. If you do not provide your Personal Data, we may not be able to provide you with our products or services.

1.​ Information You Voluntarily Provide Us

• ​ Account or Profile Data: When you register an account with us, we may collect your name and contact details, such as your email address, phone number, user name, and login credentials. During your interaction with our Products, we may further collect your nickname, profile picture, country code, language preference or time zone information into your account.
• ​ Feedback: When using feedback and suggestion features in our Products, we will collect your email address, mobile phone number and your feedback content to address your problems and solve device failures on a timely basis.

2.​ Information We Collect Automatically

• ​ Device Information: When you interact with our Product, we automatically collect device information, such as the MAC address of your devices, IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information.
• ​ Usage Data: During your interaction with our Sites and Services, we automatically collect usage data relating to visits, clicks, downloads, messages sent/received, and other usage of our Sites and Services.
• ​ Log Information: When you use our app, the system and exception log may be uploaded.
• ​ Location Information: We may collect information about your real-time precise or non-precise geo-location when you use our specific Products or Services, such as Luka.

3.​ Smart Devices Related Information:

• ​ Basic Information of Smart Devices: When you connect your Smart Devices with our Products or Services, we may collect basic information about your Smart Devices such as device name, device ID, online status, activation time, firmware version, and upgrade information.
• ​ Information Reported by Smart Devices: Depending on the different Smart Devices you elect to connect with our Products or Services, we may collect different information reported by your Smart Devices. For example, time zone, device activate status, device current status.

Purposes and legal basis for processing Personal Data

The purpose for which we may process information about you are as follows:

• ​ Provide You Services: We process your account and profile data, device information, usage data, location information, and Smart Device related information to provide you with our Products and Services that you have requested or purchased. The legal basis for this processing is to perform our contract with you according to our Terms of Use.,
• ​ Improve Our Services: We process your device information, usage data, location information and Smart Device related information to ensure the functions and safety of our Products, to develop and improve our Products and Services, to analyse the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
• ​ Non-marketing Communication: We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications. The legal basis for this processing is to perform our contract with you according to our Terms of Use.
• ​ Marketing Communication: We may process your Personal Data to provide marketing and promotional materials to you on our Products and Services. If we do so, each communication we send you will contain instructions permitting you to opt-out of receiving future communications of that nature. The legal basis for this processing is your consent. Additionally, if you consent to participate in our lottery, contest or other promotions, we may use your Personal Data to manage such activities.
• ​ Personalization: We may process your account and profile data, usage data, device information to personalize product design and to provide you with services tailored for you, such as recommending and displaying information and advertisements regarding products suited to you, and to invite you to participate in surveys relating to your use of our Products. The legal basis for this processing is your consent.
• ​ Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

Who do we share Personal Data with?

At Luka, we only share Personal Data in ways that we tell you about. We may share your Personal Data with the following recipients:

• ​ To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
• ​ To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our Sites and Services.
• ​ To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of your Personal Data, and choices you may have regarding your Personal Data.
• ​ As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• ​ To subsidiaries or affiliates within our corporate family, to carry out regular business activities.

Except for the third parties described above, to third parties only with your consent.

Your Rights Relating to Your Personal Data

We respect your rights and control over your Personal Data. You may exercise any of the following rights: Via the “Profile – Personal Centre” in our Products You do not have to pay a fee and we will aim to respond you within 30 days. If you decide to email us, in your request, please make clear what information you would like to have changed, whether you would like to have your Personal Data deleted from our database or otherwise let us know what limitations you would like to put on our use of your Personal Data. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes. You may:

• ​ Request access to the Personal Data that we process about you;
• ​ Request that we correct inaccurate or incomplete Personal Data about you;
• ​ Request deletion of Personal Data about you;
• ​ Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about you;
• ​ Request transfer of Personal Data to you or a third party where we process the data based on your consent or a contract with you, and where our processing is automated; and
• ​ Opt-out or object to our use of Personal Data about you where our use is based on your consent or our legitimate interests.

Data Retention

We process your Personal Data for the minimum period necessary for the purposes set out in this Privacy Policy, unless there is a specific legal requirement for us to keep the data for a longer retention period. We determine the appropriate retention period based on the amount, nature, and sensitivity of your Personal Data, and after the retention period ends, we will destruct your Personal Data. When we are unable to do so for technical reasons, we will ensure that appropriate measures are put in place to prevent any further such use of your Personal Data.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (send to the e-mail address specified in your account) or by means of a notice in the mobile applications prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Contact Us If you have any questions about our practices or this Privacy Policy, please contact us as follows: Luka Postal Mailing Address: Unit 7 Speedwell Road, Whitwood, Castleford, West Yorkshire, WF10 5PY, United Kingdom Email: info.group@lcogroup.co.uk

Service Agreement of Luka

Welcome to Luka! Before accepting the Agreement, you are supposed to thoroughly read all contents of the Agreement, and fully know its terms, especially restrictive clauses or exceptions. Restrictive clauses or exceptions are bold or highlighted in other forms to catch your attention. In case of any doubt for the terms of the Agreement, please contact relevant business department of Luka. You are not allowed to use the service before you have read and accepted all terms of the Agreement, relevant agreements and rules, etc. Once you select "agree and submit the Agreement" (see registration page for detailed wordings) and complete the registration procedure, or you use the service in any form, it will be deemed that you have read and agreed with the restriction of the Agreement and rules above. In case of any breach of the Agreement, Luka has the right to unilaterally restrict, suspend or terminate the service for you, and has the right to investigate your relevant responsibilities. The Service Agreement (hereinafter referred to as "the Agreement") is signed by you and Luka. It includes (but not limited to) Luka Privacy Policy and other contents. In case of change, Luka will announce by means of the licensed software sending a message without further notification. Upon announcement, the changed agreement and rules become a part to the Agreement automatically, without further notification to you for your consent. In case of objection to such relevant changes, stop use Luka's service; if you keep using it, it will deemed as that you hold no objections against the changed rules and agree to abide by them.

1. Definitions of Terms

1.1 Licensed software refers to software system developed by Luka, downloaded and installed and applied in specified system mobile terminals. 1.2 Services refer to services provided for you by Luka and its suppliers. You can use such services on the mobile terminal with the licensed software

2. Service

2.1 Luka offers you intelligent life equipment management services, based on which you can access the intelligent terminals on Luka and its suppliers' smart platform through the Luka control, and realize interlinkage among intelligent equipment. Service contents include intelligent equipment management, scene interlinkage and analysis report, etc. Such functions may be optimized or modified according to changes of users' demands or judgment of service supplier, and service supply may be suspended due to regular and irregular maintenance.

3. Scope of Service

3.1 Please enter the company name grants you with the right to use the product based on this software. 3.2 You are prohibited to license, sell, lease, transfer, issue the product in any form, or use the product for other commercial purpose. 3.2 Due to limitations on software adaptation platform and terminals, you can only use the licensed software in the authorized system platform and terminal; if you install the licensed software on other terminal equipment, it may damage your hardware or software function. 3.3 You acknowledge that the licensed software can only be used for non-commercial purpose and installation, application and running of the licensed software is prohibited. If such commercial operation is necessary, prior written authorization and permission from Luka shall be obtained. 3.4 Luka and its suppliers may change, upgrade, or transfer the licensed software or relevant functions from time to time, and may add new functions or services in the licensed software system. If no separate agreements are accompanied with the aforesaid new functions or services, you are entitled to the corresponding functions and services, which is also subject to the Agreement. 3.5 You shall be responsible for the accuracy, reliability, integrity and legality of input data and legality of the way in which you obtain the data and shall back up data and information from time to time. You shall bear all risks for damage and loss of such information. 3.6 You shall properly keep your account number and password. In case of any safety loophole for your account (including but not limited to divulgence of user password), you shall notify Luka in time, and Luka will assist you in taking relevant measures. Otherwise, all behaviours related to your account shall be assumed by you and you will bear all responsibilities.

4. A Third Party

4.1 You acknowledge that certain service of Luka and its suppliers is based on software or services provided by a third party. Such service is set to facilitate your application and necessary legal authorization is obtained from the third party. 4.2 The product includes certain information and services of the third party. Luka and its suppliers neither controls nor bears responsibility for information and services of the third party. 4.3 You acknowledge that Luka and its suppliers cannot guarantee that the licensed software always uses or contains such services, or that other software provided by the same third party will be used in future. Likewise, it may use similar services supplied by another third party. Upon application, the aforesaid corresponding software or services are subject to this Agreement.

5. Service Application Standard

5.1 You shall use the licensed software in a normal manner. The following ways are in breach of the application standard: 1) Issue or share computer virus, worms, malicious codes, or software that deliberately damages or changes computer system or data; 2) Collect information or data of other users without authorization, for example, email address and the like; 3) Maliciously use the product in an automatic way, causing over load to the server, or interfere with or damage web server and network links in other forms. 4) Attempt to visit server data or communication data of the product without authorization; 5) Interfere with or damage the production application by other users. 5.2 You understand and agree that: 1) Luka will determine whether or not you are involved in violation of standards above, and suspend or terminate your application license according to determination results or take other restrictions according to agreements. 2) Luka will directly delete information in breach of laws, or infringing others' legal rights, or in breach of the Agreement issued by you when using the licensed software. 3) If a third party suffers from damage due to your breach of application standards, you shall independently bear legal responsibility in your name, and protect and indemnify Luka from losses or additional expenses generated therefrom. Otherwise, Luka has the right to claim compensation. 4) If Luka and its suppliers suffers from any loss due to your breach of relevant laws or the Agreement, you shall compensate Luka and its suppliers for losses and (or) expenses generated therefrom.

6. Information Content Standard

6.1 You promise that you will not conduct any act in breach of laws or improper behaviors by using the service, such act and behavior include (but not limited to): 6.1.1 Uploading, transferring or sharing information containing one of the following contents: 1) Opposing the basic principles determined in the Constitution; 2) Endangering state safety, disclosing state secret, subverting state power and sabotaging state unity; 3) Damaging state honor and benefit; 4) Inciting national hatred and discrimination and sabotaging national unity; 5) Destroying religious policy of the state and advocating heresy and feudalistic superstition; 6) Spreading rumors, disturbing social order and destroying social stability; 7) Spreading obscenity, porn, gambling, violence , murder and terror or abetting a crime; 8) Insulting or slandering others and infringing on the legal rights and interests of others; 9) Containing contents of sham, defraudation, harm, threat, infringement to others' privacy, harassment, infringement, slander, coarseness, indecency, or morally repulsive contents; 10) Containing other contents restricted or forbidden by applicable laws, regulations, rules, provisions and other legal standards.

7. Private Policy and Data

7.1 It is crucial for Luka to protect your personal information. Luka prepares Luka Privacy Policy, in which contents related to ownership and protection of intellectual property, collection, use, share, storage and protection, etc. of your information are disclosed. You are suggested to thoroughly read Luka Privacy Policy.

8. Exception Clauses

8.1 Unless otherwise specified in laws and regulations, Luka will do its best to ensure the security, validity, accuracy and reliability of the licensed software and technologies and information involved, but Luka is unable to guarantee the same due to restriction by available technologies nowadays. 8.2 You understand that Luka will not assume responsibility for direct or indirect losses caused by force majeure and default of a third party. 8.3 You shall be responsible for personnel injury or incidental or indirectly injury caused by or related to one of the following accidents: 1) A third party uses the licensed software or changes your data without permission; 2) Expenses and losses produced by using the licensed software; 3) Your misunderstanding of the licensed software; 4) Other losses related to licensed software caused by reasons not attributable to Luka. 8.4 Any other licensed software-derived software not developed and released by Luka or the development and release are not granted by Lukais illegal software. Downloading, installing and using such software may cause unpredictable risks. Luka shall be free from legal responsibilities and disputes generated therein and Luka shall have the right to suspend or terminate application license and/or other all services. 8.5 You have been informed of that the usage of Luka and its supplier's smart platform involves in Internet service, which may be affected by unstable factors in all links. Although Luka has taken safeguard measures, the service may be suspended, terminated, delayed, suffered from application restriction or application failure due to inherent defects of Internet and e-communication as well as factors beyond reasonable control of any party to the Agreement (including but not limited to fire, flood, terrorist attack, pestilence, natural disasters, riot, terminal virus, hacker attack, network fault and terminal fault). You hereby agree to bear foregoing risks and agree that Luka is free from any responsibility when normal running of services are influenced by the occurrence of foregoing risks.

9. Agreement Termination and Breach of Agreement

9.1 You should understand that you shall use the licensed software according to authorization scope, respect intellectual property of software and contents contained in the software, and perform obligations according to the Agreement when using Luka's services. Luka will terminate the application license if you are in material breach of the Agreement. 9.2 Your application of the software relies on supporting services supplied by Luka's related companies. Breach of terms, agreements, rules, annunciation and other relevant regulations of Luka and its related companies may cause failure in normal usage of licensed software, in which case, Luka shall be entitled to terminate the application license, or take measures to restrain your application license or other rights and interests controlled by Luka as agreed in the Agreement, including suspension or termination of your application license. 9.3 In case of your breach of the Agreement or other agreements signed with Luka, Luka and its suppliers shall have the right to notify the related companies, requiring them to take restrictive measures to your rights and interests, including requiring related companies to suspend or terminate supplying part or whole services for you, and legally announce your breach of agreement on websites run or actually controlled by them. 9.4 The licensed software is downloaded from the downloading platform and you shall abide by stipulations of the download platform, system platform and terminal manufacture on application ways and restrictions of the licensed software. If the above mentioned third party confirms that you are in breach of the agreement and Luka and its supplier's treatment is required, Luka may terminate your application license at the third party's request. 9.5 When the application license terminates, you shall stop using the licensed software and destroy all copies. 9.6 You must bear all compensation responsibilities if Luka and other users suffer from losses caused by your breach of terms in the Agreement.

10. Governing Laws and Severability

10.1 Effectiveness, explanation, change, execution and dispute settlement of the Agreement are subject to laws of the People's Republic of China. If no relevant laws and regulations are available, reference to general international business practices and (or) industrial practices shall be made. 10.2 Dispute arising from or in connection with the Agreement may be settled by you and Luka through friendly negotiation or submitted to People's Court of Luka where the Agreement is signed for adjudication. 10.3 When any term of the Agreement is judged to be invalid by the People's Court, it will not influence the effectiveness of other terms or any part thereof, and you and Luka shall perform the valid terms in good faith. 10.4 The Agreement is signed in Luka.