App Name: Pulse

Package Name: com.landry9527.softwater.controllerc

Developer: Landry9527

Effective Date: September 3, 2026

Update Date: September 16, 2026

This Privacy Policy applies to the mobile application Pulse (package name: com.landry9527.softwater.controllerc), developed and operated by Landry9527 (hereinafter collectively referred to as "We"). We are committed to protecting your personal privacy. This Privacy Policy (hereinafter referred to as the "Policy") describes how we process personal data and safeguard information privacy when you use the following services, products and supporting mobile applications (collectively the "Products").

When you interact with our Products, please read this Policy carefully to understand the purposes and security measures for our collection and processing of your personal data, including how we use, store, share and transfer personal data. Within this Policy, you may exercise your privacy rights over personal data (such as the right of access and right to erasure) in accordance with our instructions.

If you agree to this Policy, or start/continue using our Products or services through proper means without contacting us to express objection, we shall deem that you have fully understood and consented to this Policy. If you have any questions, comments, suggestions or complaints during reading, please contact us.

Definitions

• Personal Information: Information recorded electronically or by other means that can identify a specific natural person either alone or in combination with other information, or reflect the activity status of a specific individual.
• Sensitive Personal Information: Including personal biometric data, communication records and content, health-related information, transaction information and precise location information. When we provide specific products or services that involve collecting sensitive personal data, we will obtain your consent through prominent and explicit notice prior to collection.
• Smart Devices: Refers to water softeners and control valves equipped with human-machine interfaces and capable of transmitting information via wireless networks.
• Application: The mobile application "Pulse" provided by us, which enables end users to remotely control smart devices and connect to the supplier's Internet of Things (IoT) platform.

What Personal Information We Collect

We will request necessary personal data to deliver our services. If you refuse to provide such personal data, we cannot provide corresponding Products or services to you.

1. Information You Voluntarily Provide to Us

• Account Data: When you register or log into our account, we collect your email address. During your interaction with our Products, we may further collect your account nickname, country code, language preference and time zone information.

Information Collected for Supplementary Functions

To provide you with more convenient and high-quality Products and/or services and improve your experience, we will collect and use your personal information for the following supplementary services. Refusing to provide such information will not affect your use of basic APP functions, but you will not be able to enjoy the experience brought by these supplementary services:

Location-Based Supplementary Services

If you enable the location function of your mobile device via system authorization and use location-based services, we will collect and use your location information to facilitate device network configuration via the APP. With your consent when using specific Products or services, we may collect your real-time precise or non-precise geographic location information. You may disable location services in your mobile device system to stop our collection of your location data.

Storage Permission Supplementary Services

We apply for this permission to ensure stable client operation. After you grant read/write access to your device storage, we will read or write necessary information such as images, files and crash logs from your device storage for functions including information display and local crash log recording.

2. Information Automatically Collected by Us

• Device Information: When you interact with our Products, to guarantee your normal use of services, maintain stable service operation, optimize user experience and protect your account security, we automatically collect device model, Android ID, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files and mobile network information.
• Usage Data: During your interaction with our services, we automatically collect usage data related to visits, clicks and device control operations, so that we can diagnose faults and improve the service.
• Log Information: System and exception logs will be uploaded when you use our application, including your IP address, system language, operating system version, access date and time, etc.

Please note that standalone device information and service log information cannot identify a specific natural person. If we combine such non-personal information with other data to identify a specific natural person, or combine it with personal information, such non-personal information shall be deemed personal information during the combined use. Unless authorized by you or otherwise stipulated by laws and regulations, we will anonymize and de-identify such information.

• Location Information: Consistent with the location-based service rules above, we collect and use your location information for APP device network configuration only when you enable mobile device location permissions. With your consent for specific Products or services, we may collect real-time precise or non-precise geographic location data. You may disable location services in your mobile device system to stop such collection.

3. Smart Device-Related Information

• Basic Smart Device Information: When you connect our Products to the APP, we collect basic smart device information including device name, Device ID, online status, activation time, firmware version and upgrade records.
• Data Reported by Smart Devices: We collect operational data reported by the smart water softener you connect to the APP.

Purposes and Legal Basis for Processing Personal Data

We process your information for the following purposes:

• Service Delivery: We process your account and profile data, device information, usage data, location information and smart device-related information to provide the Products and services you request or purchase. The legal basis for such processing is the performance of the contract between us in accordance with our Terms of Service.
• Service Improvement: We process your device information, usage data, location information and smart device-related information to ensure product functionality and security, develop and upgrade our Products and services, analyze operational efficiency, and detect and track fraud or unauthorized usage. The legal basis for such processing is the performance of the contract between us in accordance with our Terms of Service.
• Legal Compliance: We may process your personal data when we deem it necessary or appropriate to:
  1. Comply with applicable laws and regulations;
  2. Abide by legal procedures;
  3. Respond to requests from public institutions and government authorities;
  4. Perform our terms and conditions;
  5. Protect our operations, business and systems;
  6. Safeguard the rights, privacy, security and property of Us and/or other users including yourself;
  7. Seek available remedies or limit compensations we may be liable for.

We may use your collected personal information for other purposes with specific notice provided at the time of collection and your consent as required by applicable laws. If the purpose of processing your personal information changes, we will notify you of such changes via email and/or prominent website notices, and inform you of your options regarding your personal data.

With Whom We Share Your Personal Data

The APP only shares your personal data in ways disclosed to you. We may disclose your personal data to the following parties:

• Third-party service providers that provide business-related services for us (such as email delivery services) to enable them to deliver services to us.
• Customers and other business partners that directly or indirectly supply smart devices and/or the networks and systems you use to access our website and services.
• Affiliates or other third parties in the event of restructuring, merger, sale, joint venture, assignment, transfer or other disposal of all or part of our business, assets or equity (including without limitation any bankruptcy or similar proceedings). In such cases, you will receive clear notification via email and/or our website regarding ownership changes, incompatible new personal data usage methods and your options for personal data.
• When we deem it necessary or appropriate to:
  1. Comply with applicable laws and regulations;
  2. Abide by legal procedures;
  3. Respond to requests from public institutions and government authorities, including authorities outside your country/region of residence;
  4. Perform our terms and conditions;
  5. Protect our operations, business and systems;
  6. Safeguard the rights, privacy, security and property of Us and/or other users including yourself;
  7. Seek available remedies or limit compensations we may be liable for.
• All other third parties only with your explicit consent.

International Transfer of Collected Information

The APP complies with data localization requirements under applicable laws and regulations and stores data within corresponding jurisdictions. For operational convenience, we may transfer, store and process your personal data in jurisdictions outside your place of residence, which may adopt different data protection laws. In such cases, we will ensure adequate protection of your information through measures including but not limited to agreements based on the EU Standard Contractual Clauses approved under Article 46 of the General Data Protection Regulation (GDPR).

If you wish to learn more about our security safeguards, you may contact us directly via the channels specified in this Policy.

Your Rights Relating to Personal Data

We respect your rights over the personal data we hold. You may contact us via email. All requests are free of charge. We will complete verification and processing within 15 working days or 30 calendar days. When submitting a request via email, please specify which information you wish to modify, whether you request full erasure of your personal data, or restrictions on our processing of your personal data. Please note that for security purposes, we will require you to verify your identity before further processing your request.

You are entitled to:

• Request access to all personal data we process relating to you;
• Request rectification of inaccurate or incomplete personal data relating to you;
• Request erasure of your personal data;
• Request temporary or permanent restriction on our processing of part or all of your personal data;
• Request portability of your personal data to yourself or a third party where processing is based on your consent or our contract and conducted via automated means;
• Object to or refuse our processing of your personal data where processing relies on your consent or our legitimate interests.

Right to Withdraw Consent

We guarantee your right to withdraw consent through the following channels:

1. Privacy permissions accessible via device system settings: you may withdraw consent by modifying device permissions for functions including location, camera, album, microphone, Bluetooth settings, notifications, etc.
2. Unbind smart devices within the application to stop collection of your smart device usage information.

Withdrawing consent or authorization will render us unable to continue providing services corresponding to the revoked permissions. However, withdrawal of consent or authorization shall not affect prior personal data processing conducted with your consent before revocation.

Account Cancellation

You may cancel your account via the path: [Mine] - [Account & Security] - [Delete Account].

Security Safeguards

We adopt commercially reasonable physical, administrative and technical safeguards to maintain the integrity and security of your personal data. Our company implements multiple security strategies to effectively protect user and device data security.

• Device access: We guarantee data security, access authentication and authorization management.
• Data communication: Secure encryption algorithms, transmission encryption protocols and commercial-grade dynamic key-based encryption transmission are supported.
• Data processing: Strict data filtering, validation and complete data audit workflows are adopted.
• Data storage: All user confidential information is securely encrypted for storage.

If you believe your interaction with our services is insecure for any reason (e.g. your account security has been compromised), please notify us immediately via our designated email address.

Data Retention Period

We will process your personal data for the shortest period necessary to fulfill the purposes set out in this Policy, unless a longer retention period is required by specific laws. We will determine an appropriate retention period based on the volume, nature and sensitivity of personal data. Upon expiration of the retention period, we will destroy your personal data. If permanent destruction is technically unfeasible, we will implement appropriate measures to prevent further use of your personal data.

Third-Party Information Sharing and SDK Service List

To ensure stable operation of the APP or enable relevant functions, we may integrate third-party Software Development Kits (SDKs) and Application Programming Interfaces (APIs).

We conduct rigorous security testing on all SDKs to safeguard data security.

This list allows you to fully understand how third-party partners access and process your personal information. As third-party services (including SDKs and APIs) may undergo irregular version iterations or business policy adjustments, their data processing rules may change accordingly. For definitive details on how third parties process your data, please refer to their official privacy policies or service agreements.

I. Third-Party Information Sharing List

1.1 Sharing of User Account Information

• Information Category: Account Information
• Specific Information: User Email Address
• Purpose of Sharing: User Registration & Identity Verification
• Recipient: Tuya Smart Platform
• Sharing Method: Encrypted API Transmission
• Security Measures: TLS 1.2+ Encryption, Data Desensitization

1.2 Sharing of Device-Related Information

• Information Category: Device Information
• Specific Information: Water Softener Device ID, Model, Status
• Purpose of Sharing: Remote Device Control & Status Synchronization
• Recipient: Tuya Smart Platform
• Sharing Method: Encrypted MQTT Communication
• Security Measures: Device Identity Authentication, End-to-End Encryption

• Information Category: Usage Data
• Specific Information: Device Usage Frequency, Water Softening Settings
• Purpose of Sharing: Product Function Optimization & User Experience Improvement
• Recipient: Tuya Smart Platform
• Sharing Method: Aggregated & Anonymized Data Transmission
• Security Measures: Data Minimization Principle, De-identification Processing

II. SDK Service List

2.1 Tuya Smart SDK

• SDK Name: Tuya Smart SDK
• Version: Latest Stable Release
• Function Description: Provides core capabilities including device connection, remote control and firmware upgrade.
• Types of Information Collected:
  • Device Information:
    • Unique Device Identifier (Device ID)
    • Device Model & Firmware Version
    • Device Network Status
  • User Operation Information:
    • Records of Device Control Commands
    • Scene Preference Settings
    • Firmware Upgrade Logs
  • Network Information:
    • IP Address (for device discovery and connection)
    • Network Type (Wi-Fi / Mobile Network)
    • Signal Strength
• Data Processing Rules:
  • All data transmissions adopt TLS encryption
  • Sensitive user information undergoes desensitization
  • Device control commands adopt asymmetric encryption
• Privacy Policy Link: https://www.tuya.com/privacy

2.2 Tencent Bugly (Crash Reporting)

• SDK Name: Bugly
• Provider: Tencent
• Function Description: Collects App crash and exception logs so that we can locate defects and improve stability.
• Types of Information Collected: Crash and exception stack traces, device model, operating system version, App version, launch time, network type.
• Privacy Policy Link: https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56

III. Data Processing Principles

• 3.1 Data Minimization Principle: We only collect the minimum information necessary to deliver product functions and do not gather user data irrelevant to water softener control.
• 3.2 Purpose Limitation Principle: All collected information shall only be used for the following purposes:
  • Enable intelligent control of water softeners
  • Provide user account services
  • Optimize product experience
  • Fault diagnosis & technical support
• 3.3 Security Protection Measures:
  • Transmission Security: All network communications adopt HTTPS / TLS 1.3 encryption
  • Storage Security: Sensitive information is encrypted at rest, with periodic security audits
  • Access Control: Strict permission management based on the least privilege principle
  • Data Retention: Data shall be retained for the shortest period required by applicable laws and regulations

IV. User Rights Statement

You are entitled to the following rights:

• Right to Know: Access full transparency on information collection and usage
• Right of Access: View and obtain copies of your personal data
• Right to Rectification: Correct inaccurate personal information
• Right to Erasure: Request deletion of unnecessary personal information
• Right to Withdraw Consent: Revoke your consent for information processing

Statement on Policy Revision

We may update this Policy to reflect changes in our data processing practices. If we implement material revisions, we will notify you via email (sent to your registered account email address) or publish notices on the mobile application prior to the effective date of changes. We recommend you review this page regularly to obtain the latest information on our privacy practices.

Contact Us

If you have any questions regarding our data processing practices or this Policy, please contact us:

Developer: Landry9527

Email: 740175208@qq.com