Privacy Policy

This Privacy Policy was originally published on March 11, 2024. This revision takes effect on: July 15, 2026. The main updates include new rules regarding default device snapshot capture and album storage. The new version replaces the corresponding content of the previous version and takes effect on the revision date.

You may use our services in a variety of ways across different devices, including Turing Care software products and services. Please carefully read and understand this Policy before using the APP, and only use our products or services after you have fully understood and agreed to it. Once you begin using Turing Care products and services, you indicate that you have fully understood and agreed to this Policy, and consent to our collection, use, storage, and sharing of your relevant information in accordance with this Policy. Through this Privacy Policy, we aim to explain how we collect, process, and use information, as well as the measures you can take to protect your own privacy rights.

This Privacy Policy sets out how Turing Vision (Shenzhen) Co., Ltd. and its affiliated companies (hereinafter referred to as "Turing Vision" or "we") collect, use, disclose, process, and protect the information you provide to us when using our products and services. If we require certain information from you to verify your identity when using Turing Care platform-connected products and services, we will use such information strictly in compliance with this Privacy Policy and/or our User Terms and Conditions.

This Privacy Policy has been formulated with full consideration of your needs. It is important that you have a comprehensive understanding of our personal data collection and usage practices and are confident that you ultimately have control over the personal information provided to Turing Vision.

In this Privacy Policy, "personal information" refers to data that can identify a specific individual, either on its own or when combined with other information accessible to Turing Vision.

By using Turing Care platform-connected products and services, you indicate that you have read, acknowledged, and accepted all terms set forth in this Privacy Policy, including any changes we may make from time to time. We are committed to protecting the privacy, confidentiality, and security of your personal information in compliance with applicable laws (including the data protection laws of your location). We also commit that all our employees and agents will fulfill these obligations.

You represent that you are an adult when you begin using this product/service. If you are a minor, you must ensure that your guardian has consented to your use of this application and agreed to all terms of service of this Agreement before use.

Our Privacy Policy includes explanations on the following:

• What information we collect.
• How we collect, process, and use information.
• How you can choose whether to provide this information, and how to access and update it.
• Information sharing and security.
• Personal information storage.
• Managing your information.
• Protection of minors' information.
• Scope and amendments of the Privacy Policy.

Information Collection

In order to provide our services to you, we will ask you to provide personal information necessary for delivering such services. If you do not provide the personal information, we may be unable to provide our products or services to you. Below are details on the types of information Turing Vision may collect and how we use such information.

• Account Registration Information — After installing Turing Care on your mobile phone, you need to register or log in to a Turing Care account on the APP in order to use it. When registering a Turing Care account, you need to provide your phone number and set an account password for registration and login. When you cancel your Turing Care account, we will stop using and delete the above information or anonymize your personal information, unless otherwise required by laws and regulations.
• Device-Related Information — Information related to your smart device, including device name, device model, device ID, and device location (e.g., bedroom).
• Location Information — When you use location-based program services or features, we may collect your geographic location information. For example: Wi-Fi access points and Bluetooth information that can provide relevant location data.
• Wi-Fi Network Information — When you use smart device pairing, device discovery, network connection, or troubleshooting features, we may collect the name (SSID) of the Wi-Fi network you are currently connected to, the Wi-Fi access point identifier (BSSID), network connection status, and IP address. This information is used to complete device pairing, discover smart devices on the local network, determine whether your phone and device are connected to the same network, and troubleshoot network connection issues.
• Information Collected via Cookies and Other Technologies — Turing Vision's websites, online services, interactive applications, email messages, and advertisements may use Cookies and other technologies such as programmatic tags and web beacons to collect and store your information.
• Log Information — When you access Turing Vision's servers, our servers automatically record certain log information. Such server log information may include: IP address, device ID information, device version number, APP version number, browser type, browser language, referring source page, operating system, date/time stamps, and clickstream data.
• Mobile Device Unique Identifiers — When you first use and launch the Turing Care product application, the mobile device unique identifier paired with the smart camera (including device serial number, device MAC address, IMEI, OAID, MEID, Android ID, IMSI, GUID, SIM card serial number) and approximate geographic location information.
• Third-Party Applications — Information such as device MAC addresses, unique device identifiers, and mobile app installation lists required by third-party applications. We will only share necessary user data with third parties for lawful, legitimate, necessary, specific, and clearly defined purposes, and only with your explicit authorization and consent, in order to provide you with relevant services.
• When you sync Turing Care product data, your data will be transmitted to your mobile device via servers.
• The push notification feature of the Turing Care APP will collect your device's MAC address in silent/background states to ensure the normal functioning of message notification services.
• To implement junk cleaning and performance acceleration features, Turing Care will request your storage permission to access external storage information (SD card data) to check phone CPU, memory, and SD card status.
• When your phone plays videos or other content, to adapt to your device's state, Turing Care will invoke the device's gravity and acceleration sensor information to identify your device's landscape/portrait orientation.
• When you share or receive shared information, the APP needs to access your clipboard locally to read sharing codes and links for purposes such as navigation, sharing, and other linked features and services.

System Permission Requests

• System permissions such as Camera, Photos (Storage), and Microphone are not enabled by default. We will only request such permissions and obtain the corresponding information (if applicable) through pop-up windows when you trigger the relevant business functions. Please rest assured that the permissions we request are limited to what is necessary for specific functions, and you may withdraw your authorization for system permissions at any time. If you refuse or withdraw authorization for system permissions, you will be unable to use the corresponding functions, but this will not affect your normal use of other functions of the product and/or service.
• For system permission request details, please see the System Permission Description below. Alternatively, you can access it through settings: Android devices via Home navigation path: "My - User Guide - System Permissions", and iOS devices via system "Settings - Turing Care APP" for system permission configuration.

Supplementary Note: The images required for device automatic snapshot capture and AI visual detection are all collected by hardware cameras and do not require invoking the user's mobile phone camera or photo album permissions.

Information Processing and Use

Turing Vision will strictly process and use your information in accordance with the content set forth in this Privacy Policy and its updates. Your information will only be used for the purposes confirmed at the time of collection and to which you have consented. For any other purposes beyond this, we will obtain your prior consent. We may use your personal information for the following purposes: The information we collect may be used to provide you with Turing Vision's products and services, process your orders, or fulfill contracts between you and Turing Vision, to ensure the functionality and security of our products and services, verify your identity, and prevent and investigate fraud or other improper use. The information we collect may be used for our product and service development, although generally we use only aggregated and statistical information for this purpose. The information we collect may be used to communicate with you, for example, to notify you at the earliest opportunity of updates or releases of Turing Vision products or services.

Below are more details on how we use your information (which may include personal information):

• Creating Your Turing Care Account: Personal information collected when creating a Turing Care account via a mobile device is used to establish the user's personal Turing Care account and profile page.
• Providing Turing Care Login and Connection Services: Collected information (device-related information, including device number, MAC address, device category, system and performance information, and location information such as mobile country code, mobile network code, and location area code) is used to activate Turing Care services for user authentication and service activation.
• Binding Devices and Syncing Data: To sync data, allow devices to receive commands, and upload data to servers (applicable only to certain functions/services), we collect account information, device-related information, and network information.
• Providing Location-Based Services: When using Turing Care, we may use location information to provide you with the correct version of the service and accurate location information for the best possible user experience, such as Wi-Fi information. You may disable this feature at any time through device settings or by discontinuing use of this application.
• Providing Push Notification Services: Devices send notifications based on trigger events, for example, pushing notifications to your phone when the device detects crying. To do this, we collect your push notification settings, device MAC address, and device serial number. You may disable push notifications in settings. To ensure that the application can normally receive broadcast messages pushed by the client when closed or running in the background, this application must use the (auto-start) capability, which will involve waking the application through system broadcasts at a certain frequency, as this is necessary for implementing the functions and services.

Supplementary Visual Data Usage Agreement

1. Original images from device default snapshots: When no AI detection is enabled, they are only used to generate event messages and store in the user's cloud album; no AI analysis is performed and they are not used for algorithm training. After enabling any of the face-covering/bed-leaving/awakening detection functions, images may additionally be used for AI anomaly alert recognition. 2. Only anonymous images for which you have separately checked and authorized in Privacy Settings may be used for AI algorithm training. Without your renewed explicit consent, images will not be used for advertising, user profiling, or other unrelated purposes.

How Users Choose Whether to Provide Information

Everyone has different concerns regarding privacy. Based on this, we will clearly indicate how we collect information so that you may choose how to provide it.

• You may modify your device's location settings from the device settings, for example: changing or disabling location methods or modifying the accuracy of your location information, thereby changing the location information provided to Turing Care.
• You may modify your browser settings as needed to reject or accept Cookie storage, delete them from your storage device at any time, or be notified when Cookies are written.

Visual Screen Control: In the device settings, you can turn off "Auto Snapshot Save to Album" with one click; once turned off, no images will be captured or uploaded throughout the entire process. Turning off the three AI detection functions only stops image AI analysis without affecting the existing snapshot logic for albums and messages. You may cancel algorithm training authorization by going to Privacy Settings.

Accessing and Updating Information

By logging into your account, you can view and update your information. You may also delete some information or request that we delete your personal account, unless we are required to retain such information by legal requirements. Whenever you use our services, we strive to enable you to view your information. If this information is incorrect, we will make efforts through various means to allow you to quickly update or delete it (unless we are required to retain such information by legal requirements). When updating your personal information, we may ask you to verify your identity before processing your request.

We may refuse requests that are unreasonably repetitive, pose a risk to others' privacy, or are highly impractical. We must also refuse your request if it does not comply with the requirements of the competent authorities.

We provide free access to viewing and modifying information as long as it does not require an excessive burden. We strive to maintain services well to protect information from accidental or malicious destruction. Therefore, when you delete information from our services, we may not immediately delete residual copies from active servers, nor may we delete corresponding information from backup systems.

Information Sharing

Except for the limited sharing set forth in this Privacy Policy, we will keep your personal information strictly confidential and will not share it with third parties. You hereby authorize that we may provide or transfer your information to third parties without obtaining your consent again under the following circumstances:

• Disclosing your personal data to third-party service providers who provide certain business-related services to us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support services, email delivery services, and other similar services, to enable them to provide services to us.
• When required by law, judicial or administrative investigations, litigation, enforcement, or other mandatory legal provisions or competent authority requirements. When providing information to our affiliated companies or other trusted businesses or individuals to provide the above services on our behalf. We require the above parties to agree to process such information in accordance with legal regulations, our policies, this Privacy Policy, and any other applicable confidentiality and security measures.
• If we engage in financing, restructuring, merger, sale, or similar transaction processes, we may disclose your personal data to affiliated companies or other third parties; provided that before transferring all information we have collected in accordance with such transaction process, we will continue to protect its security in accordance with the current Privacy Policy and notify all affected users.
• Disclosing your personal data to subsidiaries or affiliated companies under the company for regular business activities.
• We may reasonably share aggregated information with the public and partners based on operational needs or to protect users, such as to demonstrate overall usage trends of our products or services.
• To ensure the implementation of Turing Care-related functions and the secure and stable operation of the application, we may integrate third-party Software Development Kits (SDKs) for relevant purposes. We will conduct strict security monitoring of the SDKs through which partners obtain information to protect data security. The third-party SDKs we integrate are listed in the directory below, and we recommend that you carefully read and understand the third parties' privacy policies. The current third-party SDK information integrated in Turing Care is as follows:

Supplementary: Original portrait images captured by the device will not be provided to any third-party SDKs or partners. If training data needs to be delivered to algorithm partners, only fully anonymized datasets that cannot identify natural persons will be provided, and partners must sign confidentiality agreements.

Personal Information Storage

Storage Location

In accordance with laws and regulations, we store your personal information collected and generated during operations within the territory of the People's Republic of China. We will not transfer such information overseas, except in the following circumstances: (1) where expressly provided by applicable laws and regulations; (2) where we separately obtain your explicit authorization and consent; (3) where the products and/or services you use involve cross-border scenarios and you actively provide personal information overseas.

If we provide products or services through globally distributed resources and servers, this means that, after obtaining your authorized consent, your personal information may be transferred to jurisdictions outside the country/region where you use the products or services, or be subject to access from such jurisdictions. Such jurisdictions may have different data protection laws or may not have established relevant laws. In such cases, we will ensure that your personal information receives protection equivalent to that within the People's Republic of China and that your personal information security is legally protected in accordance with this Policy.

Storage Period

We will retain your personal information only for the period necessary to achieve the purposes described in this Policy. For example, when you use the corresponding functions after registering and logging in with your phone number, we will continuously retain your phone number during the period you provide and use such functions in order to provide you with the functions normally.

Retention periods for fulfilling other statutory obligations, such as those under the Regulations on the Protection of Information Network Dissemination Rights, require us to retain relevant network logs for monitoring network operation status and network security incidents for no less than six months. Under the E-Commerce Law, we are required to record and retain information on goods and services published on the platform, and transaction information shall be retained for no less than three years from the date of transaction completion.

Visual Image Specifics: Original device snapshot images are stored for a validity period of 30 calendar days and are automatically deleted upon expiration. Anonymized algorithm training data has no fixed destruction deadline.

After the retention period has expired, we will delete your personal information or anonymize it in accordance with applicable legal requirements. When you proactively cancel your account, we will process data in accordance with legal and regulatory requirements.

Information Security

We strive to protect Turing Vision users by ensuring that the information we hold is not viewed, accessed, tampered with, disclosed, or destroyed without authorization. To this end, we have specifically adopted the following measures:

We use SSL to encrypt many of our services. We review our information collection, storage, and processing practices (including physical security measures) to prevent unauthorized access or tampering and malicious attacks on various systems. We only allow Turing Vision employees and personnel of authorized service processing companies who need to know such information to process it to view personal information, and they are required to fulfill strict contractual confidentiality obligations. If they fail to fulfill these obligations, they may be held legally liable or have their relationship with Turing Vision terminated.

The security of your information is very important to us. Therefore, we will continuously strive to safeguard your information security and implement security measures such as full encryption during storage and transmission to prevent your information from being viewed, used, or disclosed without authorization. At the same time, no one other than the user themselves has the right to view certain encrypted data content.

Managing Your Information

While using the APP, you may access and manage your personal information through the following methods:

(I) Accessing and Correcting Your Personal Information

(1) You have the right to access, correct, and export your personal information at any time. If you wish to access or edit your personal profile information in your account, or correct your password, you can do so by logging into the APP and going to [My - Profile Settings] for viewing and correction. (2) For access or correction of other personal information generated during your use of our products or services, please contact us at any time by logging into the APP and going to [My - Contact Customer Service/User Feedback]. We will respond to your request within fifteen days in the manner set forth in this Policy.

(II) Deleting Personal Information

You may directly clear or delete information on our product and/or service pages, including non-mandatory registration information such as profile photos, using the same access paths as described above for accessing or correcting information.

You may request deletion of other personal information under the following circumstances: (1) If our processing of personal information violates laws and regulations; (2) If we collect or use your personal information without your consent; (3) If our processing of personal information violates our agreement with you; (4) If you have canceled your Turing Care account; (5) If we terminate services and operations.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it promptly, unless otherwise provided by laws and regulations or unless such entities have obtained your independent authorization. If, due to applicable legal and security technology limitations, we are unable to immediately delete the corresponding information from backup systems after you or we assist you in deleting it, we will securely store your personal information and restrict any further processing until the backup can be cleared or anonymized.

Image Data Supplementary: You may contact customer service to request early deletion of stored snapshot images on your device. After account cancellation, unexpired original snapshot images will be deleted immediately, while anonymized training data will be retained in compliance with regulations.

(III) Account Cancellation

You may apply for account cancellation. After you cancel your account, we will stop providing you with products or services and, at your request and unless otherwise provided by laws and regulations, we will delete or anonymize your personal information. If you need to cancel your Turing Care account, you can do so through the APP client at [My - Profile - Cancel Account], or contact customer service to request cancellation of your account. We will provide account cancellation services within fifteen days after verifying your identity and following the relevant rules and procedures for account cancellation.

(IV) Changing/Withdrawing Your Consent or Authorization

In the APP, you may withdraw your consent and authorization through the following methods: (1) You can go to your phone's local "Settings -> Permission Management -> Turing Care" to access the permission management interface for Turing Care and withdraw your authorization and consent for the Turing Care APP; (2) Turn off relevant functions or unbind smart hardware devices through the functional descriptions in "How We Collect, Process, and Use Information" in this Policy. Turning off such functions constitutes withdrawal of the corresponding authorization.

Visual-Specific Withdrawal: ① Turn off "Auto Snapshot Save to Album" on the device page = terminate image capture; ② Turn off face-covering/bed-leaving/awakening detection switches = stop image AI analysis; ③ Uncheck training authorization in Privacy Settings = no additional images used for algorithm training.

Please understand that each business function requires certain basic personal information to be completed. After you withdraw your consent and authorization, we will be unable to continue providing the services corresponding to the withdrawn consent or authorization and will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the personal information processing previously carried out based on your authorization.

(V) Obtaining Copies of Personal Information

You have the right to obtain copies of your personal information. If you need to obtain copies of the personal information we have collected about you, you may contact us at any time. To the extent permitted by applicable laws and technically feasible, we will provide you with copies of your personal information upon your request.

(VI) Restraining Automated Decision-Making by Information Systems

We may make decisions based solely on non-manual automated decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us. You may contact us using the contact information published in this Policy, and we will respond within fifteen days.

(VII) Responding to Your Requests

If you are unable to access, correct, or delete your personal information through the above methods, or if you need to access, correct, or delete other personal information generated during your use of our products or services, or if you believe that Turing Vision has violated any laws, regulations, or agreements with you regarding the collection or use of personal information, please contact us through the contact information published in this Policy. For security purposes, we may require you to submit a written request or otherwise prove your identity. We will respond to your request within fifteen days after receiving your feedback and verifying your identity. For reasonable requests, we generally do not charge fees, but for repeated or excessive requests, we may charge a cost-based fee as appropriate. We may refuse requests that are unreasonably repetitive, require excessive technical means (e.g., developing new systems or fundamentally changing current practices), pose a risk to the legitimate rights and interests of others, or are highly impractical.

Under the following circumstances, in accordance with laws and regulations, we will be unable to respond to your request: (1) Those related to national security or national defense security; (2) Those related to public safety, public health, or major public interests; (3) Those related to criminal investigation, prosecution, and trial; (4) Where there is sufficient evidence that you have subjective malice or are abusing your rights; (5) Where responding to your request would cause serious harm to the legitimate rights and interests of you or other individuals or organizations.

Protection of Minors' Personal Information

Turing Care's products and services are primarily intended for adults. We do not use age identification as a prerequisite when providing products or services to users, but the nature of our products and/or services requires that you be an adult with full civil capacity. If you are a minor, you must ask your parents or other guardians to carefully read this Privacy Policy and use our services or provide information to us only with the consent and under the supervision of your parents or other guardians.

If you are a child under the age of 14, before using our products and services, you and your parents or other guardians must also ensure that you use our products and services under the guidance of your guardian after obtaining parental or guardian consent.

We attach importance to the protection of minors' personal information. Where minors' personal information is collected with the consent of parents or legal guardians, we protect minors' personal information in accordance with relevant national laws and regulations, and will only collect, use, or publicly disclose minors' personal information to the extent permitted by law, with the explicit consent of guardians, or where necessary to protect your rights and interests.

Supplementary: For infants and young children under 14 years of age being cared for, automatic device visual snapshots require guardian authorization. Guardians may at any time turn off automatic snapshots, disable AI detection, revoke training authorization, and request deletion of the baby's historical snapshot images.

If you are the guardian of a minor and have questions regarding the minor under your guardianship's use of our services or personal information, please contact us promptly. We will protect the confidentiality and security of minor users' information in accordance with relevant national laws and regulations and the provisions of this Policy. If we discover that we have collected a child's personal information without first obtaining verifiable guardian consent, we will endeavor to delete it as soon as possible.

Scope of the Privacy Policy

Our Privacy Policy does not apply to third-party products and/or services. Turing Care products and services may contain third-party products and services. When you use third-party products or accept third-party services, they may obtain your information. Therefore, we remind you to carefully read the third-party privacy policies.

Additionally, this Privacy Policy does not apply to data collection activities on external websites after you click on links.

Amendments to This Privacy Policy

This Privacy Policy may be subject to adjustments. Without your explicit consent, we will not diminish your rights under this Privacy Policy, unless we notify you via the email address you provided or publish a website announcement. The new content regarding default device snapshots and album storage added this time constitutes an important revision, and subsequent policy changes will be disclosed in accordance with the aforementioned rules.

Specific Product and Service Practices

The following describes specific privacy practices for certain Turing Care account products and services you may use.

When you use the products, services, and websites of Turing Care account services (collectively, "Turing Care Account Services"), the terms of this Privacy Policy will also apply.

Turing Vision Company is the provider of Turing Care Account Services. Once you log into a Turing Care account, we will collect your phone number, mobile subscriber identification information, and mobile device unique identifier.

You further agree that, for the purpose of providing you with this service and related functions, Turing Vision Company may collect, use, transmit, process, maintain, and utilize information related to your account, as well as information related to any device or computer registered under the account. When you use this service, the information collected by Turing Vision Company may also include technical, statistical, or diagnostic information related to or resulting from your use that Turing Vision Company may use to support, improve, and enhance Turing Vision Company's products and services.

You may revoke this consent at any time by simply not using the Turing Care account function and deactivating the Turing Care account function on your devices and computers.