PRIVACY POLICY FOR PanPan DEVICES

Last updated: 2 May 2022

Your privacy is important to PanPan. We developed this Privacy Policy to provide you with information on how we process your personal data when you use the PanPan website, mobile app, PanPan wearable devices or other PanPan accessories.

“Personal data” is information relating to an identified or identifiable natural person.

To jump to a specific section of this Privacy Policy, please click on a link below:

Categories of Personal Data Processed by PanPan

When you create an account, we ask you to provide the following personal data: your email address, name, and password. You can choose to provide only your first name or a nickname instead of your full name if you wish.

PURPOSES AND LEGAL GROUNDS:

(a) PanPan processes your email address and password because you use them to sign in to your account. The legal ground for processing your email address and password is PanPan’s legitimate interest in protecting the security of your account.

(b) PanPan processes your email address to send you important information about your PanPan products, services, apps, or account, such as safety information or material changes to this Privacy Policy. The legal ground for this is PanPan’s legitimate interest in providing you important safety or other information about your PanPan products, services, apps, or account or changes to this Privacy Policy and in providing you with an opportunity to engage with other PanPan users.

(c) If you provide your opt-in consent to receiving marketing information from PanPan, PanPan will also process your email address to send you marketing information about PanPan products, services and apps. The legal ground for processing your email address for this purpose is your consent. You may withdraw your consent at any time by changing your preferences in your PanPan account or through the unsubscribe link at the bottom of our marketing emails. 

(d) PanPan processes your email address to associate it with your PanPan account when you interact with our customer support representatives. The legal ground for this is our legitimate interest in providing better customer support.

(e) PanPan processes your email address to notify you of a violation of our terms. The legal ground for this is our legitimate interest in ensuring a quality experience for all customers and adherence to our terms.

When you create an account, you are also given the choice to add additional information to your profile, such as your home location, blood type, your gender, birth date, height and weight.

PURPOSE AND LEGAL GROUND:

PanPan processes this information with the purpose of sharing it with first responders during an emergency. The legal ground for processing this information is your vital interest should you need urgent medical attention or find yourself in other types of life-threatening situations. You can delete or modify this information from your account profile at any time.

If you live in China, you may choose to sign in to your PanPan account using your social media sign-in credentials (e.g., your WeChat or QQ sign-in credentials). If you choose this method, the first time you sign in, you will be asked whether you agree to the social media provider delivering certain information to PanPan, such as your name, email address, profile photo, posts, comments, and other information associated with your social media account.

All of this information is made available to PanPan by the social media provider due to the way the social sign-on configuration works. However, the only information PanPan retains and processes is your email address. If you do not want your information to be shared with PanPan by the social media provider, then you can simply sign in to your PanPan account using your PanPan account credentials instead of your social media account credentials.

PURPOSE AND LEGAL GROUND:

PanPan associates the email address provided by the social media provider with your PanPan account so that in the future if you no longer wish to sign in to your PanPan account using your social media account credentials, you can do it using your email address. The legal ground for processing this information is PanPan’s legitimate interest in providing you with an alternative sign-in method and in securing your account.

When you wear a PanPan smartwatch, we process the personal data collected by the device such as your heart rate, falls, and location to show it on the PanPan platform.

PURPOSES AND LEGAL GROUNDS:

(a) If you choose to upload this type of data to PanPan, we will process the data to enable you and your carers access to it. The platform will show you the location on your map, and your heart rate metrics. If you reside in the EEA, U.K., or Switzerland, the legal ground for this processing is your explicit consent, which you can withdraw at any time within your PanPan account.

(b) PanPan also processes your activity data in an aggregated manner to analyse usage and trends and develop or improve features and services. The legal ground for this processing is PanPan’s legitimate interest in providing relevant and quality features and services.

If you enable email notifications, PanPan processes your email address following your notification settings.

PURPOSE AND LEGAL GROUND:

If you provide your opt-in consent, PanPan will process your email address to send you notifications based on your selections (e.g., device battery low, etc.). The legal ground for processing your email address for this purpose is your consent. You can withdraw this consent at any time by changing your email settings to opt out of receiving such notifications or by disabling email notifications.

When you interact with our customer support representatives by email or telephone, online, or in person, we collect personal data, such as your name, mailing address, phone number, email address and contact preferences, and information about the PanPan products you own, such as serial numbers, dates of purchase, and subscriptions. We also may create event logs that are useful in diagnosing product or app performance-related issues and capturing information relating to the support or service issue.

To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives, and analyse any feedback provided to us through voluntary customer surveys. With your consent, our customer support representatives may sign in to your PanPan account, if appropriate, to help troubleshoot and resolve your issue.

PURPOSES AND LEGAL GROUNDS:

We use this information to offer and improve customer service and product support and to facilitate repairs, returns, or exchanges. The legal ground for processing this information for these purposes is PanPan’s legitimate interest in providing quality product support.

If you choose to use location-based services such as geofence, the physical location of your device will be collected in order to provide you with this type of service.

PURPOSE AND LEGAL GROUND:

The purpose of processing the location of your device is to provide you with the location-based services you wish to use. The legal ground for processing this data for this purpose is the performance of our contract.

If you provide emergency contacts to PanPan, we will request the name, phone number and email address of your contact(s). PanPan will process this personal information if an emergency is detected by or reported using your PanPan watch. PanPan will send a notification with information about the incident, such as location, to your chosen emergency contacts via SMS or email.

PURPOSE AND LEGAL GROUND:

We process this personal data to notify you of an incident involving the PanPan user. The legal ground for processing this information for this purpose is our legitimate interest in enabling our users to share important information with carers and family and to contact them during an emergency.

Other service providers:

PanPan uses cloud services from third parties such as Amazon Web Services to assist in sending emails. Those services track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on, and whether purchases were made following clicks on those links. PanPan uses this data to analyse the level of engagement with its emails. PanPan also uses third-party service providers to help us better understand the usage of the PanPan website and app and for related purposes.

Other disclosures:

We may disclose personal data about you to others: (a) if we have your valid consent to do so; (b) to comply with legal obligations, such as a valid subpoena, court or judicial order, or other valid legal processes; (c) to enforce any of our terms and conditions or policies; or (d) as necessary to pursue available legal remedies or defend legal claims.

We may also transfer your personal data to an affiliate, a subsidiary, or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of PanPan’s business, assets, or stock, including, without limitation, in connection with any bankruptcy or similar proceeding, provided that any such entity that we transfer personal data to will not be permitted to process your personal data other than as described in this Privacy Policy without providing you notice and, if required by applicable laws, obtaining your consent.

For customers outside of mainland China, when you create a PanPan account, add personal data to your account profile, or upload data to your PanPan account, your data will be collected and stored on servers in Ireland.

Personal data regarding individuals who reside in a country in the European Economic Area ("EEA"), United Kingdom ("U.K."), or Switzerland is controlled by PanPan Würzburg GmbH and processed on its behalf by other PanPan-owned companies to provide support, infrastructure, security, and other key functions. PanPan Würzburg GmbH has entered into approved model contractual clauses where these companies are not located in the EEA or a jurisdiction deemed adequate under applicable data protection law.

All PanPan-owned companies are required to follow the privacy practices outlined in this Privacy Policy.

Application Analytics

We collect data from our subscribers regarding the use of the PanPan mobile app. The information we collect includes the date and time the App accesses our servers, App version, location of the device, language setting, files and information downloaded to the app, user behaviour (e.g., features used, frequency of use), the device’s state, model, hardware and operating system information, and data regarding the functioning of the app.

Google Analytics is an example of a third-party provider we use to track statistics and user demographics, interests, and behaviour on our app.

PURPOSE AND LEGAL GROUND:

PanPan uses this data to improve the quality and functionality of these and other apps; to develop and market products and features that best serve you and other users, and to help identify and fix app stability issues and other usability problems as quickly as possible.

The legal ground for processing this analytical information is our legitimate interest in understanding how our customers interact with our products and apps so we can enhance the user experience and functionality of our products and apps.

Children

We request individuals under the age of 13 in the U.S. and under the age of 16 in the rest of the world not provide personal data to PanPan. If we learn that we have collected personal data from a child under the age of 13 in the U.S. or under 16 in the rest of the world, we will take steps to delete the information as soon as possible.

Privacy Policy Updates

We may update this Privacy Policy from time to time as we add new products, services, and apps, as we improve our current offerings, and as technologies and laws change. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Policy.

We will provide notice to you if these changes are material and where required by applicable law we will obtain your consent. This notice will be provided by email or by posting notice of the changes on the PanPan websites and apps that link to this Privacy Policy.

Retention of Personal Data

We will retain your data as long as your PanPan account is considered to be active or following applicable law and regulatory obligations. In addition, see below under “Your Rights” for a description of your right of erasure.

Automated Decision-Making, Including Profiling

PanPan does not make any decisions based on algorithms or other automated processing that significantly affect you.

Data Controller and Data Protection Officer

If you reside in the EEA, U.K., or Switzerland, your personal data collected by PanPan is controlled by Pandu Solutions LTD in Dublin, Ireland. The company's EU Data Protection Officer can be reached by email at info@PanPan.watch.

Your Rights

If you reside in the EEA, U.K., or Switzerland, you have the right, subject to the conditions set out in the General Data Protection Regulation ("GDPR") or other applicable law, to request from PanPan access to and rectification or erasure of your personal data, data portability, restriction of processing of your personal data, the right to object to the processing of your personal data, and the right to lodge a complaint with a supervisory authority. For more information about these rights, please visit the European Commission’s “My Rights” page relating to GDPR, which can be displayed in several languages. If you reside outside of the EEA, U.K., and Switzerland, you may have similar rights under your local laws.

To request access to or rectification, portability, or erasure of your personal data, or to delete your PanPan account, please contact us at info@panpan.watch.