Welcome to E-WAY Hands Free! We understand the importance of personal information to you and are committed to protecting your personal information and privacy in accordance with laws and regulations such as the "Information Security Technology - Personal Information Security Specification" (GB/T 35273-2020) and the "Information Security Technology - Security Specification for Personal Information Processing" (GB/T 41852-2022). Please read this policy (hereinafter referred to as "this Policy") carefully before using our products or services. This Policy applies to all services provided by E-WAY Hands Free (including but not limited to websites, applications, mini-programs, etc., collectively referred to as "our Platform"). By using the services on our Platform, you agree to the contents of this Policy.

• Personal Information: As defined in GB/T 35273-2020 "Information Security Technology - Personal Information Security Specification," refers to various kinds of information recorded electronically or by other means related to identified or identifiable natural persons, excluding information that has been anonymized.

Sensitive Personal Information: As defined in GB/T 35273-2020 "Information Security Technology - Personal Information Security Specification," refers to personal information that, once leaked or illegally used, may easily lead to the infringement of personal dignity or harm to personal or property safety, including biometrics, religious beliefs, specific identity, medical health, financial accounts, location tracking, and other information, as well as personal information of minors under the age of fourteen.

• Anonymization: Refers to the process by which personal information is processed so that it cannot identify a specific natural person and cannot be restored.

• De-identification: Refers to the process by which personal information is processed so that it cannot identify a specific natural person without the use of additional information.

• Minor: Refers to a natural person under the age of eighteen.

• Authorization: Refers to your consent or separate consent (if applicable) for us to collect, use, share, transfer, or publicly disclose your personal information.

• Separate Consent: Refers to separately informing you and obtaining your consent for specific personal information processing purposes, methods, scope, etc., when seeking your consent.

• Automated Decision-Making: Refers to activities that make decisions through automatic analysis and evaluation of personal information by computer programs.

We adhere to the following basic principles to protect your personal information: Lawfulness and Legitimacy, Minimum Necessity, Transparency, Security Assurance, Subject Participation, and Accountability.

We will collect and use your personal information based on the principles of lawfulness, legitimacy, and necessity when you use our products or services. The following are the types and scenarios of personal information we collect and use:

When you use E-WAY Hands Free products (such as breast pumps and other smart devices) and related services, to enable you to normally use core functions such as device connection, function control, data recording, and viewing, we will collect the following personal information:

• Device Information: Includes your breast pump device model, device unique identifier (such as Bluetooth MAC address, IMEI code, etc.), device connection status, firmware version, and other information. Used for device pairing and connection with the mobile app, function control command transmission, and device status identification.

• Operation Information: Information such as the mode you set during the use of the breast pump (e.g., pumping mode, suction strength, duration, etc.) and operation records. Used to record your usage habits, enable function control and data statistical analysis, and provide you with personalized services and basis for product optimization.

• Health Data (if applicable and authorized by you): If you use the health data recording function of the breast pump (e.g., pumping volume, pumping frequency, milk composition analysis data, etc., if such functions exist), we will collect health data that you actively enter or that is automatically recorded by the device. Used to provide you with breastfeeding health management suggestions, data statistical analysis, and other services.

The above information is necessary to achieve the core functions of the E-WAY Hands Free product. If you do not provide relevant information, you may not be able to use device connection, control, and core functions normally, but this will not affect your use of other non-core functions (if any).

We may collect information such as your frequency of use, preference settings, and historical operation records. By analyzing this information, we provide you with the following services:

• Product Optimization: Understand your usage habits and needs to optimize product functions, operation interface, etc., and enhance your user experience.

• Personalized Recommendations: Based on your usage behavior and preferences, recommend functions, services, or content that better meet your needs (e.g., breastfeeding knowledge, related product recommendations, etc., if any). If you do not wish to receive personalized recommendations, you can turn off this function in the relevant settings (if available).

To ensure the security of your use of our products and services, and to investigate and resolve system failures, we will collect the following information:

• Log Information: Includes device operation logs, application logs, network logs, etc., recording your operation behavior, error information, network connection status, etc., during your use of the product or service. Used to analyze system operation status, investigate the cause of failures, and ensure stable service operation.

• Location Information (with your authorization and only when necessary): In scenarios where you authorize and network positioning or device location-related troubleshooting is required (e.g., when abnormal device connection requires judging network environment location factors), we may collect the approximate location information of your device (such as location information based on network IP). This information is only used for troubleshooting and security purposes. We will promptly delete or anonymize it after completing the relevant purposes.

If you choose to use certain additional functions or services we provide (such as participating in user research, community interaction, online customer service consultation, etc.), we may collect the following corresponding information:

• User Research: If you participate in our user research activities, we will collect the questionnaire information you actively fill out (such as your breastfeeding experience, product evaluation and suggestions, basic personal information (e.g., age, occupation, etc., if the questionnaire involves)). Used to understand user needs and improve products and services.

• Community Interaction (if any): If you participate in our community functions (such as posting experience sharing, asking questions, commenting, liking, etc.), we will collect the content information you publish, interaction behavior information (such as comment content, like records, etc.), and personal information you actively fill in or display in the community (such as nickname, avatar, etc., if you set them). Used to provide you with community communication services. You can choose whether to make it public and the scope of publicity.

• Online Customer Service Consultation: When you communicate with our online customer service, we will collect your question description, chat history with customer service, and relevant information you provide (such as operation records related to device issues, screenshots of faults, etc., if you actively provide them). Used to solve your problems and provide customer support. Chat records will be deleted or anonymized within a reasonable period after the service is completed and there are no disputes.

In certain scenarios required by law, contractual agreements, or to fulfill our legal obligations (such as cooperating with regulatory investigations, responding to litigation, etc.), we may need to collect and use your relevant personal information. This will be done within the scope permitted by law, and we will inform you of the relevant situation as much as possible (unless prohibited by law or required to be kept confidential).

We will not share your personal information with any third-party organizations or individuals outside of E-WAY Hands Free, except in the following circumstances:

• With your explicit authorization or consent: With your explicit authorization or consent, we will share your personal information with relevant third parties according to the scope and purpose of the authorization/consent. For example, you authorize us to share your breastfeeding health data with specific health management institutions (if there is cooperation and scenarios agreed by you) to provide you with more professional health advice.

• To achieve product functions or services: Share with necessary partners who provide us with technical support, service support, etc., and only process your personal information for the purposes stated in this Policy. For example, we may share your device log information with cloud service providers for server hosting, data storage, and analysis. These providers must process your information according to our requirements, relevant laws and regulations, and confidentiality agreements.

• To comply with laws, regulations, administrative orders, etc.: Under mandatory circumstances required by law, administrative orders, etc., we may need to share your necessary personal information with relevant regulatory authorities, judicial institutions, etc., to cooperate with investigations, law enforcement, and other work.

We will not transfer your personal information to other third parties, except in the following circumstances:

• Merger, division, bankruptcy, liquidation, or business transfer: If a merger, division, bankruptcy, liquidation, or business transfer of the company owning E-WAY Hands Free occurs, we will require the recipient to continue to abide by this Policy to protect your personal information. If the recipient cannot comply, we will require them to re-obtain your authorization and consent, or inform you before the transfer and delete the relevant information (unless required by law to retain it). ）。

• With your explicit authorization: With your explicit authorization, we will transfer your personal information according to the scope and purpose of the authorization, ensuring that the recipient has corresponding data protection capabilities and compliance.

We will not publicly disclose your personal information, except in the following circumstances:

• With your explicit authorization or consent: With your explicit authorization or consent, we will publicly disclose your personal information according to the scope and purpose of the authorization/consent. For example, you agree to publicly disclose your breastfeeding experience sharing content (including related operation information, insights, etc.) in the community for community exchange.

• To fulfill legal obligations: Under mandatory circumstances required by law, administrative orders, etc., we may need to publicly disclose your necessary personal information to cooperate with investigations, law enforcement, and other work. This will be done within the scope permitted by law, and we will inform you as much as possible (unless prohibited by law or required to be kept confidential).

We adopt technical and management measures that comply with industry standards to protect the security of your personal information, including but not limited to:

• Data Encryption: Encrypt your personal information (such as device information, health data, and other sensitive information) during transmission and storage (e.g., using SSL/TLS encryption protocols) to prevent information from being stolen or tampered with.

• Access Control: Implement strict permission management for employees and partners who can access your personal information, only authorizing necessary personnel to access necessary information, and record and audit access behaviors.

• Security Audits: Regularly conduct security audits of personal information processing activities to identify security risks and promptly improve security measures.

• Security Training: Provide employees with data security, privacy protection, and other relevant training to enhance their data protection awareness and operational standards.

If a security incident such as personal information leakage, tampering, or loss occurs, we will immediately initiate an emergency plan and take the following measures:

• Loss Mitigation: Take technical means and management measures to prevent the security incident from expanding and prevent more personal information from being leaked, tampered with, or lost.

• Investigation: Conduct a comprehensive investigation of the security incident to determine the cause, scope of information involved, degree of impact, etc.

• Notification and Remediation: If the security incident is likely to affect you, we will promptly inform you of the incident situation (including the nature of the incident, possible impacts, measures taken, etc.) as required by laws and regulations, and provide you with necessary remedial measures (such as assisting you in changing passwords, re-authorizing, etc., if applicable). At the same time, we will report to the relevant regulatory authorities (if required by law).

Subject to relevant laws and regulations, you have the following rights regarding your personal information:

You have the right to access your personal information on our Platform, including device information, operation records, health data (if applicable), account information (if any), etc. You can view this information through relevant function modules on our Platform (such as the "Me" page, settings page, etc.).

If you find that your personal information is incorrect or incomplete, you have the right to request us to correct or supplement it. You can submit a correction request through feedback channels within the Platform (such as online customer service, feedback forms, etc.). We will process it promptly after verification and inform you of the result.

You have the right to copy your personal information (where technically feasible and in compliance with legal provisions). You can obtain a copy of your personal information through the download function provided by the Platform (if any) or other reasonable means.

You have the right to request us to delete your personal information under the following circumstances:

• The purpose for which we processed your personal information has been achieved, cannot be achieved, or the period for achieving the purpose has expired;

• You have withdrawn your authorization for our processing of personal information (and we have no other legal basis to continue processing);

• Our processing of your personal information violates laws or administrative regulations;

• Other circumstances stipulated by laws and administrative regulations.

After verifying your deletion request and the relevant circumstances, we will promptly delete the relevant personal information. If immediate deletion is impossible due to technical reasons, we will stop processing the information (except for storage and taking necessary security technical measures) and complete the deletion within a reasonable period.

You have the right to withdraw your authorization and consent for us to collect, use, share, transfer, or publicly disclose your personal information (unless otherwise stipulated by law). You can withdraw authorization and consent through relevant settings within the Platform (such as the permission management page) or feedback channels. However, please note that withdrawing authorization and consent may result in your inability to use some product or service functions that rely on that authorization, and you shall bear the corresponding consequences.

If you believe that our personal information processing activities have infringed upon your legitimate rights and interests, or you discover personal information security issues, you have the right to complain and report to us. You can provide feedback through the complaint and reporting channels on our Platform (such as online customer service, complaint email, etc.). We will promptly investigate and handle the matter after receiving the complaint or report and inform you of the result.

We attach great importance to the protection of minors' personal information. If you are a minor (under the age of eighteen), please read this Policy accompanied by your guardian, and use our products or services only after obtaining your guardian's explicit consent.

If we discover that we have collected the personal information of a minor without the guardian's consent, we will immediately delete the relevant information and stop related processing activities. At the same time, we will take measures to contact the guardian, inform them of the situation, and seek legal authorization or processing methods.

We may update this Privacy Policy based on changes in laws and regulations, product function adjustments, and other factors. When this Policy changes, we will notify you through the following methods:

• Platform Announcement: Publish a prominent policy change announcement on our product or service platform (such as the APP, mini-program, website, etc.) to prompt you to review the changes.

• Push Notification (if applicable): If you have authorized us to send you notifications, we will send policy change notices to you via push messages or other methods.

The changed Privacy Policy will take effect from the effective date specified in the announcement or notice. If you continue to use our products or services, it means that you accept the changed Privacy Policy. If you do not accept it, you should stop using our products or services.

If you have any questions, comments, or suggestions regarding this Privacy Policy or personal information protection, you can contact us through the following methods:

• Customer Service Email: 

263745807@qq.com

We will respond to your questions or process your requests within a reasonable period (generally within 15 working days, unless otherwise stipulated by laws and regulations) after receiving your feedback.

Thank you again for your trust and support of E-WAY Hands Free! We will continue to be committed to protecting your personal information security and privacy rights, providing you with better products and services.