Company
Shenzhen Qinglai Innovative Intelligent Technology Co., Ltd.
Quick Guide to This Policy
- What We Collect: We collect information to create your account, process your orders (including prescriptions), deliver products, provide customer support, operate and improve our services, and conduct marketing. Prescription data is treated as sensitive health information.
- How We Use It: We use your information based on legal grounds, such as to fulfill our contract with you, with your consent, to comply with law, or for our legitimate interests (e.g., security).
- Who We Share With: We do not sell your data. We share it only with essential service providers or as required by law. Tools like Google Analytics may involve "sharing" for advertising.
- Your Rights: You have rights to access, correct, delete, or port your data. California residents can opt-out of "sharing."
- Contact Us: For privacy questions or to exercise your rights, email us at: privacy@memo-mind.com.
This is a summary. Please read the full Policy for complete details.
Important Notice for Users in Mainland China: If you are located in mainland China, please refer to our dedicated Chinese website and privacy policy.
1. General
Thank you for your interest in Shenzhen Qinglai Innovative Intelligent Technology Co., Ltd. and its affiliates ("Qinglai," "Company," "we," "us," or "our"). This Privacy Policy ("Policy") describes how we collect, use, disclose, and protect your personal information when you visit our website at www.memo-mind.com ("Site"), use our software applications, purchase our hardware products (such as smart glasses), or otherwise interact with our services (collectively, "Qinglai Products and Services").
2. Information We Collect
We collect "Personal Information," which is information that identifies, relates to, describes, or can be reasonably linked to you. We collect it in three ways:
A. Information You Provide to Us
- Account & Registration: When you create an account or register a product, we collect your email address, phone number, password, username, and profile information (e.g., gender, region, language). This may be collected directly or via third-party logins (e.g., Google, Facebook).
- Order & Payment: When you make a purchase, we collect your name, shipping/billing address, phone number, and order history. Payment details (e.g., credit card information) are processed directly by our payment partners (see Section 4); we do not store full card numbers.
- Prescription Data: If you order prescription eyewear, you provide prescription details and insurance information. This is sensitive health data handled with heightened care.
- Communications: When you contact customer support, participate in surveys, or use AI chat features, we collect your contact details, communication content, and any information you choose to provide.
- Marketing Preferences: When you subscribe to newsletters, we collect your email address.
B. Information Collected Automatically
- Device & Usage Information: When you use our Site or connect Qinglai hardware, we automatically collect:
- Technical Data: IP address, browser type, operating system, device identifiers, network provider.
- Usage Data: Pages viewed, time spent, clickstream data, access times, browsing history, purchase history.
- Product Data (for hardware): Device model, serial number, firmware version, connection status (Wi‑Fi/Bluetooth), basic operational logs, and error reports for functionality, support, and safety. Media files you capture (photos/videos) are typically stored locally on your device unless you choose to upload them to our cloud services.
- Location Data: With your explicit consent (managed in device/app settings), we may collect approximate or precise geolocation to provide features like location tagging, safety notifications, or lost device finding.
- Cookies & Similar Technologies: We use cookies, pixels, and local storage. For details, see our Cookie Policy.
C. Information from Third Parties
We may receive information about you from: advertising partners (e.g., campaign performance data), social media platforms (if you interact with our ads), data analytics providers, and publicly available sources, in accordance with their policies and applicable law.
3. How We Use Your Information
We use your Personal Information for the following business and commercial purposes:
| Purpose of Processing | Types of Information Used | Legal Basis (EEA/UK) |
|---|---|---|
| To provide and maintain our services, including account creation, order processing, and customer support | Account info, order details, communication records | Performance of a contract |
| To process payments and prevent fraud | Payment info, device info, order history | Legitimate interests, legal obligation |
| To personalize your experience and improve our products | Usage data, preferences, feedback | Legitimate interests, consent |
| To communicate with you about updates, offers, and promotions | Contact info, marketing preferences | Consent, legitimate interests |
| To ensure safety, security, and compliance with laws | Device info, usage logs, IP address | Legal obligation, legitimate interests |
| To conduct research and analytics | Aggregated usage data, survey responses | Legitimate interests |
If you are in the EEA or UK, we process your data based on legal grounds such as: fulfilling our contract with you, your consent, our legitimate interests (like improving our services), or legal obligations.
5. International Data Transfers
To provide fast and reliable service worldwide, your Personal Information is processed and stored in secure data centers located in Silicon Valley (USA), Frankfurt (Germany), and Tokyo (Japan). The primary location used depends on your region to optimize performance and comply with regional data guidance.
However, as a global company, we also engage service providers (as described in Section 4) that operate in other countries. When we transfer your data from your home region to a country with different data protection laws (for example, when using a U.S.-based analytics provider), we implement robust legal safeguards to protect it.
For transfers of personal data originating from the European Economic Area (EEA), United Kingdom (UK), or Switzerland to countries not deemed to provide an adequate level of data protection (such as the United States or Japan), we rely on legally recognized transfer mechanisms, primarily the European Commission's Standard Contractual Clauses (SCCs).
6. Your Rights and Choices
Depending on your region of residence, you may have certain legal rights regarding your Personal Information, such as:
- Access and Portability: Request access to or a copy of your Personal Information.
- Correction: Request correction of inaccurate or incomplete information.
- Deletion: Request deletion of your Personal Information, subject to certain legal exceptions (e.g., where we need to retain data to comply with a legal obligation or complete a transaction).
- Restriction and Objection: Object to or restrict certain types of processing.
- Opt-Out of Marketing: Unsubscribe from our promotional emails by following the link in any email. You may still receive transactional emails.
- Cookies: Manage your cookie preferences through your browser settings or our cookie banner. See our Cookie Policy for details.
Identity Verification
For your security and to prevent unauthorized access to your data, we are required to verify your identity before processing certain rights requests. The verification method may vary depending on the nature of the request and the sensitivity of the information involved. We may require you to provide information matching what we have on file (e.g., email associated with your account) or, for more sensitive requests, additional proof of identity. We will only use the information you provide for verification purposes.
Consequences of Choice
Please note that if you choose to exercise certain rights (such as deletion of account information or objection to processing that is necessary for service delivery), it may impact our ability to provide you with the full functionality of Qinglai Products and Services. For example, deleting your account will result in the loss of access to your historical data and personalized features.
To exercise your rights, please contact us at privacy@memo-mind.com. We will respond in accordance with applicable law and verify your identity before processing your request.
7. Data Retention
We retain your Personal Information only as long as necessary for the purposes outlined in this Policy, unless a longer period is required or permitted by law (e.g., for tax, accounting, product safety, or prescription records). Retention periods vary based on data type, purpose, and legal requirements. We periodically review and securely delete or anonymize data that is no longer needed.
8. Data Security
We implement reasonable administrative, technical, and physical safeguards designed to protect your Personal Information. However, no method of electronic transmission or storage is 100% secure.
9. Children's Privacy
Our Services are not directed to children under 16. We do not knowingly collect Personal Information from children under 16. If you believe we have, please contact us so we can delete it.
10. Region-Specific Addenda
The following addenda apply only to users residing in the specified jurisdictions and supplement the information provided in the main body of this Policy. In the event of any conflict between the provisions of the main Policy and the relevant addendum, the addendum shall prevail for users in that jurisdiction.
A. For Users in the European Economic Area (EEA), United Kingdom (UK), and Switzerland
- Legal Basis: The legal bases for our processing are detailed in the table in Section 3.
- Data Subject Rights: In addition to the rights in Section 6, you have the right to withdraw consent and to lodge a complaint with your local data protection authority.
- International Transfers: As explained in Section 5, personal data of EEA/UK users is primarily stored in our Frankfurt, Germany data center. When data is accessed from or transferred to other locations (e.g., for support or analytics), we ensure compliance with GDPR transfer rules by implementing safeguards such as Standard Contractual Clauses. You can request more information about these safeguards by contacting us.
B. For California Residents
Please see our separate California Privacy Notice below, which details our compliance with the California Consumer Privacy Act (CCPA) as amended by the CPRA, including the categories of Personal Information collected and disclosed, and your rights to know, delete, correct, and opt-out of "sharing" for cross-context behavioral advertising.
C. For Users in Australia
Under the Australian Privacy Act, you have the right to access and correct your personal information. We will handle complaints in accordance with Australian law.
12. Health Information (U.S. Specific)
Qinglai is not a "covered entity" under the U.S. Health Insurance Portability and Accountability Act (HIPAA). Prescription information you provide is used solely to fulfill your eyewear order and is protected by our general security and privacy measures, not HIPAA-specific rules.
13. Changes to This Policy
We may update this Policy. The "Last Updated" date will reflect changes. For material changes, we will notify you via the Site or email.
14. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
Shenzhen Qinglai Innovative Intelligent Technology Co., Ltd.
[Your Company's Registered Address]
Email: privacy@memo-mind.com
For users in the EEA/UK, you may also contact our designated representative:
[If applicable, insert the name and contact details of your EU/UK representative]
California Privacy Notice
This Notice supplements the information above for California residents.
Categories of Personal Information
We have collected the categories listed below in the past 12 months:
| Category | Examples | Collected |
|---|---|---|
| Identifiers | Name, email, phone number, device identifiers, IP address | Yes |
| Personal information categories (Cal. Civ. Code §1798.80) | Address, payment status, order details | Yes |
| Commercial information | Purchase history, products viewed | Yes |
| Internet or network activity | Browsing history, clickstream, time on page | Yes |
| Geolocation data | Approximate or precise location (with consent) | Yes |
| Audio/visual/electronic information | Photos/videos you choose to upload to cloud services | Yes |
| Sensitive personal information | Account login credentials, precise geolocation, prescription information | Yes |
Sale or Sharing
We do not "sell" personal information for money. Our use of analytics or advertising partners may constitute "sharing" for cross-context behavioral advertising under the CPRA.
You can opt-out of "sharing" by adjusting your preferences in our cookie banner or by emailing privacy@memo-mind.com.
Your CPRA Rights
- Right to know, access, and portability
- Right to delete
- Right to correct
- Right to opt-out of "sharing"
- Right to limit use of sensitive personal information
- Right to non-discrimination
To exercise these rights, contact us at privacy@memo-mind.com. We will verify your identity and respond within the time period required by law.