As a company devoted to big data and artificial intelligence technology, we, Spacewalker Technology Hong Kong Co.,Limited (hereinafter referred to as “we”) are fully aware of the importance of user privacy protection and have been committed to protecting the privacy of our customers. We hereby remind you that during your participation in the in-home usage test plan (“Test Plan”), we may need to collect the personal data from you in order to make sure the information you submit meets the basic requirements of the test and better understand how the current product may serve our customers. All data collected is necessary for the product test and we assure you that these data will not be used for any purpose other than those notified to you in this document.

In order to protect your right to know, in this statement, we will fully disclose the information we require during the test, including but not limited to the type of the information, the purpose of the information and our protection of your rights and interests to help you better understand our use of the data. In particular, please pay extra attention to the clauses in bold.

If you have any questions or concerns towards our test plan or privacy policy, please contact us anytime via privacy@mova-tech.com. We will reply in a timely manner.

1. In-Home Usage Test Plan

There are three phases in the test, which includes user recruitment, assessment and communication, and in-home test.

In the user recruitment phase, we will explain how the test works and what data the participants need to submit (please refer to the table below for more information about data collection). If you are willing to participate in the test, apply by submitting relevant information to us in the application page. We regard the submission of your application as the consent to join our test plan and keep contact in the product test.
In the assessment and communication phase, after receiving your information submitted, we will assess it according to the test requirements of the specific product. If you pass our assessment, we will get in touch with you according to the contact information you provided during the user recruitment phase and communicate with you in detail on the process and arrangement of the subsequent in-home test phase. The participation of the in-home usage test is fully voluntary. If you have been successfully enrolled and would like to take the test, you need to provide some personal data to us (Related data types are listed in the table below). Such personal data are necessary to implement the follow-up test plan. We would send the sample product to you and invite you to test the product on your own based on our instructions.

In the in-home test phase, we may collect some product operation information provided by you (please refer to the table below for more information about the data collection). The sample product will be given as a gift to you once the test is finished.

2. Types of your personal data we may collect

During the process of user recruitment, review communication and in-home test, we may need to collect some data from you accordingly:

Phase of test	Types of data collected		Purpose/scenario of data use
User recruitment phase	Personal date	Name, email address, country , gender, age, occupation, oral health status.	The data will be used to contact you upon successful enrollment in the test program and to assess whether you meet the eligibility criteria for participation.
	Non-personal data	Usage and purchase intention of toothbrushes or electric toothbrushes, oral hygiene habits, storage environment of toothbrushes or electric toothbrushes, pet oral care needs,user identity attributes, participation in similar product testing	The data will be used to determine whether you meet our testing requirements
Assessment and communication phase	Phone number, address		The data will be used to send the product and equipment  used  for the test to you if you pass  the assessment
In-home test phase	Information and suggestions during the operation of the equipment you feedback		The data will be used to test the functional  effectiveness   of  the new  product  and  find  technical deficiencies and make improvements

We promise that these data will only be used for the purpose of product test. We will not use the data to identify any person or for any other purpose without your consent.

3. How we store, protect, entrust, share, transfer and disclose your personal information and data

The data collected during the product test will be stored in China where our research and development department is located.We will strictly follow the privacy policy stated below to protect your information.

(1) Where we store your personal data. The personal information and product working data we collect will be stored in our server in China. In the case where we need to transfer data to a foreign agency for business needs or legal requirements, we will proceed by strictly complying with laws, administrative regulations, the provisions of relevant regulatory authorities and require the relevant foreign agency to keep the personal data obtained safe by signing confidential agreements, conducting inspections.

(2) Data security and policy. We promise to reach the level of data security required by law. We are committed to using various security technologies and supporting management systems to prevent your data from being leaked, damaged or lost. Our Personal Data Protection Department and the Internal Data Usage Policy work to minimize the access of personal data from relevant staff and strictly scrutinize the application of data access.

(3) Handling of personal data security incidents. Due to factors beyond our control such as the limitation of technology and the possibility of being attacked by hackers, the possibility of personal data security incident may not be completely avoided. If such incident happens, we will promptly inform you about the incident and its potential impact, the disposal measures we have taken or will take, our suggestions for personal protection to reduce further risk in accordance with the requirements of laws and regulations. We will inform you via email or phone call in a timely manner about the incident. If it is too complex to inform individually, we will issue public announcement in a reasonable and effective way. We will also report the data breach and our handlings of the incident to authorities and regulators.

In order to keep the test sustainable and efficient, and to establish a good communication with the test participators, we established a user database for the test plan. If you agree to join this test, we will store the data you submit for three months. After the expiration of the aforementioned storage period, we will delete all your data collected during the recruitment process.

Once you join the test and are selected to take the in-home usage test, relevant data collected will be stored for the needs of product development such as improving technologies and functionalities. After the test, we will store the data collected for 6 months. After the expiration of the aforementioned storage period, we will delete all your data collected.

4.How we protect your related rights of personal data

If you would like to visit, modify or delete the information submitted, please contact us via privacy@mova-tech.com.

We fully respect your voluntary right to participate in the program.If you change your mind after you are enrolled, you can withdraw your consent to our processing of your personal data at any time through the above methods, or opt out of our user testing program. Once we receive your request, we’ll contact and confirm it is your personal wish and delete all data you provided during the test.

We’ve been consistent about the equal treatment of all types of data collected from users. For items not covered in this document, we will strictly follow the Mova Privacy Policy to process and protect your personal data.

The disagreement to this document will remove you from the test plan program; however,it will not impact your usage of our robot product.