Privacy policy
GEBC Privacy Statemen
Effective: March 7, 2023
This Privacy Statement explains how GEBC, Inc. (“GEBC”, “we” or “us”) processes information about you, including relating to information we collect when you use our products and services, when you contact our customer service team, engage with us on social media, and when you otherwise interact with us.

When we refer to our “Services” in this statement, we mean our websites https://www.homewellinc.net, apps and other online services, including the online services we provide for our Devices. When we mention “Devices,” we mean GEBC-branded hardware products.

We may change this Privacy Statement from time to time. If we make changes, we will notify you by revising the date at the top of the statement and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Privacy Statement whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
1.COLLECTION OF INFORMATION
The information we collect about you depends on how you interact with us or use our Services. In this section, we describe the categories of information we collect and the sources of this information.
Information You Provide to Us
We collect information you provide directly to us. For example, we collect information directly from you when you create an account, fill out a form, submit or post content through any interactive features of our Services, make a purchase, communicate with us via third-party platforms, participate in a contest or promotion, volunteer as a product tester, request customer support, or otherwise communicate with us. The types of information that we collect include your:

    • name
    • email address
    • postal address
    • phone number
    • username
    • photographs (such as for your profile picture)
    • social media profile information
    • demographic information
    • payment information
    • any other information you choose to provide

Some of this information is considered “sensitive” under some laws. For more information and to exercise your related choices, see the Your Privacy Rights and Choices section below. In connection with specific Devices, you may provide us with additional information, such as the name you choose for your Device, or, when setting up or using the GEBC Watch, GEBC Band or GEBC Scale, your birth year, height, weight, gender, and personal fitness goals. This information may be used, for example, to estimate various weight and other physical body metrics for you to view through our Services. You may also provide still images in connection with creating a Smart Vision Skill in conjunction with your use of certain GEBC cameras. We use the content contained in such images to generate the Smart Vision Skill that you direct us to create.

Automatically Collected Information and Information We Generate

When you use our Services, we automatically collect or generate certain information about you as follows:

    • Device Log and Sensor Information:When your Device is connected to our Services, our Services will collect various Device event data, such as when the Device is used, whether it is turned on or off, and when it is capturing video, motion or other sensor data. We provide additional details below regarding information collected by some of our Devices, which we collect in accordance with your Device settings:
    • Cameras:Our Services will collect video and images from your cameras in accordance with your camera storage settings, which may include images or videos of individuals.
    • Watch,Band and Scale:The GEBC Watch and GEBC Band have sensors that collect heart rate,speed and other distance and movement data, and the GEBC Scale sensors collect heart rate and weight measurements.
• Person Detection Information:If you have enabled the person detection feature for your camera, then the Services analyze the video to help detect the presence of a person in that video (without trying to identify that person). We use this person detection information solely to provide and improve this feature. For most users, this person detection information is stored for a limited period of time in accordance with your video storage settings. However, if you choose to voluntarily submit a video to help improve our Services, we store this person detection information for as long as needed to provide and improve the Services but in no event longer than 3 years after the date you submitted the video.

• Activity and Usage Information:When you use our websites and mobile apps, we collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our websites.

• Transactional Information:When you make a purchase, return or warranty claim, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.

• Your Content:With your permission, we collect information and content stored on your device, such as the photograph you choose to upload as your profile picture.

• Location Information:We derive the approximate location of your computer or mobile device from your IP address. With your consent, we may also collect information about the precise location of your mobile device in connection with your use of our mobile apps. You may stop the collection of precise location information at any time (see the Your Privacy Rights and Choices section below for details).

• Information Collected by Cookies and Similar Tracking Technologies:We use tracking technologies, such as cookies, pixels, and SDKs to collect information about your interactions with the Services. These technologies help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. For more information about the cookies and other tracking technologies we use, and the choices available to you,see the Your Privacy Rights and Choices section below.

Information We Collect from Other Sources

We obtain information about you from other sources. For example, we may collect information from publicly available sources, from third-party platforms through which you interact with us, and other third parties in connection with your purchase of or feedback regarding any of our products or services via those third parties. This information includes information about your purchase of a Device, information from reviews you post, your username and profile picture for those third-party services, and demographic information.

Information We Derive
We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

2.USE OF INFORMATION
We use the information we collect to provide, maintain, and improve our Devices and Services. We may also use the information we collect to:

    • name
    • email address
    • postal address
    • phone number
    • username
    • photographs (such as for your profile picture)
    • social media profile information
    • demographic information
    • payment information
    • any other information you choose to provide

    • Process and fulfill your purchases;
    • Personalize your experience with us;
    • Develop new Devices and Services;
    • Send you technical notices, updates, security alerts, and support and other transactional or relationship messages;
    • Communicate with you about products, services, and events offered by GEBC and others, and provide news and information    • we think will be of interest to you (see the Your Privacy Rights and Choices section below for information about how to opt out of these communications at any time);
    • Monitor and analyze trends,usage,and activities in connection with our Devices and Services;
    • Target advertisements to you on third-party platforms and websites (for more information and to opt out,see the Your Privacy Rights and Choices section below);
    • Target advertising to you when you use our Services based on information provided by our advertising partners(for more information and to opt out,see the Your Privacy Rights and Choices section below);
    • Comply with our legal and financial obligations;
    • Detect, investigate and help prevent security incidents and other malicious,deceptive,fraudulent,or illegal activity and help protect the rights and property of GEBC and others;
    • Facilitate contests,sweepstakes,and promotions and process and deliver entries and rewards;
    • Create de-identified,anonymized,or aggregated information;and
    • Carry out any other purpose described to you at the time the information was collected.

3.TARGETED ADVERTISING AND ANALYTICS

We engage others to provide analytics, serve advertisements, and perform related services across the web and in mobile apps. These entities may use cookies, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to deliver advertising targeted to your interests on our Services and other companies’ sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better understand your activity. Some of our advertising partners enable us to translate your email address or phone number into an identifier that can’t be used to identify you personally. Our advertising partners then use that unique identifier to show ads that are more relevant to you across the web and in mobile apps. Some of the activities described in this section may constitute “targeted advertising,” “sharing,”or “selling” under certain laws. To learn more about the choices available to you with respect to these practices, see the Your Privacy Rights and Choices section below).

You can also learn more about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices or,in Canada,www.youradchoices.ca.

4.DISCLOSURE OF INFORMATION
In certain circumstances, we disclose (or permit others to directly collect) information about you. We disclose the information about you described above in the following ways:
    • With vendors, service providers, and contractors that need this information to provide services to us, such as companies that assist us with web hosting, shipping and delivery, payment processing, fraud prevention, customer service, and marketing and advertising;
    • If you provide a product review or otherwise post content on our Services, the public/other users of our Services will be able to see this information.
    • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
    • If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of GEBC or others;
    • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
    • Between and among GEBC and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
    • With your consent or at your direction. For example, if you choose to integrate our Devices or Services with third-party services (such as voice assistants), then those services will collect certain types of data depending on the nature of the service. Please review their privacy policies for details on the information they will receive and how they process this information.

We may disclose aggregated or de-identified information that cannot reasonably be used to identify you. GEBC processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information, except as permitted by law.

5.YOUR PRIVACY RIGHTS AND CHOICES
Account Information

You may update and correct certain account information at any time by logging into your account on the Services. If you wish to deactivate your account, please email info@homewellinc.net, but note that we may retain certain information as required by law or for our legitimate business purposes.
Opting Out of Targeted Advertising, Sharing, and Sales

As described in the Targeted Advertising and Analytics section above, we process personal information to understand and improve your experience with our Services and to serve you advertisements on non-GEBC properties. Some of these activities may be considered “sales” or “sharing” of your personal information or “targeted advertising” under the law that applies to you.
Depending on where you reside, you may have the right to opt out of targeted advertising, sharing, and sales of your personal information. You can do so by following the prompts on our website.
Consent, Objection, and Related Rights

Depending on where you reside, you may have the right to object to certain processing, withdraw your consent where we process your information on that basis, and the right to request we restrict certain processing. For example, if you provided information to us such as your race/ethnicity or sexual orientation as part of our DEI efforts, in addition to requesting deletion of this information, you can request that we stop processing this data. To exercise any of these rights, please email us at info@homewellinc.net.

Nondiscrimination

We will not discriminate against you for exercising your privacy rights.

Location Information

When you first launch our mobile app, you will be asked to consent to the app’s collection of precise location information. If you initially consent to our collection of such location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.If you do so, our mobile apps,or certain features, may no longer function properly. You may also stop our collection of this information by deleting our app from your mobile device.

Cookies

GEBC uses cookies and similar tracking technologies to analyze visits to our websites and interactions with our communications to help us improve our website, Services, and marketing campaigns. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Promotional Emails

You may opt out of receiving promotional emails from GEBC by following the instructions in those emails or by contacting us at info@homewellinc.net. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Text Messages

If you want to opt out of text messages sent to your mobile device, including promotional or non-promotional text messages, you can reply “STOP” or “UNSUBSCRIBE” to any message you receive.

Mobile Push Notifications/Alerts

With your permission,we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

6.DATA RETENTION

Account Information

We store personal data associated with your account for as long as your account remains active. If you close your account, we will delete your account data within 30 days; otherwise, we will delete your account data after three years of inactivity. We store other personal data for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Privacy Policy.

7.TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

GEBC is based in the United States and we process and store information in the U.S. and other countries. Therefore, we and those that perform work for us may transfer your information to, or store or access it in, jurisdictions that may not provide levels of data protection as that are equivalent to those of your home jurisdiction.

8.CALIFORNIA AND OTHER STATES NOTICE OF COLLECTION AND PRIVACY RIGHTS

California law, as well as privacy laws in Colorado, Connecticut, Utah and Virginia afford consumers residing in those states certain rights with respect to their Personal Information. If you are a resident of those states, this section applies to you as indicated and supplements the information provided to you in our Privacy Policy.

Categories of Information Collected

We collect, and have collected, in the preceding 12 months, the following categories of personal information:

    • Identifiers
    • Customer Records Information
    • Commercial information
    • Internet or other electronic network activity information
    • Precise geolocation data
    • Audio,electronic, visual, or similar information
    • Inferences
    • Sensitive personal information (see below)
    • For more information about the data points we collect and the categories of sources of such collection,please see the Collection of Information section above.

Retention of Personal Information

For information about how long we retain personal information,see the Data Retention section above.

Business Purposes for Collection,Use,and Disclosure of Personal Information

We collect,use,and disclose personal information for the business and commercial purposes described in the Use of Information section above.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, we have made disclosures for business purposes to the following categories of recipients:

Category of Personal Information Categories of Recipients
Identifiers Web hosting and cloud storage providers
Customer support services providers
Customer feedback services providers
Data analytics providers
Fraud prevention services providers
Advertising partners
Demographic information Customer feedback services providers
Commercial information Customer support services providers
Customer feedback services providers
Data analytics providers
Fraud prevention services providers
Advertising partners
Internet or other electronic network activity information Web hosting and cloud storage providers
Data analytics providers
Fraud prevention services providers
Advertising partners
Geolocation data Web hosting and cloud storage providers
Customer support services providers
Customer feedback services providers
Data analytics providers
Fraud prevention services providers
Advertising partners
Audio and visual data Web hosting and cloud storage providers
Customer support services providers
Customer feedback services providers
Data analytics providers
Fraud prevention services providers
Inferences Advertising partners


Sale of Personal Information

California requires certain disclosures about Personal Information we “sell.” Under California law “sale” means certain scenarios in which GEBC has disclosed Personal Information with third parties in exchange for valuable consideration. In addition, California and other state privacy laws define “sale” to include disclosure of Personal Information with third parties for monetary consideration. Under California law, the “sharing” described below constitutes a “sale.” Accordingly, GEBC“sells” Personal Information as described in the Sharing section below.

California Sharing of Personal Information

California law also requires that we notify you if we “Share” your Personal Information with third parties. “Sharing” in this context means that we make available or otherwise disclose your information to third parties for cross-context behavioral advertising, such as targeting of advertising to you based on your Personal Information obtained from your activity across businesses, websites, apps, and services other than our Services.

We “share” personal information for the following commercial purposes: to advertise our products to you. We share the following categories of personal information to the following categories of third parties:

Category of Personal Information Category of Third Parties
Identifiers Advertising networks, internet service providers, data analytics providers, operating systems and platforms, and social networks.Advertising networks, internet service providers, data analytics providers, operating systems and platforms, and social networks.
Internet or other electronic network activity information Advertising networks, internet service providers, data analytics providers, operating systems and platforms, and social networks.


We do not knowingly sell or share personal information about consumers under the age of 16.

Sensitive Personal Information

Privacy laws in California, Colorado, Connecticut, Utah and Virginia specify certain rights with respect to our collection of certain information those laws designate as “sensitive” personal information (“Sensitive Personal Information”). We obtain consent to collect that information in those states where consent is required. Moreover, each state’s privacy law may consider different pieces of information to be Sensitive Personal Information. When we notify residents of certain states that we collect Sensitive Personal Information, that means that we collect Sensitive Personal Information within the meaning of the law of that particular state. We collect Sensitive Personal Information in California, Colorado, Connecticut, Utah and Virginia. We collect the following types of Sensitive Personal Information, to the extent included in your state’s definition: precise geolocation information. We only use Sensitive Personal Information to the extent necessary to provide you the products or services in connection with which we collected that information or as permitted by applicable law. We do not use Sensitive Personal Information to infer characteristics about you.

Your Consumer Privacy Rights

Depending on where you reside, you may have the right to (1) request to know more about and access your personal information, (2) request deletion of your personal information, and (3) request correction of inaccurate personal information.

To request access, correction, or deletion of your personal information, please email us at info@homewellinc.net or call our toll-free number at 626 759 1699. You can also access, correct, or delete certain information stored within your GEBC online account by logging into your account and visiting the “My account” page on our website, or visiting the “Account” page in the mobile app.

We may verify your request by asking you to provide information related to your recent interactions with us, such as by asking you to provide information that matches what we have on file about you or by having you log into your account to submit or confirm the request. If we deny your request, you may appeal our decision by contacting us at info@homewellinc.net. If you have concerns about the results of an appeal, you may contact the attorney general in the state where you reside.

You have the right to opt out of sharing and sales at any time by clicking the “Do Not Sell or Share My Personal Information” link on our webpage and/or by toggling the slider of the “Opt Out of Data Sharing” setting in Account settings of our mobile app (under the “About” menu). You can also opt out of certain targeted advertising, sharing and sales by visiting our Services with a legally-recognized universal choice signal enabled (such as the Global Privacy Control). Please note that, depending on which legally-recognized opt-out preference signal you use and whether you are logged into your account with us, our processing of the signal may be limited to the specific browser or device that you are using. You may need to renew your opt-out choice if you use a different browser or device to access our Services.Please see the Your Privacy Rights and Choices section above for more information about the privacy rights you have as a California resident,how to exercise your rights,and how we will verify your requests.

If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with this request, such as a driver's license or other government-issued ID. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please email us at info@homewellinc.net.

California Notice of Financial Incentive

We offer various financial incentives. For example, we may provide discounts, coupons, or other benefits to customers who join membership programs or sign up to receive our marketing emails or text messages. When you participate in a financial incentive, we may collect personal information from you, such as identifiers (like your email address or phone number), commercial information (like your purchase preferences and interests or purchase history), inferences drawn about your preferences, and other categories of personal data that relate to or are reasonably capable of being associated with you. You can opt into a financial incentive by following the sign-up or participation instructions provided,and, for any ongoing benefits, you can opt-out at any time, such as by following the unsubscribe instructions in the applicable program’s terms and conditions,promotional emails, or text messages, or contacting us at info@homewellinc.net. In some cases, we may provide additional terms and conditions for a financial incentive, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.

9.NOTICE TO USERS IN CANADA

If you are located in Canada and would like to request access or changes to the personal information that we process about you, please contact us at info@homewellinc.net, or at the address provided in the contact us section below. We will consider your request in accordance with applicable laws. Note that before we can process any request regarding your personal information, we may require additional information from you in order to verify your identity.

10.CONTACT US

HOMEWELL, Inc.
4714 VINETA AVE LA CANADA FLINTRIDGE
CA 91011
info@homewellinc.net
(626)759-1699

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