Privacy Policy

This Privacy Policy (the "Policy") describes how Shenzhen V-Intelligence Technology Limited (hereinafter referred to as "we", "us", or "our") collects, uses, stores, shares, and protects the personal information and related data you provide when using the veloqor APP (the "APP") and the related services of the Insect Bite Healer device (the "Device").

By downloading, installing, registering for, or using the APP, you agree to the collection, use, storage, and sharing of your information in accordance with this Policy. If you do not agree with any provision of this Policy, please do not use the APP or the related services.

1. Definitions

• Personal Information: means any information relating to an identified or identifiable natural person, which can be used alone or in combination with other information to identify such natural person, including, but not limited to, user profile information, usage records, device information, etc.
• Non-Personal Information: means information that cannot identify a specific natural person, either independently or in combination with other information, including, but not limited to, aggregated usage data, device operating status data, etc.
• You: means the natural person who downloads, installs, registers for, or uses the APP and related services.

2. Information We Collect

We collect only the information necessary to provide the APP and related services and will not collect irrelevant information without your consent. The information collected is categorized as follows:

2.1 Information You Voluntarily Provide

• User Profile Information: When you create a user profile in the APP, you may voluntarily provide information such as your name, age, skin sensitivity, and user type (e.g., adult, child). Such information is used to enable the APP to recommend appropriate treatment parameters based on your profile.
• Insect Bite Information: When you record treatment history, you may voluntarily provide information regarding the type of insect bite (e.g., mosquito, horsefly, bee, wasp). Such information is used to generate treatment logs and statistical records.
• Feedback and Suggestions: When you submit feedback or suggestions, or contact us through the APP, you may provide information such as your contact details (if you choose to provide them) and the content of your feedback. Such information is used to respond to your inquiries and improve our products and services.

2.2 Information Automatically Collected

• Device Information: When you use the APP to connect to the Device, the APP automatically collects information about the Device, including the Device’s unique identifier, remaining power, operating mode, current temperature, usage duration, and firmware version. Such information is used to enable device connection, status monitoring, and functionality optimization.
• APP Usage Information: The APP automatically records your usage activities, including the time you open or close the APP, the functions you use (e.g., device connection, treatment control, history query), treatment parameters (temperature, mode, duration), and frequency of use. Such information is used to improve the APP’s functionality, enhance user experience, and generate usage statistics.
• Device Connection Information: When you use short-range wireless connection to connect the APP to the Device, the APP collects short-range wireless connection data (e.g., connection signal strength and connection status) to ensure a stable connection and to troubleshoot connection issues.
• Mobile Device Information: The APP may collect basic information about your mobile device, including the device model, operating system version, wireless communication version, and remaining battery level. Such information is used to ensure compatibility between the APP and the Device and to optimize performance and power consumption.

2.3 Information Collected with Your Explicit Consent

In certain scenarios, we collect your information only after obtaining your explicit consent:

• Notification Permission: If you choose to enable notifications, the APP may send you notifications (e.g., device connection status, treatment completion, low power, and itch relief reminders) to keep you informed of relevant information in a timely manner.
• Exported Record Information: When you choose to export treatment records in PDF or Excel format, the APP may collect information related to the export operation, as well as the content of the exported records, in order to perform the export function and facilitate sharing or archiving.

3. Legal Basis for Processing (EEA Users)

For users located in the European Economic Area (EEA), we process your personal data on the following legal bases:

• Performance of a contract: to provide the APP’s functions and to connect with the Device;
• Consent: for optional features such as notifications and non-essential data collection;
• Legitimate interests: to improve the APP, enhance user experience, and ensure system security;
• Legal obligations: to comply with applicable laws and regulatory requirements.

4. How We Use Your Information

We use the information collected solely for the purposes stated in this Policy and will not use it for any other purposes without your consent. The specific uses are as follows:

4.1 To Provide Core Services

• To enable short-range wireless connection, automatic reconnection, and connection troubleshooting between the APP and the Device, thereby ensuring stable operation of the Device;
• To control the Device to start or stop treatment, adjust treatment temperature and mode, set treatment duration, and provide personalized treatment services based on your skin condition and bite type;
• To record and store treatment history, and to provide query, filtering, statistical, and export functions, thereby enabling you to track skin recovery status and treatment effectiveness;
• To provide bite type identification, post-treatment care tips, itch relief reminders, and emergency handling guidance, thereby enabling proper handling of insect bites and protection of skin health.

4.2 To Optimize Products and Services

• To analyze APP and Device usage activities, identify potential issues, and optimize the APP’s interface, functions, and performance in order to enhance user experience;
• To use collected treatment data and feedback to optimize the Device’s firmware and the APP’s functions, and to develop new features that meet user needs;
• To provide insect prevention tips based on usage patterns and regional characteristics, thereby helping to reduce the likelihood of insect bites.

4.3 To Handle Your Needs

• To respond to your feedback, suggestions, or inquiries, and to address issues encountered during your use of the APP and the Device;
• To send important notifications, including APP and Device firmware update notifications and device fault alerts, in order to ensure continued access to the latest functions and services.

4.4 To Comply with Legal Obligations

We may use your information as required by applicable laws, regulations, judicial decisions, or administrative orders in order to fulfill legal obligations, including for purposes such as investigations, evidence preservation, and law enforcement.

5. How We Store Your Information

5.1 Storage Location

The APP does not collect or upload any personal data to external servers. All personal information and usage data are stored locally on your mobile device only, and no such data is transmitted to or stored on our servers or those of any third parties.

5.2 Storage Period

We retain your personal information only for the minimum period necessary to fulfill the purposes stated in this Policy. Upon expiration of the applicable retention period, we will delete or anonymize your personal information, unless otherwise required by applicable laws and regulations.

• Treatment history and related records are retained for a period of 2 years from the date of the last treatment, unless you choose to delete them earlier or export and archive them;
• User profile information is retained for as long as you use the APP. If you unregister the APP, we will delete your profile information within 30 days, unless otherwise required by applicable laws and regulations;
• Non-personal information (such as aggregated usage data) may be retained indefinitely for purposes of product optimization and statistical analysis.

5.3 Storage Security

We implement appropriate technical and organizational measures to protect the security of your information and to prevent unauthorized access, disclosure, loss, alteration, or damage:

• Technical measures: We use encryption technologies (such as SSL) for the transmission and storage of personal information; implement access control mechanisms to ensure that only authorized personnel have access to such information; and regularly update system security patches to address potential vulnerabilities.
• Organizational measures: We maintain an internal information security management system, define the responsibilities of relevant personnel; provide regular information security training to employees to enhance their awareness; and enter into confidentiality agreements with employees and partners to prevent unauthorized disclosure of information.

6. Information Sharing and Disclosure

We do not share or disclose your personal information to any third party, except in the following circumstances:

6.1 With Your Explicit Consent

We share your personal information with third parties only after obtaining your explicit consent. For example, if you choose to share treatment records with a doctor, we will provide the relevant records to the designated doctor in accordance with your instructions.

6.2 With Trusted Third-Party Service Providers

To provide and improve our services, we may engage trusted third-party service providers to perform services on our behalf, such as technical support, data analysis, and server hosting. These service providers will have access only to the information necessary to perform their functions and are required to comply with this Policy and applicable laws and regulations. They are not permitted to use such information for any other purposes.

6.3 To Comply with Laws and Regulations

We may disclose your personal information as required by applicable laws, regulations, judicial decisions, or administrative orders, or in response to lawful requests from government authorities (such as public security or tax authorities), in order to fulfill legal obligations.

6.4 To Protect Rights and Interests

To protect the legitimate rights and interests of you, us, or other third parties, or to ensure the proper operation of the APP and related services, we may disclose your information where necessary in emergency situations (such as to prevent personal injury, property damage, or to combat fraud).

6.5 Anonymized Information Sharing

We may share anonymized and aggregated non-personal information with third parties (such as partners and research institutions) for purposes such as product research and market analysis. Such information cannot be used to identify any specific natural person and does not infringe upon your privacy rights.

7. Your Rights to Your Information

You have the right to manage your personal information in accordance with applicable laws and regulations (including the GDPR for EEA users and the CCPA/CPRA for California users), including the rights to access, correct, delete, withdraw consent, data portability, restriction of processing, and account deletion. You may exercise these rights in the following ways:

7.1 Query and Correct Your Information

You may access your personal information and treatment records through the "User Profile" and "Treatment History" sections within the APP. If you determine that any information is inaccurate or incomplete, you may correct it directly within the APP or contact us using the contact details provided below to request correction.

7.2 Delete Your Information

You may delete your treatment records individually within the "Treatment History" section of the APP. To request deletion of your user profile information, you may contact us using the contact details provided below. Once deleted, such information cannot be recovered, except where retention is required by applicable laws and regulations.

7.3 Withdraw Consent

You may withdraw your consent to the collection and use of your information at any time. For example, you may disable notification permissions in your mobile device settings to stop receiving APP notifications, or disconnect the short-range wireless connection between the APP and the Device to stop the collection of device connection data. Withdrawal of consent will not affect the lawfulness of processing carried out prior to such withdrawal.

7.4 Data Portability (EEA Users)

You may request a copy of your personal data in a structured, commonly used, and machine-readable format.

7.5 Account Deletion

You may contact us using the contact details provided below to request deletion of your account. Upon account deletion, we will delete your personal information within 30 days, except where retention is required by applicable laws and regulations. Following deletion, you will no longer be able to use the APP and related services.

7.6 Complaints and Appeals

If you believe that we have violated this Policy or applicable data protection laws, you may contact us or lodge a complaint with a competent data protection authority. We will process your request within 15 working days and provide a response.

8. EU Representative

In accordance with Article 27 of the General Data Protection Regulation (GDPR), we have appointed the following representative in the European Union:

• Company Name: GRZAN GROUP SL
• Address: C/ FUENCARRAL KM 29, MADRID 28004, SPAIN
• Email: eu@grzan-ar.com
• SRN: ES-AR-000039086

If you are located in the European Economic Area (EEA), you may contact our EU representative regarding matters related to the processing of your personal data.

9. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights:

• The right to know what personal information we collect, use, or disclose about you;
• The right to request deletion of your personal information;
• The right to opt out of the sale of your personal information (we do not sell your personal information);
• The right not to be discriminated against for exercising your privacy rights.

To exercise these rights, you may contact us using the contact details provided in Section 11.

10. Children’s Privacy Protection

The APP is intended for users aged 3 and above. Children under the age of 12 must use the APP under the direct supervision and guidance of a parent or legal guardian, who must review and agree to this Policy on behalf of the child.

We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent. If we become aware that we have collected personal information from a child under the age of 13 without such consent, we will promptly delete such information.

11. Changes to This Policy

We may update this Policy from time to time to reflect changes in applicable laws and regulations, product features, or user needs. The updated Policy will be made available within the APP (e.g., in the "Settings – Privacy Policy" section) and will take effect 7 days after publication. Your continued use of the APP and related services after such updates constitutes your acceptance of the updated Policy. If you do not agree with the updated Policy, please discontinue use of the APP and related services.

12. Contact Us

If you have any questions, suggestions, or complaints regarding this Policy or the protection of your personal information, you may contact us using the following details:

• Company Name: Shenzhen V-Intelligence Technology Limited
• APP Name: veloqor
• Contact Email: vit-official@vit-uni.com

We will process your request within 15 working days and provide a response.

13. Miscellaneous

If any provision of this Policy is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.