Privacy Policy

Updated: January 10, 2025

Effective: January 10, 2025

This Privacy Policy contains the following sections:

I. Introduction

II. Cookies and Similar Technologies

III. How We Collect and Use Your Information

IV. How We Collect and Use Your Information

V. How We Store and Protect Your Personal Information

VI. Your Rights

VII. How We Protect the Personal Information of Minors

VIII. How This Policy is Updated

IX. Contact Us

I. Introduction

JR Audio, which stands for JOYROOM Audio, is an application offered by Shenzhen JOYROOM Technology Co.,Ltd.(hereinafter referred to as "we" or "us") for you to set up JOYROOM audio.It enables features including gesture settings, sound settings, earbuds firmware OTA update, and more.

We take your privacy very seriously. This Privacy Policy has been developed with YOU in mind. It is critical for you to fully understand how we collect and use your personal information, ensuring you maintain control over the information you provide to us. This Privacy Policy outlines how we collect, use, disclose, process, and store the information you share when using our JR Audio APP (hereinafter referred to as "the APP").

II. How We Collect and Use Your Information

(i) Circumstances in which you must authorize us to collect and use your personal information

We will follow the principles of propriety, lawfulness, transparency, and necessity to collect and use the personal information that you voluntarily provide to us in the course of, or as a result of, using our products/services for the following purposes as set out in this Privacy Policy. If we are going to use your personal information for purposes other than those stated in this Privacy Policy, or if we are going to use your personal information collected for a specific purpose in another way, we will inform you in a reasonable manner and apply for your consent again before using it.

Please note that sensitive personal information has been underlined to serve as a special reminder for you to pay close attention to while reading. Before providing us with any sensitive personal information, you should have carefully considered and hereby confirmed that such provision is appropriate. Furthermore, you agree that your personal sensitive information be processed for the purposes and in the manners specified in this Policy.

1. Binding the Earbuds

In order to support the binding of your earbuds to the APP, we may collect the identification information of your earbuds, including device name, model number, unique device identifier, firmware version, MAC address.The information mentioned above is essential personal data required for this feature. If you decline to permit us to process this information, you will be unable to use the Bluetooth feature to connect your earbuds.

2. Displaying Earbuds Details

During the process of connecting your JOYROOM device, we need to collect such information as the model number of your JOYROOM device and the version number of the JR Audio APPto display the device's image on the function details page, earbuds management page, and device search page. The information mentioned above is essential personal data required for this feature. If you decline to permit us to process this information, the name, images, and functions of the earbuds will not be displayed.

3. Updating Earbuds Firmware

In the JR Audio APP, you can view the firmware information of your earbuds, and check for and update the current firmware. For this, we need to collect such information as the model number and the firmware version number of your JOYROOM device. The information mentioned above is essential personal data required for this feature. If you decline to permit us to process this information, you will be unable to update the firmware version of your earbuds.

4. APP Update Detection and Download

We will regularly detect new versions of the APP and, with your consent, download them. To determine if updates are currently available, we need to collect such information as the device model number, the system version number, and the APP version number. The information mentioned above is essential personal data required for this feature. If you decline to permit us to process this information, the APP will not automatically prompt for an update.

n addition, to provide you with the corresponding business functions or services, we may need to access specific device permissions, but only to the extent necessary. Please rest assured that when obtaining particular permission, we will do so strictly within the scope of your authorization, acquire only the relevant information (if involved), and seek your individual consent for accessing any sensitive personal information. Once you have granted authorization, you can withdraw it at any time by navigating to the "Settings" on your mobile device (note that the authorization management page may vary depending on the model and system version; please refer to the actual page). Upon withdrawal of your authorization, we will immediately cease accessing the corresponding permissions.

Request Device Permissions Purpose of Permission Request Inquire before Enabling Permissions Disable Permissions by User Impact of Disabling/Denying Permission Request
Obtain location information Search for devices to quickly connect to them Yes Yes Unable to discover devices, thus unable to connect to them via JR Audio
Use Bluetooth Complete Bluetooth scanning and Bluetooth connection between JR Audio and the device, and provide device management, function settings, and transmit firmware update package through Bluetooth data interaction Yes No Unable to scan for Bluetooth earbuds, connect to them, or perform function settings and firmware updates via JR Audio
Request APP installation JR Audio requests to install the APP after the self-update download is complete Enabled by default No Unable to request APP installation

(ii) You are fully aware that in the following circumstances, our collection and use of your personal information do not need your consent:

1. It is related to the fulfillment of obligations stipulated by laws and regulations by the personal information controller.

2. It is directly related to national security and national defense security.

3. It is directly related to public safety, public health, and significant public interests.

4. It is directly related to criminal investigation, prosecution, trial, and execution of judgments.

5. It is necessary for safeguarding the vital legitimate rights and interests, such as life and property, of the personal information subject or other individuals, and it is difficult to obtain the subject's authorization and consent.

6. The personal information involved is disclosed to the public by the personal information subject.

7. It is necessary for signing and performing contracts as required by the personal information subject.

8. Personal information is collected from legally disclosed sources to the public, such as legitimate news reports and government information disclosure channels.

9. It is necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and handling product or service failures.

10. The personal information controller is a news organization, and it is necessary for legitimate news reporting activities.

11. As an academic research institution, the personal information controller collects and uses personal information for statistical or academic research in the public interest. When externally disclosing research outcomes or related descriptions, all personal information is de-identified to protect individual privacy.

IV. How We Collect and Use Your Information

(i) Sharing

To provide you with more comprehensive and superior platform services, we may share your personal information with third parties, such as affiliated companies and partners. We assure you that this sharing will only occur for lawful, justified, necessary, specific, and exact purposes, and we will seek your individual consent as explicitly required by relevant laws and regulations. And these third parties are strictly forbidden from utilizing the shared personal information for other purposes. We will enter into data protection agreements with our partners, explicitly outlining their duties and obligations regarding safeguarding your personal information.

If you decline to permit our partners to gather the necessary personal information required for delivering specific services, you may not be able to use this platform or enjoy the services offered by our partners. Except for the following situations and unless otherwise agreed in this Policy, we will not share your personal information with any third party:

1. To fulfill functional requirements, we collaborate with third-party Software Development Kit (SDK) service providers and integrate some functional SDKs. Please be informed that such SDKs do not collect personal information nor utilize sensitive permissions.

(ii) Transferring

Except for the following situations, we will not transfer your information to any entity:

● With your explicit consent.

● In the event of a merger, acquisition, or sale of all or part of our assets that may impact your personal information, we will notify you via email and/or by posting prominent notices on our website or through other appropriate channels of any changes to the ownership or use of your personal information, as well as any options you may have regarding your personal information.

● In circumstances that have been explained in this Privacy Policy or otherwise communicated to you.

(iii) Disclosing

In the following situations, we may publicly disclose your personal information:

● When announcing the winners of promotions, contests, or prize draws, we'll only reveal limited details.

● When we've received your explicit consent or when you disclosed the information through our services, such as on social media pages or public forums.

● When disclosure is required by law or based on legitimate reasons, including legal and regulatory requirements, legal proceedings, litigation, or in response to requests from governmental authorities.

V. How We Store and Protect Your Personal Information

(i) Storage Location

In principle, we will store the personal information collected and generated during our operations within the territory of the People's Republic of China, within the territory of the People's Republic of China. Given that we offer products/services through a global network of resources and servers, your personal information may be transferred to or accessed from jurisdictions outside the country/region where you are utilizing our products/services. In such jurisdictions, where personal information protection laws may differ, we will do our utmost to ensure that your personal information receives protection that is equivalent to that in the People's Republic of China.

Only in the following situations, and with the requirements of relevant laws, regulations, and regulatory authorities fulfilled, will we provide your personal information to overseas entities. Meanwhile, we will strictly request the recipients to handle your personal information in line with the relevant laws, regulations, and provisions of this Policy:

(1) There are explicit provisions in laws and regulations.

(2) We have obtained your individual consent.

(3) The products and/or services you are using involve cross-border activities, and you have voluntarily provided your personal information abroad.

(ii) Safety Measures

We commit to ensuring the security of your personal information. To prevent unauthorized access, disclosure, or other similar risks, we have implemented all legally required physical, electronic, and administrative measures and procedures to protect the information we collect from your mobile device. We will safeguard your personal information in compliance with applicable laws.

All your data is stored on secure servers and protected within controlled facilities. We categorize your information according to its importance and sensitivity, ensuring that your personal information has the appropriate level of security. Similarly, we have specific access control measures for cloud-based data storage, and we regularly review information collection, storage, and processing practices, including physical security measures, to prevent any unauthorized access and use.

We will take all feasible and legally required measures to safeguard your personal information. However, please be aware that the Internet is not always secure. Consequently, we cannot assure the security or integrity of personal information during its bidirectional transmission over the Internet.

In the event of any personal information breach, we will adhere to the applicable data protection regulations and, as necessary, promptly inform both the relevant regulatory authorities and the affected data subjects of the breach.

(iii) Retention Policy

We retain personal information for the duration necessary to fulfill the purpose of information collection outlined in this Privacy Policy, or as required by applicable laws. Once the purpose for collection has been achieved, or upon confirmation of your request for deletion or cancellation, or upon the termination of our operation of relevant products or services, we will cease retention and proceed to delete or anonymize the information.

VI. Your Rights

(i) Control Settings

We acknowledge that everyone has different concerns regarding privacy rights. Therefore, we provide examples illustrating various ways our devices offer for you to choose to limit the collection, use, disclosure, or processing of your personal information and control your privacy settings:

● Through [My Devices]-[Add Device]/[Remove Device], you can pair/unpair your earbuds.

VII. How We Protect the Personal Information of Minors

We won't automatically identify the age of users or take the initiative to engage in activities such as collecting, storing, using, transferring, or disclosing children's personal information (minors under the age of fourteen) through the Internet or other means. If you're a parent or legal guardian of a child, or if you find out that we've collected, stored, or used any personal information of a child via other channels, please promptly contact us via the contact details provided in this Policy. We'll do our best to delete the information swiftly.

VIII. How This Policy is Updated

We will regularly review this Privacy Policy based on changes in our business and services, and may update it from time to time. If we make significant changes to this Privacy Policy, we will notify you via in-APP pop-up alerts so that you can stay informed about the information we collect and how we use it. Such changes to this Privacy Policy will apply from the notified update date. We recommend that you periodically review the in-APP Privacy Policy for updates on our privacy practices. Should we need to collect more personal information from you or use/disclose your information for new purposes, we will apply for your consent again.

IX. Contact Us

If you have any suggestions or questions about this Privacy Policy or any concerns regarding our collection, use, or disclosure of your personal information, please contact us at <support@joyroom.com>. Generally, we will make a response within fifteen business days. Should you find our response unsatisfactory, you may hand over your complaint to the relevant regulatory authority in your jurisdiction.