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Last Updated: July 15, 2025

Notice on the Collection of Personal Information and Privacy Policy Statement

Dear User,

Doctor HHH (hereinafter referred to as “DR H”) is an application provided by 智合芯科技(深圳)有限公司 (hereinafter referred to as “we”) to offer you smart device control and management services.

We understand that privacy is important to you, and we are committed to protecting it. Before submitting any personal or private information to our product DR H, please read, understand, and agree to this Privacy Policy (hereinafter referred to as the "Policy").

This Policy describes how DR H will handle your personal information and affirms DR H's commitment to privacy. We encourage you to read this Policy thoroughly to fully understand the privacy practices associated with specific DR H products or services.

Please note: Due to differences in device system versions, the configuration of service features may vary. Some services listed below may not be available on certain models, and some functions may be unavailable depending on the specific model. Please refer to your actual configuration. All rules concerning the collection and use of information apply solely to the usage of data and the provision of specific services to you.

(A) How We Use Your Personal Information

Personal information refers to any information that can identify an individual, either alone or in combination with other data. This information is collected when you use DR H products or services and may include your gender, date of birth, account information, photos, as well as the location and date when you access our products or services.

DR H will collect and use your personal information for the purposes described in this Policy.

Below are examples of personal information we may collect and how we may use it:

(1) Personal Information Collected

(2) How We Use Your Personal Information

The collection of personal information is intended to provide you with services and to enhance your experience with our products. Where required by applicable laws, we will comply with all relevant legal and regulatory obligations. By using our services, you expressly consent to our processing of your personal information for the purposes set forth in this Policy, including the sharing of such information with our subsidiaries (including those engaged in communications, social media, technology, and cloud businesses) and third-party service providers (as defined below).

We may use your personal information for the following purposes:

(3) How We Use Your Personal Data

We may also use your personal data for the following purposes:

  1. To make modifications and provide technical support based on your requests.
  2. To send you notifications regarding operating system or application updates and installations.
  3. To enhance your user experience and provide timely after-sales services.
  4. To conduct internal audits, data analysis, and research to improve our products and services.
  5. To analyze operational efficiency and measure market share.
  6. To improve customer communication and ensure the provision of secure and high-quality services.
  7. To troubleshoot errors when you choose to provide detailed reports to us.
  8. To synchronize, share, and store data that you upload or download, and to enable the performance of uploads and downloads.
  9. To improve our loss prevention and anti-fraud programs.

(4) Location-Based Services

When accessing certain location-based services (such as performing Bluetooth device searches), we may collect, use, and process your device's precise or approximate location. This location information is necessary to deliver such services. We collect real-time location data from your device (including through GPS, WLAN, and your network provider's ID), as well as the device type and model.

We collect location data in order to provide and enhance location-based products and services. You will be asked to specify which applications you wish to enable for location-based services. You may choose to disable location services on your device and refuse to share your location data. For more information on how to disable location-based services, please contact your network service provider.

(5) Collection and Use of Non-Identifiable Data

Non-identifiable data refers to information that cannot be used to identify an individual. For example, we may collect aggregate statistical data such as the number of visits. We collect such data to understand how users engage with our products and services. Through this, we can improve our services and better meet the needs of our customers. We reserve the right to collect, use, process, transfer, or disclose non-identifiable data at our sole discretion for other purposes.

(6) Access to Device Permissions

DR H may request access to certain permissions on your device as necessary to provide its services. Below is a list of permissions that may be requested, along with their corresponding descriptions and purposes:

No. Permission Purpose
1 Bluetooth Permission To connect and pair with your smart wearable devices, supporting features such as data synchronization.
2 Network Access Permission To identify your current network environment and enable functions that require internet connectivity.
3 Location Access To provide location-based services, such as searching for Bluetooth devices when binding a smart ring.
4 Fitness Permission To display step count and activity data. If you choose to sync device data (including steps) to other platforms, this permission must be enabled.
5 Storage Permission To store local data, support application functionality, and fulfill content storage requirements. You can manage these permissions through the path: Settings > Apps > App management > Doctor HHH > Permission (for Android) or Settings > Apps > Doctor HHH (for iOS).
6 Camera Permission Used for setting and uploading profile photos. When you actively take or select a photo and confirm the action, the system will store your photo.
7 Nearby Devices Permission Required for Android 12 and later versions to support the connection of wearable devices (not applicable to iOS devices).
8 Notification Permission Used to send notifications from the application, including those related to devices, fitness activities, and system alerts.
9 Microphone Permission Enables voice input functions, such as converting speech to text.
10 Third-Party SDK Integration Permission In collaboration with third-party software providers and to offer you more comprehensive and high-quality products and services, certain features may be provided through third-party software development kits (SDKs), such as push notifications. For this purpose, we have integrated software tools or similar components from our partners. For more details, please refer to our partners' Third-Party SDK List.

(B) Privacy Policy

We are committed to protecting the privacy, confidentiality, and security of the personal data in our possession, and we comply with the requirements for personal data management under the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong (the "Ordinance").

(C) How We Disclose Your Personal Information

We may disclose your personal information under the following circumstances:

We may process and disclose your personal data to Our Partners for specific, explicit, and legitimate purposes necessary to provide the requested services. Our Partners are not authorized to use the shared personal information for any other purposes. However, we do not accept responsibility for, nor do we have control over, the privacy and data protection policies of Our Partners.

(D) How We Protect Your Personal Information

We take the security of your personal information seriously. We will take all reasonable and feasible measures to protect your personal information from unauthorized access, disclosure, use, modification, or alteration.

We employ a range of measures to protect your personal information. For example, we use encryption technologies to ensure data confidentiality; we implement protective mechanisms to prevent malicious attacks on data; and where necessary, we may adopt additional measures to protect your personal information from unauthorized access, disclosure, modification, destruction, or loss.

We will organize security and privacy training programs to raise awareness among employees about the importance of protecting personal data.

We will take all reasonable and feasible steps to ensure that we do not collect irrelevant personal information. While we strive to protect your personal data, you acknowledge and accept that no security measures are perfect.

We will retain your personal information only for the period necessary to fulfill the purposes outlined in this Policy. After the retention period, we will either delete or anonymize your personal information, unless required by laws or regulations. The data retention periods for related services are as follows:

Your DR H Account Information: Your account, profile picture, nickname, phone number, and email address will be encrypted during transmission and stored on our servers until you deactivate your account, at which point the information will be automatically deleted.

Additionally, if our products or services cease operations, we will notify you via push notifications, announcements, or other means, and will delete or anonymize your personal information within a reasonable time frame.

(E) How We Handle Personal Information of Minors

Our products and services are primarily aimed at adults. If you are a minor, we recommend that you ask your parents or legal guardians to carefully read this Policy, and use our services or provide information to us only after obtaining their consent.

If you are a child under the age of 18 (regardless of local laws or customs regarding the definition of a child, we consider anyone under 18 as a child), we will not permit you to use our services or provide information to us without the consent of your parents or legal guardians. Children under 18 are prohibited from creating user accounts without parental or guardian consent.

In cases where we collect personal data from children, we will do so only where permitted by law, with explicit parental or guardian consent, or when necessary to protect the child.

If allowed by law, with parental or guardian consent, or if necessary to protect a child, we may use or disclose the data. If we discover that we have collected personal data from children without parental consent, we will make every effort to delete this data as quickly as possible.

If you are a parent or legal guardian, please be aware of whether your child is using our services with your consent. If you have any concerns about your child's personal information, please contact us.

(F) Our Third-Party Service Providers and Their Services

We cannot control the privacy and data protection policies of third parties, and such third parties are not bound by this Policy. Before submitting personal information to any third party, please review that third party's privacy policy.

(G) How Your Personal Information May Be Transferred Globally

We provide our products and services through resources and servers located worldwide. This means your personal information may be transferred to or accessed from jurisdictions outside the country or region where you use our products or services. These jurisdictions may have different data protection laws or none at all. In such cases, we will ensure that your data receives protection equivalent to that required by all applicable laws and regulations.

(H) Data Retention

We take all feasible measures to ensure that the personal information we collect is not retained for longer than is necessary to fulfill the purposes for which it was collected (including any directly related purposes), unless we are legally permitted to extend the retention period.

(I) Updates to This Policy

We reserve the right to update or modify this Policy from time to time. By continuing to use DR H products, we will assume you agree to the updated or modified Policy.

You can view the latest version of this Policy on DRH App.

(J) Access

You have the right to request access to and/or correction of your personal information held by us in accordance with the Ordinance.

To make an access request, please complete the Access Request Form No. OPS003 issued by the Privacy Commissioner for Personal Data or any other form prescribed by the Privacy Commissioner for Personal Data, Hong Kong.

Any access or correction requests may be made to our Data Protection Officer via the following:

Name: Haichuang Intelligent Technology Co., Ltd.

Address: Room 620, 6/F, Tower 16W, Phase 3, Hong Kong Science Park, Pak Shek Kok, New Territories, Hong Kong

Email: service@doctorhhh.com

(K) Inconsistency Between Language Versions

In case of any inconsistency between the English and Chinese versions of this Policy, the English version shall prevail.

(L) Governing Law and Jurisdiction

This Policy shall be governed by and construed in accordance with the laws of Hong Kong, and you hereby irrevocably submit to the non-exclusive jurisdiction of the courts of Hong Kong.