UREVO PRIVACY POLICY

Last updated and effective date: April 10, 2025.

Welcome to the UREVO Privacy Policy!

This Privacy Policy specifies how Shenzhen Yiledong Technology Co., Ltd. and its affiliates ("Yiledong Technology" or "us") collect, use, disclose, process and protect the information you provide to us when using the products and services provided by UREVO App.

Please read the Privacy Agreement in its entirety. If you have any questions about the Privacy Agreement, you can contact us via the email address provided herein.

By using or continuing to use our products and services, you agree to the content of the Privacy Agreement. If you do not agree to any of the Privacy Agreement, please stop using our services immediately.

1. WHAT PERSONAL INFORMATION WE COLLECT

Depending on how you interact with UREVO and our Services, we may collect your personal information. The sources from which we collect this personal information fall into three categories: Information you provide, Information we collect automatically, Information we collect from other sources. See below for more information on the types of personal information in each category.

1.1 Information you provide

When you interact with UREVO you may volunteer personal information, or you may be asked to provide personal information in order for us to provide the Services as described.

Personal profile information. The information you provide related to your UREVO personal profile, such as your nickname, avatar (which can be an uploaded image), age, gender, height, and weight. This information is part of your account information and helps us provide you with more accurate services. Height information is used to calculate calorie consumption data for the treadmill/walking machine; if not provided, the calculation results may be inaccurate. Weight information is used for the BMI calculation function on the scale; if not provided, BMI data cannot be generated. Not providing other additional information will not affect the use of basic features.

Geolocation data. Depending on how you use the services and your device settings, type, and connection status, we may collect location-based information, including your IP address, GPS location, and the connection between your smart device and "beacons" or Bluetooth networks.

Exercise characteristics. The information you provide when using our services to track your performance, such as height, weight, number of workouts, and the equipment used.

Other information. Any additional information you may provide to us while using our services and/or interacting with UREVO.

1.2 Information that we collect automatically

Information generated through the use of the services. This includes exercise and massage records to optimize your experience. For example, workout data from the treadmill or walking machine (speed, distance, time, calories burned, step count, and leaderboard rankings, which you can choose to disable in the settings page), as well as usage data from the leg massager (frequency, duration, intensity levels, and temperature adjustments).

Device data. This includes information from the devices you use while accessing our services, such as IP address, unique digital identifiers (e.g., browser/mobile device type), mobile carrier, time zone, state/province, language, and operating system.

Location information. We may collect location-based information, including your IP address, GPS location, city, region, and the proximity of your smart device to "beacons," Bluetooth networks, and/or other proximity systems. You can choose to allow or deny us access to your location information by adjusting the location and Bluetooth settings on your device, but this may affect your ability to use certain location-based services.

1.3 Information We Collect from Other Sources

In order to provide our services, we collect information from various sources. We may collect your personal information from other individuals, enterprises, or third parties acting on your instructions, as well as from partners who support us in delivering products and services and provide assistance with security and fraud prevention measures. Additionally, we may obtain such data from other legitimate sources.

Other Applications. If you access our services through third-party applications (such as the Apple App Store or Google Play Store, collectively referred to as "App Stores") or connect to social networking sites (SNS) such as Instagram, Twitter, or Facebook through our services, we may collect information that you have made publicly available through the privacy settings of the third-party application. This information may include your name, email address.

Third-Party Applications and Accounts Linked to Your UREVO Account. As part of our service features, we allow you to link your UREVO account with third-party applications (such as Health Connect®, Google®, Apple®, Apple Health®, and similar applications). If you choose to link your UREVO account, we may collect certain personal information from the linked application based on your sharing settings and the configuration of the device and application.

To support functionalities such as search and to serve as the data source for our foundational AI model, we may utilize web crawlers to collect publicly accessible information from the Internet. We have implemented measures to minimize the collection of personal data and will not associate the collected data with any identifiable individuals or create individual profiles based on it. Furthermore, your personal data will not be utilized in the training of our foundational AI model.

2. Why We Use Personal Information

This list outlines the reasons we use your personal information and the legal grounds for processing this data, we will only use your personal information when it is supported by legitimate legal basis. More information on each point is provided below the list.

To provide you with services. UREVO uses information to operate, improve, and maintain our services. We use data to:

Legal basis: To fulfill our contract with you.

Communicate with you.

Legal basis: Legitimate business interests, which involve managing and maintaining the services provided to you in a way that aligns with both our and your interests.

For personalization and analysis.

Legal basis: Consent where required by applicable law in certain circumstances. Legitimate business interests, which involve improving and developing our services by considering your usage and, when necessary, enhancing our products (including improving our machine learning models), in alignment with our interests.

Ensure the security and integrity of our services. Providing a secure and reliable environment is key to building a responsible platform, and we achieve this by using data in the following ways:

Legal basis: Compliance with legal obligations. Legitimate business interests, specifically our responsibility to ensure the security and integrity of the services, provide uninterrupted services free from cyberattacks, and our duty to detect, prevent, and resolve fraud, security, and technical issues to ensure compliance with applicable laws and regulations.

In order to comply with any applicable laws and/or regulations, legal processes, we use data to investigate disputes or claims related to our services. In certain cases, we may be required to use your information to respond to legal, governmental, or regulatory requests. We may use the IP address associated with your login to determine your approximate location in order to comply with global privacy regulations and provide necessary notices and/or consent mechanisms.

Legal basis: Compliance with legal obligations. Our legitimate interests.

To maintain and defend our legitimate interests, exercise any rights, assert any claims, and for any other legitimate business purposes. This includes any incidental business purposes related or connected to the above, or any other purposes disclosed to you when we collect your personal information.

Legal basis: Legitimate business interests.

3. Who we share your personal information with.

We may disclose your personal information to the following categories of recipients:

Pairing Applications: Third-party applications and accounts linked to your UREVO account. As part of our service features, we allow you to connect your UREVO account with third-party applications (such as Health Connect®, Google®, Apple®, Apple Health®, and similar apps) ("Pairing Applications"). If you choose to connect your UREVO account, we may share certain personal information with the pairing applications based on the settings you manage on your device for third-party sharing. This may include information generated during your use of the service (such as exercise data, body information) and other personal profile information. The processing of your personal information by the pairing applications is governed by their respective privacy policies. These third parties may associate the information you use through our services with any personal information they may have about you for their own purposes.

Other users of our services: Depending on your profile settings and how you interact with our services, some of your personal information may be visible to other UREVO users. For example, if you enable the leaderboard feature, other users will be able to see your nickname, avatar, and exercise data. You can manage or disable this permission at any time in the settings page to control the visibility of your information.

Other. We may share your personal information in accordance with your instructions or with your consent, such as when we share your personal information with your service provider to activate your account. Additionally, we may disclose your personal information if we determine that such disclosure is appropriate or necessary for matters of national security, law enforcement, or other issues of public importance. In cases where there is a legal basis, we may also disclose your personal information if we determine that disclosure is reasonably necessary for enforcing our terms and conditions, protecting our operations or users, or in connection with a reorganization, merger, or sale.

4. Fitness Data

"Fitness Data" refers to any information related to your fitness performance and/or exercise, including calorie consumption, exercise distance, steps, and workout duration. We do not use your fitness data for identification purposes.

Why do we process your information?

UREVO will not disclose, re-disclose, or otherwise share fitness data unless:

5. International Data Transfers

Your personal information may be transferred to, processed, and stored in countries outside of your country of residence, including the United States. Such recipients may be located in any country where UREVO operates its business, as well as in other regions where our vendors and partners may transfer data. Further details can be provided upon request.

We take appropriate safeguards to protect your personal information in accordance with this Privacy Policy specifically in relation to any international transfer. This includes implementing an intra-group data sharing agreement that includes safeguards and protections for any use of your personal information by our group entities and incorporates the European Commission's Standard Contractual Clauses, which require all group companies to protect relevant information in accordance with European Union and UK data protection laws. We may engage third-party service providers to perform certain tasks on our behalf, such as processing or storing personal information for the aforementioned purposes.

We have implemented similar appropriate safeguards and comply with applicable legal requirements when transferring Personal Information to countries, and we will ensure compliance with applicable laws governing the transfer of personal information across different countries or regions, thereby ensuring that your personal data receives the same high level of privacy protection regardless of where the specific data processing occurs, such as utilizing Binding Corporate Rules, Standard Contractual Clauses, and other data transfer mechanisms and/or rely on the European Commission adequacy decisions for certain countries outside of the European Economic Area should it be applicable with our third party service providers and partners. Further details can be provided upon request.

6. Your Privacy Rights and Preferences

At UREVO, we prioritize our users and respect your rights to exercise privacy rights and preferences. Whenever possible, we empower you with control over the personal data we collect to ensure its accuracy and reflect your preferences. Depending on the country/region you are in or the state in the U.S., we respect your rights to know, access, correct, transfer, restrict processing, and delete your personal data. Please note that these rights may not always apply, and there are certain exceptions.

Additionally, we will continue to retain some of your personal data within the legal limits, and such information will not be deleted from the UREVO system. We retain your personal information in the following circumstances:

We will also confirm your identity before processing your request. If we are unable to verify your identity or confirm that you have the authority to make a request on behalf of someone else, we may not be able to respond to your request or provide personal data.

Please note that if you delete your account associated with any of our services, all UREVO accounts and all related information, including exercise records and body data, will be deleted.

6.1 Consent

If we collect and process your personal information with your consent, you can withdraw your consent at any time by using the contact details provided in the "How to Contact Us" section. Please note that such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal.

7. Data Retention

UREVO will retain the personal information we collect as described in this Privacy Policy, until you cease using our services or for the duration necessary to fulfill the purposes for which the data was collected, including providing our services, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, and complying with applicable laws. However, legal requirements may mandate that we retain some or all of your personal information for a period longer than our usual retention period. The specific retention period depends on the nature of the information, the purposes for which it was collected and processed, and the nature of the legal requirements.

8. Information Security

We take measures to ensure that your information is securely processed and complies with the requirements of this Privacy Policy. We maintain commercially reasonable administrative, technical, and physical safeguards (varying according to the sensitivity of the personal information) designed to prevent unauthorized use, disclosure, or access to personal information.

9. Legal Basis for Processing

The legal basis for collecting and using the above personal information will depend on the specific personal information involved, applicable laws, and the specific context in which we collect the personal information.

However, we generally collect your personal information only in the following cases: (i) we need the personal information to fulfill our contract with you (e.g., providing our services); (ii) processing the information is in our legitimate interests and is not overridden by your rights; or (iii) we have obtained your consent. In certain cases, we may also have a legal obligation to collect your personal information, or we may need the information to protect your vital interests or those of others.

If we request your personal information to comply with legal requirements or to fulfill our contract with you, we will clearly explain at the relevant time whether providing your personal information is mandatory (and what the consequences may be if you do not provide the information).

If we collect and use your personal information based on our (or any third party's) legitimate interests, such interests are typically for the operation of our services, to communicate with you when necessary to provide our services, and for our legitimate business interests such as responding to your inquiries, improving our products and services, conducting marketing, or detecting and preventing illegal activities. We may have other legitimate interests, and we will clearly explain those interests to you at the relevant time.

If you have any questions or need more information about the legal basis for our collection and use of your personal information, you can contact us using the details provided in the "How to Contact Us" section below.

10. Children's Privacy

UREVO services are not intended for children, nor are they designed for children. If you do not meet the minimum age requirements applicable in your jurisdiction, or the age requirements specified in our terms of service, we do not knowingly collect personal information from children.

If we become aware that we have collected personal data from a child who does not meet the minimum age requirements, we will promptly delete that personal data.

11. How to Contact Us

If you have any questions about our privacy practices, this privacy policy, or wish to contact us or our data protection officer, you can reach us by email at appservice@urevo.com or at the following address.