Privacy Policy

Consent to installation of the App

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided in our PRIVACY POLICY and it is important that you read that information.

Before installation of this App, please indicate your consent to our processing of your personal data (including your name, email address and device information) as described in the PRIVACY POLICY.

If you are below the age of 18 years, such consent must be given or authorized by the holder of your parental responsibility, who shall read and follow the instruction of our GUARDIAN WRITTEN CONSENT AGREEMENT.

YES I consent to the installation of the App for the purposes of installation and use of Wearbuds mobile application software and related services.

NO I do not consent to the installation of the App.

How you can withdraw consent

Once you provide consent by selecting "YES", you may change your mind and withdraw consent at any time by contacting us but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

We, Shenzhen AUKEY Smart Information Technology Co., Ltd., are committed to protecting your personal data and respecting your privacy.


This privacy policy, together with our TERMS & CONDITIONS and any additional terms of use incorporated by reference into the TERMS & CONDITIONS, applies to your use of:

•   Wearbuds mobile application software (App) available on APPSTORE or other mobile application distribution platforms where you download the App (App Site), once you have downloaded or streamed a copy of the App onto your smartphone or handheld device (Device).

•   Any of the services accessible through the App (Services) that are available on the App Site or other sites of ours (Services Sites). This privacy policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This App is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

Shenzhen AUKEY Smart Information Technology Co., Ltd. is the controller and is responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy).

If you have any questions about this privacy policy, please contact us using the details set out below.

Contact details

Our full details are:

•   Full name of legal entity: Shenzhen AUKEY Smart Information Technology Co., Ltd.

•   Email address:

•   Postal address: Building P03, South China City Electronics Trading Center, Longgang District, Shenzhen, Guangdong, 518111, China

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), or other competent supervisory authority of an EU member state.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on [*]. It may change and if it does, these changes will be posted on this page and, any other places we deem appropriate, so that you are aware of the information that we collect, as well as how we use, and under what circumstances, if any, we disclose such information. If there is any change to this privacy policy due to update of this App, an updated privacy policy will be displayed on-screen when you download the new version, and you may be required to read and accept the updated privacy policy to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

The data we collect about you

In order to provide you with our services, we will ask you to provide the necessary personal data, without which we may not be able to provide you with our products or services.

We will only collect the necessary personal data for a well-defined, clear and legitimate purpose and will not process it in a manner inconsistent with the above.

We may collect, use, store and transfer different kinds of personal data about you as follows:

•   Profile Data: includes your username and password, email address, gender, age.

•   Health Data: heart rate, height, weight, exercise details, sleep conditions.

We do not collect any special categories of personal data about you (including details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process your Profile and Health Data that you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, enter a competition, promotion or survey and when you report a problem with an App, our Services, or any of Our Sites, if any. If you contact us, we will keep a record of that correspondence.

How we use your personal data

We will only use your personal data when the law allows us to do so.

Most commonly we will use your personal data in the following circumstances:

•   Where you have consented before the processing.

•   Where we need to perform a contract we are about to enter or have entered with you.

•   Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

•   Where we need to comply with a legal or regulatory obligation.

Disclosure of personal data

We may disclose your personal data to our affiliates and/or to service providers engaged by us (together Third Party Service Providers) to assist us in providing services to you, such as cloud computing service providers to provide cloud storage services. We contractually require Third Party Service Providers to abide by our data privacy and security requirements in accordance with applicable law.

To the extent required by applicable laws, we may also disclose your personal data to relevant parties, which may include law enforcement agencies and courts.

Purposes for which we will use your personal data
Type of data
Lawful basis for processing
To install the App and register you as a new App user
Profile, Health
Your consent
To manage our relationship with you including notifying you of changes to the App or any Services
Profile, Health
Your consent
Performance of a contract with you
Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)
Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and this App including troubleshooting, data analysis and system testing
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

You may find out more about the types of lawful basis that we will rely on to process your personal data as follows:

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

International transfers

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

•   We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

•   Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

•   We will implement appropriate safeguards in order to ensure that all such transfers meet the requirement of applicable laws.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

All information you provide to us is stored on our secure servers encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We will collect and store personal data on your Device using application data caches and other technologies.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

We will retain your personal data as may be necessary for the carrying out of the purposes stated in this privacy policy or comply with applicable laws. We will no longer retain your personal information or delete relevant information relating to certain individuals if we reasonably believe that retention of your personal data are no longer necessary for the carrying out of the purposes stated in this privacy policy.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

•   Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

•   Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

•   Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

•   Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

•   Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a)   if you want us to establish the data's accuracy;

(b)   where our use of the data is unlawful but you do not want us to erase it;

(c)   where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d)   you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

•   Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

•   Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

•   Not to be subject to automated individual decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.