AI LINKY Privacy Policy
AI LINKY Privacy Policy
Last Updated: 2026-06-09
CONTENTS
I. Introduction
II. Personal Data We Collect
III.Cookies and Similar Technologies
IV. Legal Basis and How We Use Your Personal Data
V.How We Share Your Personal Data
VI.How Your Personal Data Transfers Globally
VII. How We Store and Protect Your Personal Data
VIII. Your Data Subject Rights
IX.Children's Privacy
X. Update to this Policy
XI.Contact Us
Thank you for using AI LINKY (hereafter referred to as "AI LINKY", "this product", or "the device")! We respect your concerns about privacy and appreciate your trust and confidence in us. We hereby develop this Privacy Policy (referred to as "this Policy") to help you understand how we collect, use, disclose, protect, store, and transmit your personal data. It also describes your data subject rights and available choices. This Privacy applies when you use our products, services, applications, and software; when you interact with us via communication channels such as email, phone, or social media; or when you engage with us in any other context (collectively, the “Services”).
Data User: UBTECH Robotics Corp Ltd (hereinafter referred to as "UBTECH", "we", "us", or "our") is the user (or similar term under applicable laws) of any data processed in connection with this Policy.
In this Policy, "personal data" means any data that can be used to directly or indirectly identify an individual, except as otherwise specifically provided by applicable law in your region. It includes data such as name, contact details, facial pictures and IP address.
Please read carefully and fully understand this Policy herein before using or continuing to use our Services and, if necessary, make appropriate choices in accordance with the guidelines in this Policy. If you have any questions about this Policy, please contact us regarding your requests and we will respond to your query as soon as possible.
We collect personal data to provide, operate, and improve our Services. The specific data we collect depends on how you use our products and services or interact with us. In some cases, you can choose not to provide such data, but this may prevent us from providing you with corresponding products or services, or may mean that we cannot respond to or resolve any issues you have raised.
1.The data you provide to us
(1) Account and device binding data
To help you register for a AI LINKY account, bind the device to the App and ensure a secure operating environment, we may collect:
- your network identity data, including your country or region, email address, verification code and password;
- your third-party account (when you log in using your Apple ID or Google Account)
- The device SN, binding time, binding IP address, and binding account;
To complete this binding process, you will also need to grant the App permissions to access Bluetooth, location (Under the Android system, the setting of the Google framework is that location data must be obtained first to establish a Bluetooth connection); we don't collect or upload geolocation data).
(2) Profile data
After you bind the device through the App, you can also complete your personal information in the personal center, such as your account nickname, gender and date of birth. In addition, you can also edit the bound AI LINKY device information, such as the device nickname and how you want it to call you.
(3) Network data
When using AI LINKY, you need to configure the Wi-Fi network for the device through the App. We will collect the Wi-Fi data (SSID, Wi-Fi password) and device ID you configure. The Wi-Fi password data is only stored locally on the device and will not be uploaded to the cloud.
(4) Voice command data
The AI LINKY supports voice commands. User-related voice data will be sent to the Alibaba Cloud platform for speech recognition, enabling users to control the device's volume and actions (such as singing and dancing) via voice commands. Please note that some voice commands need to be implemented through generative AI services. If you are not authorized to use generative AI services, you may not be able to execute the relevant voice commands.
（5）Intelligent voice dialogue data
When you use the intelligent Chinese conversation function or English practice of the AI LINKY, we will collect your voice chat records and English conversation records, and save them as the device's memory for a certain period of time. When you ask the AI LINKY weather-related questions, we will collect your location data through the IP address of WiFi to complete the local weather query. We implement the above functions by accessing Alibaba's Qwen large language model. We recommend that you do not disclose any privacy or other unauthorized data about yourself or others when using it in non-home scenarios. All data you provide to us is voluntarily provided by you and has obtained the necessary legal authorization.
Please note that AI LINKY currently cannot isolate and store conversation data of different users, and we hereby remind you to take notes to exercise caution when disclosing private data when using the Intelligent voice dialogue function in multi-person scenarios to avoid the leakage of your private data.
(6) Customer service data
You can directly click on "Mine" - "Feedback" in the App, or contact us through the contact information at the end of this policy. When you contact us for support, feedback, or dispute resolution, we collect necessary data such as your nickname, contact details, the content of your feedback and any attachments, communication records, call logs, and any evidence you provide (e.g., images/videos/text). If your inquiry relates to a specific order, we may also use your order data and shipping address.
(7) Survey data
If you participate in our optional surveys, we collect the data you submit in your responses.
2.Data we collect from you automatically
To the extent necessary to provide you with the device and its related services, we also collect the following personal data without your active provision to us:
(1) Device and application software data.
We collect certain data automatically when you use the Services. The related data may include mobile device model, software version data, operating system and version, mobile network data, device manufacturer, UUID.
(2) Log data
When you use our Services, we may automatically collect and log device IDs, system version, main service version, firmware version, storage space, battery capacity, online status, activation IP address, device wake-up log, usage duration statistics, etc.
3.Data from other sources
Our Services may, from time to time, contain links to and from social media platforms. If you choose to connect with us through a social media platform, we may, through the social media platform connection, collect additional data from you, such as your usernames, chat content. Similarly, the social media platforms may collect data about your interaction with our Services. We do not have any control of the collection, use and sharing of your data when using any social media platforms. You should read any associated privacy policies before using them.
4. Non-Personal data
We also collect aggregated, non-personal data that does not directly identify you, such as statistical data on user operations (e.g., clicks). This data is used to improve our services. If non-personal data is combined with personal data, it will be treated as personal data during the period of combination.
III.Cookies and Similar Technologies
To ensure the normal operation of our services and provide you with a smoother and more convenient user experience, we may sometimes place small data files on your computer, mobile communication terminal, or other devices. These data files may include Cookies, Clickstream, Web, or other local storage provided by your browser or associated applications (hereinafter collectively referred to as "Cookies"). Cookies are small data files that a website or mobile application stores on your computer, mobile communication terminal, or other devices when you visit the website.
They enable us to remember your actions and preferences (such as login name, interface language, setting preferences, etc.) over a period of time. We may collect and store relevant data about your visits to our website or mobile application through various technologies, which can identify your identity, save you the trouble of repeatedly entering registration data, or help determine the security status of your account. Therefore, whenever you return to the App or browse pages, you do not need to keep re-entering or reconfiguring user settings. You can clear the cache in the corresponding settings of your browser or APP. Please understand that some of our services can only be implemented through the use of Cookies.
IV. Legal Basis and How We Use Your Personal Data
We use your personal data only on a legal basis. According to applicable local laws, we may use your personal data for the following purposes under one of the legal bases: contractual necessity, legitimate interests, consent, compliance with applicable laws and regulations.
1. Contractual necessity
(1) To provide and maintain our services to you. For example, we use your personal data to bind your device to the App, enable device control and management, configure voice output, and provide real-time visual sharing.
(2) To synchronise and store the data you have uploaded or downloaded, as well as the data needed for upload and download operations.
(3) To communicate with you about the Service.
(4) To troubleshoot problems after you send error details to us.
2. Legitimate interests
Whenever we rely on legitimate interests for processing, we ensure that we consider and balance our interests against the individual’s interests before processing. We do not use your personal data on the basis of legitimate interest for activities where individuals’ interests override our interests.
(1) To improve the Services and develop new features.
(2) To carry out audits, data analysis, and research.
(3) For safety, security, fraud and abuse measures.
3. Your consent
When we process your data based on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on such consent before it is withdrawn.
(1) To participate in surveys and research: We may conduct online surveys from time to time to better understand your opinions and suggestions on the services we provide.
(2) To update the Services or marketing: If you have consented, we may use your personal data to send you updates about our products, services, and promotional activities.
(3) To provide us with sensitive personal data: If you choose to provide us with personal data that may be considered “special” or “sensitive” in certain jurisdictions, you’re consenting to our processing of that data in accordance with this Policy.
4. Compliance with applicable laws and regulations
(1) To comply with applicable local laws/regulations.
(2) To complying with legitimate governmental requirements, such as assisting law enforcement.
(3) To gather and to provide data required by or relating to audits, inquiries or investigations by regulatory bodies;
(4) Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g., under safety law or rules issued by our professional regulator.
V.How We Share Your Personal Data
We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable laws and regulations. We do not allow our third-party partners to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with contractual obligations which ensure adequate protection.
1. Sharing with your consent or at your request
With your explicit consent or at your request, we will share your personal data within the scope of your consent or request with specific third parties designated by you.
2. Sharing with affiliates
In order to provide you with richer features and services, or to carry out our obligations and enforce our rights under our contract or this Policy, your personal data may be shared with affiliated companies of UBTECH. This includes such affiliates that process your personal data, necessary for providing our products or services to you.
3. Sharing with third-party service providers
We may disclose personal data to our service providers for the performance of certain features or to provide you with better service and a better user experience. The categories of service providers to whom we entrust personal data include service providers for:
a.Data hosting and storage;
b.Intelligent voice interaction (ASR、TTS、LLM);
c.Video call function;
d.Joint development and procurement;
e. Troubleshoot application problems；
f.Security and service delivery;
g.Customer support and customer management;
h.Other service providers (where applicable).
This policy does not apply to products or services provided by a third party. Depending on the service you use, it may incorporate third parties’ products or services, such as intelligent voice services, etc. Some of these will be provided in the form of links to third-partes's websites, and some will be accessed in the form of SDKs, APIs, etc. Your personal data may also be collected by these third parties when you use these products or services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal data which they collect from you. This Policy does not apply to other sites linked to our services.
4. Sharing with authorities
Where necessary, we will disclose the relevant personal data to:
a.Public bodies or other organizations having regulatory authorities in case of specific requirements made in accordance with the applicable law;
b.Courts and tribunals, in case of specific requirements made in accordance with the applicable law;
c.Law enforcement agencies, in case of specific requirements made in accordance with the applicable law.
5. Others
We may share your personal data with our accountants, auditors, lawyers or other professional external advisors who serve us under professional obligations of secrecy when we ask them to provide us with professional advice or when their professional service is required by applicable law.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if personal data transfer is involved, we will require the new company or organization that is about to hold your personal data to continue to be bound by this Policy. Otherwise, we will require the company or organization to re-solicit your authorization and consent.
We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated such anonymized data with third parties.
VI.How Your Personal Data Transfers Globally
We process and back up personal data through a global operating and control infrastructure. Currently, the personal data we collect about you will be stored on servers located in Chinese Mainland. Your ticking of the relevant cross-border notice option during registration and login constitutes such consent.
We may also transfer your personal data to third-party service providers and business partners. Therefore, your data may also be transmitted to other countries or jurisdictions that may not have data protection standards equivalent to those in your jurisdiction. If we need to transfer personal data outside of your jurisdiction, we will comply with applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing comprehensive security safeguards. You can find out about the safeguards in the following chapter or contacting us at ucare@ubtrobot.com.
VII. How We Store and Protect Your Personal Data
1. Retention time
We will keep your personal data only as long as is necessary for the purposes set out in this Policy and to fulfil our legal obligations. We will destroy or anonymize your personal data when we have reasonably determined that：
(1) The purpose for which personal data was collected is no longer being served by the retention of such personal data;
(2) Retention is no longer necessary for any legal or business purposes; and
(3) No other legitimate interests warrant further retention of such personal data.
In each case, there are also occasions where we may need to keep your data for longer in accordance with this Policy, our legal obligations or where it is necessary for legal claims. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.
After you have terminated your use of our Service, we will store your personal data in an aggregated and anonymised format.
2. Protection of your personal data
We use appropriate technical means and organizational measures to safeguard the personal data we collect about you. The measures we take provide you with security that matches the risk of processing your personal data. The specific measures we take include Secure Sockets Layer (SSL) encryption to ensure that your data is securely transferred from your browser to our network system.
Your personal data will be stored on a secure server and protected in a controlled facility. We classify your data by importance and sensitivity and ensure the highest level of security for your personal data. We guarantee that employees and third-party service providers who provide products and services to you by accessing the data have strict contractual confidentiality obligations, and if they fail to fulfill these obligations, they will be subject to disciplinary actions or termination of cooperation. Similarly, we have dedicated access control measures for cloud-based data storage. In summary, we regularly review our data collection, storage and processing practices, including physical security measures, to prevent any unauthorized access or use of your personal data.
We will take all practicable measures to protect your personal data. However, you should be aware that the use of the Internet is not always secure, therefore we cannot guarantee the security or integrity of any personal data when transmitted in both directions over the Internet. At the same time, your assistance will help us protect the privacy of your personal data.
a.You can protect your personal data by not disclosing your device control password or WIFI data to anyone (unless duly authorized by you). Whenever you use the CISCE Linky App or other UBTECH products, especially when downloading and connecting our products by someone else's device or public Internet terminal, please be sure to clear the relevant data after use.
b.UBTECH is not liable for any security loophole in the event of any third party's access to your personal data due to your failure to maintain the privacy of your personal data. Notwithstanding the foregoing, you must notify us immediately in the event of unauthorized use of your account by any other user on the Internet or any other security loophole.
We will promptly notify the relevant regulatory authorities about the disclosure of personal data, and in some special circumstances, notify the data owner of relevant data slope events to meet relevant applicable laws, including data protection regulations in your location.
VIII. Your Data Subject Rights
In the process of using the product, you may have the following rights according to privacy laws applicable in your country:
a. Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Policy).
b. Right of access: you can request access to your personal data held by us.
c. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
d. Right to erasure: you have the right to have your data deleted in certain circumstances. We will conduct an evaluation based on your deletion request. If the request complies with provisions of the legislation, We will take corresponding steps including technical means to process it.
e. Right to restrict processing: You can require us to restrict processing of your personal data in certain circumstances, e.g., if you contest the accuracy of the data, or the processing is unlawful according to your understanding.
f. Right to data portability: You can request a copy of certain data in a machine-readable form and/or transmit that data to a third party in certain situations.
g. Right to object: In certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of direct-marketing) you may object to that processing.
h. Rights related to automated decision-making including profiling: There are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances, your rights include the right to ensure that there is human intervention in the decision-making process.
i. Right to withdraw consent. In those cases where your consent is required for the processing of your personal data, you may at any time withdraw such consent. However, please note that if you withdraw your consent, you may not be able to continue to use related services, and/or access certain data or features. The withdrawal of your consent will not affect the lawfulness of our collection and processing before withdrawal (if the collection and processing are consent-based).
The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You can make yourself aware of the particular rights under applicable privacy laws in your country.
You can access and edit most of your personal data through our application, and if you want to exercise any of your rights listed above, you can also contact us according to Chapter XI"Contact Us". For your protection and the protection of all of our users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.
You knowledge that UBTECH may not be able to comply with your data rights request in some cases, and in these cases we will explain why. For example, we may not be able to provide a copy of your personal data where it infringes on the rights of another user. In some cases, you may have shared your personal data with a third party. We will not be able to delete this information and you need to contact the third party directly.
If you feel we have not resolved your concern, you have the right to lodge a complaint with your local privacy or data protection regulator.
Our services are primarily aimed at adults. UBTECH does not offer services directly to a child or use personal data of children for the purposes of marketing.
You may only use the Services if you are old enough to consent (by yourself and not by a parent or guardian) to share your personal data under applicable laws and regulations. If you do not know whether you are eligible, or do not understand this chapter, please do not use our Service.
We consider it the responsibility of the parent or guardian to supervise the child's use of our services. Therefore, if you are a parent or guardian and you believe that the minor has provided us with personal data, please contact us according to Chapter XI "Contact Us". If we find that we have collected personal data from children, we will try to delete the relevant data as soon as possible.
We may update this Policy from time to time to reflect our current practice and ensure compliance with applicable laws. When we post changes to this Policy, we will revise the “Last Updated” date at the top of this Policy. We recommend that you check this page from time to time to inform yourself of any changes.
If there are any material changes to this Policy, we will notify you as required by applicable law.
If you have questions or concerns about this Policy or practices of personal data protection, please contact us via:
Our Data Protection Officer Email: ucare@ubtrobot.com
Phone number: +86-400-6666-700 (Monday to Friday, 9:00 - 18:30 GMT+8)
Mailing address : 22nd Floor, Building C1, Nanshan Zhiyuan, No. 1001 Xueyuan Avenue, Nanshan District, Shenzhen, China.
We will reply to you within 30 days (or within the time limit stipulated by your local laws) . If you are not satisfied with our response, especially if our personal data processing has damaged your legal rights, you can also file a complaint or report to the data protection supervisory authority.