EMITEVER Privacy Policy

Effective Date: September 3, 2026
Last Updated: September 3, 2026

CUTELED LIGHT CO., LIMITED ("CUTELED", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy ("Policy") describes how we collect, use, disclose, store, and otherwise process Personal Data in connection with your use of the EMITEVER mobile application, related smart devices, and associated services (collectively, the "Services").

Before using the Services, please read this Policy carefully. It explains the types of Personal Data we may process, the purposes for which we process it, how information may be shared or transferred, and the choices and rights available to you.

By registering for or using the Services, you acknowledge that you have read and understood this Policy. Where applicable law requires consent for a particular processing activity, we will request that consent separately. If you have questions about this Policy or our privacy practices, please contact us at b2b@emitever.com.

1. Definitions

• Personal Data: means information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual, whether alone or in combination with other information available to us.

• Sensitive Personal Data: may include categories of information that receive additional protection under applicable law, such as precise location information, biometric information, health information, communications content, or certain transaction information. Where required, we will provide an appropriate notice and obtain consent before processing Sensitive Personal Data.

• Smart Devices: means connected computing or electronic devices capable of communicating through a network or wireless connection, including smart lighting products, switches, outlets, controllers, sensors, home appliances, environmental devices, security devices, and other compatible smart products.

• App: means the EMITEVER mobile application through which users may connect to, configure, monitor, automate, and remotely control compatible Smart Devices through the applicable Internet of Things (IoT) platform.

2. Personal Data We Collect

We collect Personal Data that is reasonably necessary to provide and operate the Services. If you choose not to provide information that is necessary for a requested feature, we may be unable to provide that feature.

2.1 Information You Voluntarily Provide

• Account Information: When you create or manage an account, we may collect information such as your name, email address, phone number, username, login credentials, nickname, profile picture, country or region code, language preference, and time-zone information.

• Feedback and Support Information: When you contact us or use feedback and support features, we may collect your contact information, the content of your request, device information relevant to the issue, and any files, photographs, or other materials you choose to provide.

2.2 Information Used for Optional App Functions

Certain App features may request access to permissions on your mobile device. These permissions are used only when relevant to the feature you choose to use. You may manage permissions through your device settings and, where available, the App's privacy settings. Disabling a permission may prevent the corresponding feature from functioning.

• Location: With your permission, we may process approximate or precise location information for functions such as device discovery and pairing, location-based automations, geofencing, weather-related services, or other location-dependent Smart Device features. Where a feature relies on a third-party mapping or location service, information may be processed by that service in accordance with its own privacy terms.

• Camera: Camera access may be used when you choose to scan a QR code, pair a Smart Device, capture an image or video, or use another feature that requires the camera. Camera information is accessed only when you activate a relevant feature.

• Photos and Videos: With your permission, the App may access photographs or videos that you choose to upload, for example to update a profile image or provide evidence when reporting a device or service issue.

• Microphone: With your permission, microphone access may be used for features such as recording video with audio, sending voice information, or interacting with supported voice functions. Audio is collected only when you activate a feature that requires microphone access.

• Device Storage (Android): Where required by the Android operating system or App functionality, storage access may be used to read or write files necessary for features you request, to store information locally, or to retain diagnostic or crash information.

• Notifications: With your permission, we may send service notifications, Smart Device status messages, alerts, security notifications, or other operational messages. You may manage notification permissions through your device or App settings.

• Display Over Other Apps / Alert Window (where supported): If a supported Smart Device or feature requires it, you may choose to allow the App to display information, such as a camera view or device alert, in a separate or overlay window.

• Bluetooth: Bluetooth may be used to discover, pair, configure, communicate with, display the status of, and control compatible Smart Devices. Bluetooth access is used in connection with these functions when enabled.

Turning off a permission withdraws authorization for future collection through that permission, but does not affect processing that lawfully occurred before the permission was disabled.

2.3 Information We Collect Automatically

• Mobile Device and Technical Information: We may automatically collect information such as device model, IP address, wireless connection information, operating-system type and version, App version, software version, push-notification identifiers, mobile network information, and technical information needed to maintain a secure and reliable operating environment.

• Usage Data: We may collect information about interactions with the Services, including feature usage, visits, clicks, downloads, commands, messages, and other activity associated with the App and connected Services.

• Log and Diagnostic Information: We may collect system logs, error reports, crash information, IP address, language settings, operating-system version, access date and time, and similar diagnostic information to identify and resolve problems and improve service reliability.

Where technical or device information does not identify you by itself, we treat it as Personal Data when it is combined with other information in a manner that identifies or can reasonably be linked to you.

2.4 Smart Device Information

• Basic Smart Device Information: When you connect a Smart Device, we may collect information such as the device name, device identifier, model, online status, activation time, firmware version, and upgrade information.

• Connection and Configuration Information: Depending on the device and connection method, we may process information necessary to connect or configure the Smart Device, such as Wi-Fi information, network information, Bluetooth information, and device MAC address.

• Information Reported by Smart Devices: Depending on the type of Smart Device and the features you use, connected devices may report device status, operating state, network status, operation logs, commands, service interaction data, automation information, sensor information, and other data necessary to provide the requested smart-device functionality.

3. How and Why We Use Personal Data

• Provide and Operate the Services: We process account information, device information, usage information, location information where applicable, and Smart Device information to create and maintain accounts, connect and control Smart Devices, provide automations and other requested functions, and otherwise perform our agreement with you.

• Maintain, Secure, and Improve the Services: We may process technical, usage, diagnostic, location, and Smart Device information to maintain service functionality, troubleshoot problems, improve performance, develop features, protect accounts and systems, and detect or prevent fraudulent, abusive, or unauthorized activity.

• Service and Administrative Communications: We may use your contact information to send important information about the Services, account security, device alerts, purchases or subscriptions, and changes to our terms, policies, or Services. Where a notification is optional, you may manage it through the App or device settings.

• Data Analysis: We may analyze usage, diagnostic, and device data to understand how the Services operate, identify malfunctions, improve user experience, and evaluate features. Where applicable law requires consent for optional analytics, we will rely on that consent and provide an available method to withdraw it.

• Marketing and Personalization: Where permitted by law and, when required, with your consent, we may use account, usage, or device information to personalize content, recommend relevant products or features, display promotional information, or invite you to surveys. You may opt out through available privacy settings or other methods described in the relevant communication.

• Legal Compliance and Protection: We may process or disclose information where reasonably necessary to comply with law, regulation, legal process, or lawful governmental requests; enforce our User Agreement or other policies; protect the rights, property, or safety of CUTELED, our users, third parties, or the public; or detect, prevent, investigate, or address fraud, security, or technical issues.

If we materially change the purposes for which Personal Data is processed, we will provide notice as required by applicable law and, where necessary, request additional consent.

4. How We Share Personal Data

We do not disclose Personal Data except as described in this Policy, as needed to provide the Services, with your consent, or as otherwise permitted or required by law. We may share Personal Data with:

• Service providers that perform functions on our behalf, such as cloud and IoT infrastructure, hosting, analytics, payment processing, IT services, customer support, communications, security, and other technical or operational services.

• Business partners, device manufacturers, distributors, or other parties that provide Smart Devices, integrations, networks, platforms, or systems through which you access or use the Services.

• Our subsidiaries, affiliates, or related companies for legitimate business and operational purposes, subject to appropriate confidentiality and data-protection requirements.

• A successor, purchaser, affiliate, or other relevant party in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, joint venture, assignment, transfer, insolvency, or similar corporate transaction.

• Government authorities, courts, regulators, law-enforcement agencies, or other parties when we reasonably believe disclosure is necessary to comply with applicable law or legal process, enforce our agreements and policies, protect our operations or systems, protect rights, property, or safety, or investigate unlawful, fraudulent, deceptive, or malicious activity.

• Other third parties when you direct us to share information or otherwise provide your consent.

5. International Transfers

We may store, process, or transfer Personal Data in countries or regions other than the place where you live in order to operate the Services and work with service providers and business partners. Privacy and data-protection laws in those jurisdictions may differ from those in your jurisdiction.

Where applicable law requires safeguards for international transfers, we will use appropriate legal mechanisms designed to provide an adequate level of protection, which may include contractual safeguards such as approved standard contractual clauses or other legally recognized transfer mechanisms.

You may contact us using the information in Section 11 if you would like additional information about safeguards applicable to international transfers.

6. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have rights regarding your Personal Data. These may include the right to:

• Request access to Personal Data we process about you.

• Request correction of inaccurate or incomplete Personal Data.

• Request deletion of Personal Data, subject to applicable legal exceptions and retention requirements.

• Request restriction of certain processing.

• Request a copy or transfer of certain Personal Data where a right to data portability applies.

• Object to certain processing or opt out where processing is based on consent or where applicable law provides an objection right.

• Withdraw consent at any time for processing that relies on your consent, without affecting the lawfulness of processing carried out before withdrawal.

You may be able to exercise certain rights directly through the App, including account settings, privacy settings, device-permission settings, notification settings, device unbinding, data-export features, or the account-deletion function. Available menu names and paths may vary by App version, device operating system, region, and feature configuration.

You may also submit a privacy request by contacting b2b@emitever.com. Please describe the request and the information or account involved. We may need to verify your identity before completing a request. We will respond within the period required by applicable law.

7. Withdrawal of Permissions and Account Deletion

• You may withdraw system permissions such as location, camera, photos/videos, microphone, Bluetooth, notifications, storage, and other device permissions through your mobile-device settings and, where available, through the App.

• You may disable optional analytics or personalization through available privacy settings where those controls are provided.

• You may unbind a Smart Device from the App to stop future collection associated with that device through your account, subject to information that must be retained for legitimate or legal purposes.

• If you have linked your EMITEVER account to a supported third-party service, you may need to disconnect that integration through the App and/or the third-party service.

• Where available, you may request deletion or deactivation of your account through the App's account and security settings. Account deletion may result in loss of access to connected devices, automations, settings, and other account-based Services.

Withdrawal of consent or permissions may prevent us from providing features that depend on the affected information. Withdrawal does not affect processing that lawfully occurred before the withdrawal.

8. Security

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect Personal Data against unauthorized access, loss, misuse, alteration, or disclosure. These measures may include access controls, authentication mechanisms, encryption or protected transmission methods where appropriate, system monitoring, validation, logging, and other security practices appropriate to the nature of the Services.

No method of electronic transmission or storage can be guaranteed to be completely secure. If you believe that your account or interaction with the Services has been compromised, please contact us promptly at b2b@emitever.com.

9. Data Retention

We retain Personal Data only for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain security and business records, comply with legal obligations, resolve disputes, and enforce agreements.

Retention periods may vary depending on the amount, nature, and sensitivity of the information, the purposes for processing it, technical requirements, and applicable legal obligations. When Personal Data is no longer required, we will delete, anonymize, or otherwise securely dispose of it where reasonably practicable. If immediate deletion is not technically feasible, we will take appropriate measures to prevent further use except as legally required.

10. Children's Privacy

The Services are not directed to children under thirteen (13), or any higher minimum age required by applicable law in the child's jurisdiction. We do not knowingly collect Personal Data from children below the applicable minimum age without legally valid authorization from a parent or legal guardian. If we learn that Personal Data has been collected from a child in violation of applicable requirements, we will take appropriate steps to delete it.

11. Changes to This Privacy Policy

We may update this Policy from time to time to reflect changes to the Services, our privacy practices, legal requirements, or other operational needs. If we make material changes, we will provide notice as required by applicable law, which may include notice through the App, by email, or through another appropriate method. We encourage you to review this Policy periodically.

12. Contact Us

CUTELED LIGHT CO., LIMITED
Office No. 1712, Level 17, Landmark North
39 Lung Sum Avenue
Sheung Shui, New Territories, Hong Kong
Email: b2b@emitever.com

Draft for review: Prepared from the Tuya OEM privacy-policy template supplied for the EMITEVER app. This draft should be reviewed and approved by the appropriate company/Tuya contacts before publication.