Welcome to the products and/or services provided by this Application. This Application is a mobile application (hereinafter referred to as the “Product”) developed by Shanghai United Imaging Microelectronics Technology Co., Ltd. (hereinafter referred to as “we”, “us” or “our”). We fully understand the importance of protecting personal information (especially sensitive health information) and strictly comply with personal information protection laws and regulations of various countries and regions around the world. We hereby formulate this Policy to clearly and transparently inform you of our rules for processing personal information, and to fully protect your personal information and privacy rights.

This Privacy Policy (hereinafter referred to as “this Policy”) describes how we collect, use, share, transfer, entrust processing, store, delete and protect personal information related to hearing aid use and hearing health (including sensitive personal data/special categories of personal data, such as hearing data, health conditions, biometric-related data, etc.). It covers all personal data processing activities when you use the Application and access and use supporting services of this Product through relevant technologies.

The general provisions of this Policy apply to users of this Product worldwide. For privacy regulatory requirements of specific countries/regions, we have added a section of regional special notices, which shall prevail for users of the corresponding regions. In case of any conflict between the general provisions and the regional special notices, the regional special notices shall prevail.

Please carefully read and fully understand this Policy before continuing to use this Application, and make appropriate choices based thereon. If you do not agree to the contents of this Policy, our core services may be unable to be provided normally, or the preset functions of the Product may not be realized. Your agreement to this Policy only means that you have understood the functions provided by this Product/service, the scope of necessary personal information required for the operation of such functions, and our compliant processing rules. We will separately seek your consent for the collection of sensitive personal information and system permissions, and will not grant authorization by default.

In accordance with the requirements of your country/region, we will strictly abide by local laws and regulations in processing your personal data. During your use of this Application, we will separately inform you and obtain your explicit consent for sensitive personal information and system sensitive permissions; relevant permissions will not be enabled by default, and will only be enabled after we separately inform you and obtain your separate consent when you use the corresponding business functions. After enabling permissions, you may turn off the permissions at any time through device settings; your refusal to enable non-essential permissions will not affect the normal use of other unrelated business functions.

We may update this policy from time to time. If the updated content involves changes to your core rights and interests, we will notify you through prominent means such as APP pop-up windows and in-app messages, provide you with a way to independently choose to consent, and conduct the updated data collection and use activities only after obtaining your explicit consent. For updates involving only optimization of compliant expressions or adjustments to non-core provisions, we will directly publish them within the APP, which shall take effect upon publication.

If you have any questions, comments, suggestions or privacy-related complaints regarding this Policy, you may contact us at any time through the contact information set forth in this Policy.

This Policy will help you understand the following core contents:
1. How we collect and use your personal information;
2. How we use cookies and similar technologies;
3. How we entrust processing, share, transfer and publicly disclose your personal information;
4. Cross-border transfer of personal information;
5. How we store and protect your personal information;
6. Your rights as a personal information subject;
7. How we protect personal information of minors;
8. How this Privacy Policy is updated;
9. How to contact us;

Specifically, we will collect and use your personal information in the following circumstances or for the following purposes:

To receive our products and services, you first need to register and log in to this APP. You may register and log in via one-click login with your local mobile phone number; you may also log in via WeChat, or directly provide your mobile phone number to register and log in by obtaining an SMS verification code.
When logging in via WeChat, we will obtain your WeChat nickname and avatar to create your account.
Logging in via WeChat or registering and logging in via mobile phone number also requires you to provide your mobile phone number. We will verify the validity of your identity and create a user account for you by sending an SMS verification code. After becoming a registered user, you may supplement or modify your relevant information in 【Me】-【Settings】, and further improve your account information of this Product (including your city). If you refuse to provide your mobile phone number or SMS verification code, registration will fail, and you may be unable to continue using the complete functions or services of our products.

When you use this Application to connect to a hearing aid, this Application will inform you and obtain your separate consent before invoking the following system permissions related to personal information: Bluetooth and location permissions, for connecting to your hearing aid device. After you grant authorization, we need to read the device information of your hearing aid; if you refuse to authorize Bluetooth and device location information, we will be unable to provide device connection and device information viewing services, but this will not affect your normal use of other functions and services of this Application.

When you use the remote service function, we will inform you and obtain your separate consent before invoking the following system permissions related to personal information: camera (camcorder) and microphone permissions. After you grant authorization, you may conduct a video call with your hearing health professional remotely to complete the remote service function online. If you do not grant authorization, we will be unable to provide such business function, but this will not affect the normal use of other functions and services.

You may use this APP to view your hearing report. Information related to the report includes: name, gender, date of birth, fitting experience, hearing aid information and report time, your audiogram information, and your hearing aid and hearing aid parameter configuration information. If the hearing health professional has not sent the hearing report, you will be unable to view the report information on the APP, but this will not affect the normal use of other functions and services.

When you submit user feedback, we will separately inform you and obtain your explicit consent before invoking the camera (camcorder) and photo album (storage) permissions. You may voluntarily upload photos to assist in describing problems; meanwhile, you may independently choose whether to upload device operation logs, facilitating the R&D team to accurately analyze problems and optimize services.

When you voluntarily choose to fill in a questionnaire survey, you may voluntarily provide information such as age, gender, hearing loss information, duration of hearing aid use, and degree of hearing loss. Filling in the questionnaire is voluntary; you may refuse to fill it in, which will not affect the normal use of any product functions.

To facilitate your management of personal accounts, we will collect and use account-related information, including name, email address, password, contact number, country/region, and hearing aid device type and settings. Please note that you must truthfully fill in your country/region of residence, as this information will determine the storage region of your personal data; after creating an account, changing your country/region selection will not affect the data storage location, i.e., the data location will remain the country/region you initially defined.

To further improve products, conduct relevant research and provide proper after-sales services, we will collect and combine your personal information, hearing aid usage and identification information, which requires you to create an account and complete login. Specifically collected information includes:
- Health data (age, weight, height, gender, step count, activity level, wearing time, charging periods, usage time in different acoustic environments, streaming media playback time, heart rate, distance, step and wearing time goals, calories);
- Hearing aid information (serial number and wearing side).

If a fault occurs during your use of the Product and requires troubleshooting, we may process the fault by sharing log files. Such log files generally do not contain your personal data and will not disclose your private information.

To ensure the normal operation of hearing aids and the APP and support your independent debugging of devices, we will collect:
- Data stored in hearing aids by hearing health professionals (date of birth, age, gender, audiogram);
- Hearing aid product identifiers (product name, hearing aid type, hearing aid version, main brand, private label, price level, battery type, device type, device options, firmware version, hardware version);
- Personal adjustment settings (including custom fitting adjustments and custom settings, if any).

To provide you with hearing aid fitting and after-sales services, your hearing health professional will process the following personal data of yours:
- Data stored in hearing aids (date of birth, age, gender, audiogram);
- Hearing aid product identifiers (product name, hearing aid type, hearing aid version, main brand, private label, price level, battery type, device type, device options, firmware version, hardware version);
- Bluetooth device name, serial number, hearing aid pairing key;
- Hearing aid usage records (start counter, adjustment records, working hours since first/recent fitting, usage time in various acoustic conditions, total working hours, calibration records, recharging cycles);
- Hearing aid fitting configuration and other operating data (status of your service-registered hearing aid or service registration, IP address, RID number stored on the hearing aid);
- Voice and video conference data (if any).
The above data will be collected by hearing health professionals and shared with us through fitting software. We collect such data for the purpose of analyzing the causes of product faults in after-sales services, continuously optimizing the quality of hearing aids and related accessories, and providing you with more demand-oriented product support. If you do not agree to our collection and use of such data in the above manner, please inform your hearing health professional in a timely manner during the fitting process, or notify us via the email address specified in the “How to Contact Us” section of this Policy, and we will stop collecting and delete relevant data.

As a medical device manufacturer, we are legally obligated to monitor the quality and safety of our medical devices, and monitor the performance of hearing aids and this APP to ensure their normal operation and safe use (i.e., post-market surveillance). For this purpose, we will collect and use the following information:
- Information related to hearing aid connection (e.g., connection status, medical device UID, medical device type and settings, discovery information, pairing information, detailed connection information);
- Hearing aid charging cycles, usage duration, interval log records;
- APP crash data, hearing aid events and abnormal error logs;
- Hearing aid battery-related information (e.g., battery type, charging cycles, capacity, temperature, average current or charging status);
- Technical logs of APP events (e.g., relevant events for detecting and diagnosing performance, safety and other issues, which may involve IP addresses);
- Firmware update reports (e.g., mobile phone-related information, reasons for update failure, battery type);
- And other additional channel information used to support product improvement.

To realize the AI noise reduction function and monitor product features to ensure the quality and performance of hearing aids and the APP, we will collect relevant information, including software build number, sound environment clustering, detected speech direction, noise floor estimation, and signal-to-noise ratio.

To comply with medical device-related laws and regulations, we may merge data collected in the APP with data obtained by us from other legitimate sources (e.g., data collected through fitting software systems). Such merging processing will be strictly limited to the scope necessary for performing legal obligations. All data processing will be conducted in a pseudonymized manner, and strictly follow the principles of transparency, purpose limitation and necessity under the applicable legal framework. For example, when we conduct product quality analysis, we may use anonymized data, combined with user maintenance and service information and product information, to conduct qualitative and quantitative analysis of on-market and in-service devices, so as to continuously optimize product quality.

You may check the enabling status of various permissions item by item on your terminal device, and turn permissions on or off at any time (subject to slight differences depending on terminal devices and operating systems). Please note that enabling these permissions means that you continuously authorize us to collect and use such personal information during your use of our services to achieve the above functions; turning off permissions means that you cancel such authorization, and we will no longer continue to collect and use such personal information of yours, nor provide you with the functions corresponding to such authorization. Your decision to turn off permissions will not affect the processing of personal information conducted previously based on your authorization.
iOS System Permission Invocation
Android System Permission Invocation
*For the above processing activities, the categories of personal data collected may vary depending on your hearing aid model and APP version. The specific service scope, function content and operation method shall be subject to the actual content displayed in the corresponding APP version you install and use. We will only provide corresponding services to you based on the functions built in and technically achievable in the current APP version. For detailed information about hearing aid functions and APP functions, you may contact a hearing health professional or reach us via the email address in this Policy.

To ensure the normal operation of the server side (or scripts), we will use cookies as a mechanism for storing and retrieving information on your terminal device, to store your preference data, determine whether registered users have logged in, provide you with personalized services or promptly identify and prevent security risks, improve service/product quality and optimize user experience.

We will not use cookies for any purposes other than those described in this Policy. You may manage or delete cookies according to device preferences and clear the stored relevant data. Disabling the cookie function may affect your use or prevent you from fully using all products and/or services provided by this Application.

1. Entrusted Processing
To ensure the quality of services we provide, we may entrust partners to process information. In entrusted processing, we will comply with legal and regulatory provisions and regulatory requirements to ensure that your rights and interests are not affected.

2. Sharing
We adopt reasonable security measures to protect personal information, and in principle will not share your personal information with third parties unless we obtain your explicit consent. Currently, we will seek your authorization and consent for sharing personal information in the following circumstances:
(1) Sharing at Your Active Choice: With your explicit consent, authorization or active choice, share with the third party designated by you within the scope of your consent and authorization;
(2) Sharing under Statutory Circumstances: Share the minimum necessary personal information in response to litigation and dispute resolution in accordance with mandatory provisions of laws and regulations or requirements of legal documents issued by judicial/administrative authorities;
(3) Sharing with Third-party Service Providers: We may jointly process your account information and device information with partner third parties to ensure the smooth completion of services provided to you. However, we will only share your personal information for specific purposes and only to the extent necessary for providing services. Our partners have no right to use your personal information for any other purposes. We share your personal information with third-party service providers for the following purposes:
- Product or Technical Services: We may share your personal information with third parties that support our functions. Such support includes providing infrastructure technical services, communication service providers that send short messages on our behalf, data processing, etc. We share such information to realize the core functions of our products and/or services, such as logging in via SMS verification code.
- Analysis Services: Third-party service providers may also collect and/or count individual device information and log information (non-personal information) in an aggregated form. We will use such statistical information to understand the profile of people browsing and/or using this platform, the interaction between people and the platform, or general trends of browsing and/or using this APP, such as statistics on usage volume by country or region. Such use will not involve the identification and tracking of specific subjects.
We will conduct necessary data sharing with authorized third parties through application programming interfaces (APIs) and software development kits (SDKs) to improve product functions and better serve you. Before data sharing with third parties, we will conduct strict security testing on third parties and agree on data protection measures. You may learn about detailed circumstances of data sharing by viewing the <Third-Party Information Sharing List>.

3. Transfer
We will not transfer your personal information to any company, organization or individual, except for the following circumstances:
(1) Obtaining your explicit and separate consent;
(2) In case of merger, acquisition, bankruptcy liquidation, etc., where personal information transfer is indeed required, we will require the transferee to continue to be bound by this Policy; otherwise, we will obtain your separate consent again, except for information required to be retained by laws and regulations.

4. Public Disclosure
In principle, we will not publicly disclose your personal information, and will only disclose the minimum scope of information in accordance with laws and regulations under the following circumstances:
(1) After obtaining your explicit and separate consent;
(2) Disclosure based on law: We may publicly disclose your personal information in accordance with the law under mandatory requirements of laws, legal procedures, litigation or government authorities.

If you select a country/region outside China as your country/region of residence, we may occasionally need to access, transfer or view your personal information outside your country/region of residence to provide you with technical support related to APP use, customer service, and/or carry out APP support and maintenance work.

If relevant technical issues require the support team to view your personal information, the involved personal information may include your full name and email address; in special cases, it may also include health-related information. Such access to personal information will be initiated from China through a secure network, and will only be triggered for the purpose of providing you with necessary technical support, customer service, and/or maintaining the normal operation of the APP, and will not be used for other irrelevant purposes.

If you actively request support from us and share diagnostic/troubleshooting data, we will transfer relevant data to China, but only to the extent necessary to provide you with technical support, conduct systematic problem detection and extensive analysis, and will not additionally collect or transfer irrelevant data.

In addition, some of the aforementioned third-party service providers may operate outside your country/region.

Therefore, all the aforementioned cross-border transfers of personal data may result in your personal data being transferred to jurisdictions with different personal data protection levels from your country/region. In accordance with the applicable laws and regulations of your location, we will seek your explicit consent for such cross-border transfers of personal data. After obtaining your explicit consent, we will strictly fulfill the following commitments to ensure the security of your personal data:
(1) Strictly implement relevant procedures in compliance with applicable laws and regulations to ensure the legality and compliance of cross-border personal data transfers;
(2) Adopt technical and organizational measures such as encryption and access control to ensure that transmitted data is effectively protected and eliminate risks of leakage and abuse;
(3) For users in the EU region, adopt compliant methods such as standard contractual clauses (SCCs) approved by the European Commission and recognized certification mechanisms to protect data security;
(4) Adopt additional supplementary safeguard measures (e.g., conducting cross-border data transfer impact assessments) in accordance with the personal data protection regulations and actual conditions of the countries/regions where third parties are located to ensure that the data protection level meets statutory requirements.

1. Storage of Personal Information
1.1 Storage Period
We will continue to use your personal information provided during your use of this product and services in accordance with the law unless you take the initiative to delete it or refuse our collection; when you delete information, cancel your account or the information exceeds the necessary storage period, we will stop using and delete it. If we are still required to retain such information in accordance with laws and regulations, we will take security protection measures and stop other processing activities.
1.2 Storage Region
We store your personal information in the country/region where the data is collected, or in regions that comply with local regulatory requirements. If cross-border transfer is required, we will strictly perform statutory procedures and carry out the transfer only after obtaining your separate consent.

2. Protection of Personal Information
2.1 Security Protection Measures
To protect personal information from risks such as loss, leakage, damage, unauthorized access and use, we promise to have implemented or will implement practical security protection measures, and adopt various physical, technical and organizational management means to protect your personal information.
Measures we adopt include, for example:
- We use encryption functions such as the Secure Socket Layer (SSL) protocol, encryption technologies to ensure data confidentiality, and trusted protection mechanisms to prevent data from malicious attacks;
- We set special and limited access control permissions for your personal information to ensure that only specific personnel of ours can view or use it when necessary to the fullest extent;
- We classify your personal information according to importance and sensitivity, and ensure that the collection, storage or use of corresponding classifications have corresponding security standards and levels;
- We regularly review, monitor and evaluate the operation status of information security systems such as networks, identify potential information security risks and take corresponding measures.
2.2 Security Incident Management and Handling
In the event of a security incident such as personal information leakage, loss or tampering, we will immediately initiate an emergency response to control risk spread and prevent further damage; for users in GDPR-applicable regions, if the incident poses a high risk to your personal rights and interests, we will report to the local data regulatory authority and promptly inform you of the incident details, risk level, disposal measures taken and risk mitigation measures available to you through APP pop-up windows, SMS, email, etc.
Please note that the Internet is not an absolutely secure environment. If you find personal information leakage or abnormal account status, please contact us immediately through the contact information in this Policy, and we will take timely measures to reduce damage.

3. Your personal information processed by hearing health professionals will be stored and protected in accordance with applicable laws. For more information on specific storage and protection, please contact your hearing health professional.

In accordance with relevant laws and regulations, you may exercise your personal information rights in the following ways:

1. Access to Your Personal Information
You have the right to unconditionally understand all rules for our processing of your personal information and access your personal information; you may directly view account information in the APP 【Me】-【Profile】. If you need to access other personal information, you may apply through the contact information in this Policy, and we will reply within 15 working days after verifying your identity, except for circumstances excluded by laws and regulations.

2. Correction of Your Personal Information
You have the right to correct or modify inaccurate or incomplete personal information at any time, specifically including:
(1) You may modify your personal account through “Me-Settings”;
(2) You may modify your personal information through “Me-Profile”.
If you are unable to access or correct your personal information through the above methods, you may submit a correction request by contacting us as set forth in this Policy, and we will reply to your correction request within 15 working days.

3. Deletion of Your Personal Information
(1) We provide the following methods on this Application to help you delete part or all of your personal information on this Product: you may cancel your account in “Me-Settings” to clear your personal information.
(2) If you need to delete other personal information generated during your use of this Application, you may contact us through the contact information provided in this Policy. After verifying your identity, we will reply to your deletion request within 15 working days.
(3) You may submit a request to us for deleting personal information in the following circumstances:

• If the purpose of our processing of your personal information has been achieved, cannot be achieved or is no longer necessary for achieving the processing purpose;
• If our processing of personal information violates laws and regulations;
• If we collect and use your personal information without obtaining your consent;
• If our processing of personal information violates the agreement with you;
• If you no longer use our products or services, or you cancel your account;
• If we no longer provide products or services to you, or the storage period has expired.

(4) If we decide to respond to your deletion request, we will also notify entities that have obtained your personal information from us to delete it in a timely manner, unless otherwise provided by laws and regulations or such entities have obtained your independent authorization.

4. Restriction of Processing
You have the right to apply to restrict our processing of your personal information under the following circumstances: you dispute the accuracy of personal information, the legality of processing activities is controversial, you need information for litigation rights protection, etc. During the restriction period, we will only store the information and conduct no other processing.

5. Withdrawal of Authorization
You have the right to withdraw the consent granted for personal information processing and permission authorization at any time; after withdrawing consent, we will stop processing corresponding information and be unable to provide corresponding functions, but this will not affect processing activities conducted previously based on your legal consent; withdrawal of consent will not affect your use of core basic services.

6. Account Cancellation
You may cancel your previously registered account at any time. Specifically, you may apply to us for cancellation and deletion of your information through the deletion or cancellation application entry provided in this Application-Me-Settings or the contact information provided in “How to Contact Us” of this Policy. We will respond within 【15】 working days, subject to stricter requirements on response time under local laws and regulations.
After account cancellation, we will stop providing products or services to you and delete your personal information at your request, except as otherwise provided by laws and regulations.

7. Objection to Processing
You have the right to raise objections at any time to data processing conducted based on legitimate interests, and we will stop relevant processing unless we have compelling legitimate reasons to continue processing.

8. Obtaining a Copy of Personal Information
You have the right to obtain a copy of your personal information. You may provide feedback to us through the contact information provided in “How to Contact Us” of this Policy, and we will process your request within 15 working days, subject to stricter requirements on response time under local laws and regulations.
Where technically feasible, such as matching data interfaces, we may also directly transmit a copy of your personal information to the third party designated by you at your request.

9. Response to the Above Requests
To ensure security, you may be required to provide a written request or otherwise prove your identity. We may first require you to verify your identity before processing your request.
In principle, we will respond to your request within 【15】 working days, subject to stricter requirements on response time under local laws and regulations.
If you have any complaints, opinions or suggestions, you may contact us through the contact information provided in 【How to Contact Us】.

10. If your rights involve personal data processed for fitting services, you should contact your hearing health professional.

Users shall accurately provide their date of birth and country/region when creating an account, so that we can determine whether you are a minor in accordance with the laws of your jurisdiction. If the provided date of birth indicates that the user is a minor, account creation may be completed only after obtaining the explicit consent of the guardian (e.g., via email). After confirmation and consent of the guardian, the system will open a corresponding account for the minor.

Parents or other legal guardians may contact us via email at any time to request that we delete the account under the minor’s name to terminate the collection of the minor’s personal information. Account deletion will cancel the account being used by the minor, but we will retain information that has been or is being processed through anonymization, aggregation, pseudonymization and/or de-identification for our product research; meanwhile, we may need to retain part of relevant personal information based on mandatory requirements of laws and regulations.

This Policy will be revised from time to time in accordance with updates of laws and regulations, adjustments to products and services, and changes in compliance requirements. We will not reduce your core rights and interests under this Policy without your explicit consent.
After the Policy is updated, we will publish it at a prominent location within the APP; for material changes, we will separately inform you through APP pop-up windows, SMS, email, etc., and implement the updated processing rules only after obtaining your consent again.
Material changes referred to in this Policy include but are not limited to:
1. Material changes to the purpose, type, scope and method of personal information processing;
2. Material adjustments to the data controller’s subject identity, ownership structure and business scope;
3. Material changes to the objects and scope of personal information sharing, transfer and public disclosure;
4. Material adjustments to your personal information rights and the way of exercising such rights;
5. Changes to the data protection officer, contact information and complaint channels;
6. Other changes that have a significant and substantive impact on your personal information rights and interests.

1. If you have any questions, comments or suggestions regarding this Policy, please contact us through the following means:
Provide feedback to us through 【User Feedback】, or send an email to: UIM-SH-CS@uim-solution.com.
Contact Department: Customer Service Department
Address: 4th Floor, Building 1, No. 333 Huangqing Road, Jiading District, Shanghai
Contact Number: 4008-603-133
2. Regional Exclusive Contact Information: For privacy consultation needs of users in specific regions, we will separately publish regional exclusive contact channels (such as contact information of EU data protection officers), subject to the publication in the APP.
3. To ensure that we efficiently handle your questions and provide timely feedback to you, we may require you to submit identity certificates, valid contact information, written requests and relevant evidence according to the requirements of specific issues. We will process your request after verifying your identity.
Under normal circumstances, we will reply within 【15】 working days after confirming your identity, subject to stricter requirements on response time under local laws and regulations.