Effective Date: September 9, 2024

We highly value your privacy and are committed to providing a safe and reliable app experience.

This privacy policy aims to explain our privacy protection and data processing practices in the Magic Motion app (hereinafter referred to as “the App”). We hope to help you understand how we collect, use, update, manage, export, and delete your information.

Scope of the App

The App is intended for users aged 18 and older. To use the App, you must confirm that you are at least 18 years old. We do not knowingly collect personal data from users under the age of 18. If we discover that we have inadvertently collected data from minors, we will promptly delete the data and will not use it for any purpose. You can report such cases to our customer support team.

Scope of the Privacy Policy

This privacy policy does not apply to offline data or data from our other applications and websites, including websites you access through the App. Our websites, other applications, and third-party services may have different privacy policies. Please carefully review these policies before providing information. If you disagree with our privacy policy, please do not download or use the App.

App Features and Personal Information Collection

The Magic Motion device can be used without installing the App. After installing the App, you can choose to control the device via Bluetooth or the internet. During the installation or use of the App, we will not require personal privacy information from you. If you need to control the device remotely over the internet, you will need to create an anonymous account.

Who We Are and How We Process Your Data

We collect your data either directly when you provide it or automatically when you use the App. If personal data is involved, we will notify you within the App and obtain your consent. When processing personal data from EU users, we comply with the provisions of the General Data Protection Regulation (GDPR) 2016/679.

Shanghai Maylian Industrial Co., Ltd. is the controller of the personal data you (the data subject) provide and is responsible for determining how to use and process this data.

Types of Anonymous Data We Collect

● Anonymous ID
● Avatar
○ We provide cartoon anonymous avatars for you to choose from.
○ User-uploaded custom avatars are associated with the anonymous ID. The system does not encourage uploading identifiable avatars. It will not attempt to recognize the user’s identity through the avatar, nor will it associate the avatar with any personal data. Therefore, avatars are considered anonymous data in our system.
● Chat content (text, images, audio)
● Device type and model
● Running process information
● Sensor information (e.g., detecting the device’s inverted state via the accelerometer to control vibration)

The above anonymous data is not associated with your personal data, which refers to information that can identify you, such as your name or contact details.

Permissions Required for the Android Version of the App

• Bluetooth permission: Used when scanning for peripheral devices and prompting the user to manually enable Bluetooth.
• Location permission: Starting with Android 6.0, location permission is required to use Bluetooth. We use location permission only in this context to scan and connect Bluetooth devices. While location permission is enabled, we will not access, record, or use your location information in other scenarios.
• Network permission: Used to store anonymous IDs, avatars, and device information in the cloud and sync chat content.
• Recording permission: Used to send voice messages and use voice control features.
• SD card permission: Used to access the SD card when setting avatars.
• Vibration permission: Used for message notification vibrations.
• Camera permission: Used to set avatars and take photos.
• Access software list: Used to check whether related applications are installed during quick login.
• Autostart permission: Used to ensure that music functionality and background control of Bluetooth devices work properly. Users can manage autostart permissions in the settings.

Permissions Required for the iOS Version of the App

• Bluetooth permission: Used to connect to the smart massager.
• Camera permission: Used to set avatars and take photos during remote chatting.
• Photo library read/write permission: Used to create avatars and send photos.
• Network permission: Used to store and sync information in the cloud.
• Microphone permission: Used for voice control and recording during remote chatting.

Purposes and Legal Basis for Personal Data Processing

We comply with GDPR regulations to ensure the accuracy and security of personal data and take appropriate measures to protect it. The purposes of processing personal data include:

• Providing and improving services
• Enabling essential app features

Upon first launching the App, we will ask you to provide a nickname and assign you a unique anonymous identifier. This identifier is used for remote chat functionality, allowing your chat partner to recognize you and share control of the device.

Clipboard write feature: Use this to copy invitation codes when inviting friends.

Chat records are encrypted and stored on the server for three days. If you share personal data in the chat, it will be stored as part of the chat record. We also process your personal data to:

• Comply with legal obligations
• Protect vital interests of you or others
• Perform public tasks
• Pursue legitimate interests

If we process special categories of personal data (e.g., race, religion, health), we will obtain your explicit consent before processing.

Location of Data Processing

Your personal data is stored on Amazon servers located in the United States. Our data service engineers are located at Room 508, 1888 Yishan Road, Shanghai, China. When necessary, they will log in to Amazon servers to process your data.

Data Protection and Retention

We have implemented administrative, technical, and physical measures to protect personal data from theft, loss, and unauthorized access. Access to relevant data is limited to necessary employees and authorized third-party service providers. Data will be deleted when no longer needed, and chat records are irreversibly destroyed after three days.

Data Sharing

We keep your personal data confidential and will only share it with third parties with your explicit consent. Non-personal information may be disclosed to other company members or third parties to improve products and services. The types of non-personal information we may disclose and their purposes include:

● Device information: Includes device model, operating system version, and system language. These are primarily used for:
○ Technical support and troubleshooting: Helps us identify and resolve issues related to specific devices.
○ Statistical analysis: Analyzes the usage of different types of devices to optimize the App and enhance the user experience.

We ensure that any shared data is appropriately de-identified and anonymized to protect your privacy.

Data Storage and Analysis

Except for using remote chat and DreamLab features, data for other control functions will be stored on your phone. We also use third-party services to collect anonymous analytical data to help improve the App. Users can opt in or out of anonymous data collection.

Third-Party SDK Information

We use third-party SDKs to implement app features, as detailed below:

SDK Name: QQ SDK
Third-Party Company Name: Tencent Computer System Co., Ltd.
Purpose: To provide QQ login and sharing functionality
Personal Data Collected: Device identifier information (IMEI, IDFA, IDFV, Android ID, MEID, MAC address, OAID, IMSI, ICCID, hardware serial number), network access, network status, user identifier information, phone status and identity
Privacy Policy Link: https://privacy.qq.com/policy/tencent-privacypolicy

SDK Name: WeChat SDK
Third-Party Company Name: Tencent Computer System Co., Ltd.
Purpose: To provide WeChat login and sharing functionality
Personal Data Collected: Device identifier information (IMEI, IDFA, IDFV, Android ID, MEID, MAC address, OAID, IMSI, ICCID, hardware serial number), network access, network status, user identifier information, phone status and identity
Privacy Policy Link: https://privacy.qq.com/policy/tencent-privacypolicy

SDK Name: RongCloud SDK
Third-Party Company Name: Beijing Yunzongrongxin Network Technology Co., Ltd.
Purpose: We use the RongCloud SDK to implement instant messaging functionality. During this process, your device and related information will be collected anonymously to analyze and improve service quality.
Personal Data Collected: Device brand, device model, Android device ID (ANDROID_ID), iOS device ID (deviceToken), operating system version, CPU information, memory usage, IP address, network access method and type, timezone, language, IDFV
Privacy Policy Link: https://doc.rongcloud.cn/rcloud/-/-/privacy#%E4%BA%8C-imkit-sdk

Your Rights

Under the GDPR, you have the following rights regarding the personal data we store:

• Access a copy of your personal data
• Correct inaccurate or outdated data
• Delete data no longer needed
• Withdraw consent for processing
• Request data portability
• Restrict or object to processing

Reporting Feature

We provide a reporting feature to maintain a healthy chat environment.
Path: Click the avatar - User profile - Top-right icon - Report.
After a report is made, we will review and handle the relevant content.

Account Deletion

Once your account is deleted, you will no longer be able to use our services.
To delete your account in the App: “Settings - Delete Account.”
Deletion is immediate.

Data Transfer

Your personal data is stored on Amazon servers in the U.S. and may be transferred to Mainland China for processing. We ensure the security and privacy of your data during the transfer process.

Further Processing

If there are new uses of your personal data, we will notify you and obtain your consent before processing.

Changes to the Privacy Policy

● General Updates: Updates to this privacy policy will be published on our official website. We recommend regularly visiting this link to review the latest version of the privacy policy.
● Major Updates: For significant changes affecting user rights or privacy protection, we will notify you via an in-app system notification.

Contact Information

For complaints about personal data processing, please contact us at dataservice@magicsmotion.com or write to us at Room 508, No. 1888 Yishan Road, Shanghai, China. We will address your complaint and assist in resolving the issue.

Shanghai Maylian Industrial Co., Ltd.