BRAINUP's PRIVACY POLICY

DEFINITIONS

Capitalized terms used but not defined elsewhere in the Policy will have the following definitions:

"Activity Data" means data such as progress, trends, achievements over time, and session start and end times collected by us based on your activity.

"Location Data" means your location features when using our android mobile applications to enable use of Bluetooth functionality.

"Meditation Data" means Sensor Data, Processed Data and Activity Data.

"Personal Device" means computers, smartphones, connected TVs and other web-connected devices you use that integrate with our Products.

"Preference Data" means data you provide regarding your preferences, such as session reminders, and any other data you choose to input; for example, notes you record in the application after a meditation session.

"Processed Data" means data such as EGG rate, and spirit rate which is generated by us by processing Sensor Data.

"Purchase Information" means your name, email address, shipping address, billing address, phone number, account information, other information you share during the purchasing process, details of the product or subscription purchased, the date and time of the order or subscription, the quantity and price of the order or subscription, whether payment was made, method of payment, purchase or subscription history, and whether you re-ordered or renewed a subscription.

"Sensor Data" means data such as brainwave patterns (through electroencephalogram or EEG), Mental state data, UV data, battery status data, temperature data, and pressure data collected through the sensors on the KANG Sleep device.

"Transmission Data" means your log data such as the date and time of syncing of your Personal Device with our servers, duration of the time spent using our applications on your Personal Device, and the Internet Protocol (IP) address of your Personal Device.

INFORMATION WE COLLECT AND HOW WE USE IT

When You Use or Access our Products

Creating a KANG Sleep Account

If you are under 16 you will not be allowed to set up an account with us. When you set up an account with us, you will need to provide us with information such as your login credentials (e.g. Your email address, name, and/or password). Instead of providing us with your login credentials, you could also use a third-party service such as Google Sign-in to create an account with us. When doing so, you authorize us to access certain account information (consistent with your privacy settings on the third-party service), such as your name, email address and age. We use the foregoing information for the purpose of creating and accessing your account.

KANG Sleep Mobile Application

The KANG Sleep mobile application in conjunction with the KANG Sleep device is designed to assist users with their meditation practice.

Creating an account

To use our KANG Sleep mobile application, you will be asked to download our mobile application and create an account.

Additional information we will ask you for when you are creating your KANG Sleep mobile application account is your geographic region and/or country, whether you are right or left handed, your gender, and year of birth. Factors like age, gender and handedness can impact your brain and help us with our research and development of the application. We use this information to improve and customize your user experience.

When using the KANG Sleep mobile application

When you use the KANG Sleep application with the KANG Sleep device, we record, process and store your Activity Data, Sensor Data, Preference Data, Processed Data and Transmission Data. We use the data referenced in the preceding sentence to provide you with real time feedback during a meditation session, reports after meditation sessions, customer support, brain/body scientific research, technical troubleshooting, performance management and product enhancement. When you use an Android Personal Device to access the KANG Sleep application, we also need to access your Location Data during that use in order to enable Bluetooth connectivity; however, we do not store this Location Data.

KANG Sleep In-Application Third Party Research Program: While using the KANG Sleep mobile application, you may have the option of participating in our voluntary in-application research program involving third parties. When you choose to participate in our third-party research program, you are consenting to the sharing of your Sleep Data on a de-identified basis with third parties involved in research related to improving the scientific understanding of the brain/body or to improving products and/or delivering better experiences and services. You can choose to withdraw your consent to us sharing your information in the context of these voluntary research programs at any time through the settings of the KANG Sleep mobile application you are using. Should you withdraw your consent, we will not share your Sleep Data in any new third-party research studies.

Websites

We use www.naolubrain.com and www.naolubrainup.com to provide information and market and/or sell certain Products.

When using our Websites

We collect information about how you use our websites, such as the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our website, and what posts, videos and other content you view on our websites.

We collect information from and about the Personal Devices you use to access our websites, and we combine this information across your different Personal Devices. For example, we use the information collected about your use of our websites on one of your Personal Devices, such as your smartphone, to better personalize the content or features you see when you use our websites on another Personal Device, such as your laptop or tablet, or to measure whether you took an action in response to an advertisement we showed you on your smartphone on a different device. Our access to and use of information from Personal Devices and our use of cookies and tracking technologies is further described below under “cookies, tracking technologies and additional information about our products”.

We use technologies to deliver products and services, to make it easier for you to use our websites, enable you to move around the website and use their features, such as accessing secure areas, and store information so that we respond faster. We may use these technologies to collect information about how you use the website, for example which pages you visit most often and if you receive error messages from certain pages.

We may use technologies to allow us to remember choices you make (such as your user name, language or the region you’re in) and tailor the website to provide enhanced features and content for you. We may use technologies to deliver advertising that is relevant to your interests. These technologies can remember that your Personal Device has visited a site or service, and may also be able to track your Personal Device’s browsing activity on other sites or services other than www.naolubrain.com or www.naolubrainup.com.

Information collected from Personal Devices may be shared with organizations outside of our company, such as advertisers and/or advertising platforms to deliver the advertising, and to help measure the effectiveness of an advertising campaign

We may also use information collected through these technologies to understand, improve, and research products and services.

WHEN YOU MAKE PURCHASES FROM US

While payments made through or for our Products are processed through a third-party payment processor, we collect and use information about the purchase or transaction. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping and contact details. We use this information to the extent necessary to provide you with the Products you request in accordance with our terms, including to administer, manage, and fulfill the purchases or subscriptions you make and for inventory management and our other legitimate business interests.

WHEN YOU CONTACT US

When you contact us with a comment, question, or complaints via telephone call, email, or other means, we collect information like the identity of the caller or sender of email or other communication, the date and time of the call or message, and the subject and resolution of the issue. Your customer service telephone calls, emails, and other communications with us may be recorded, logged, and/or monitored for quality assurance, and/or product and service enhancement purposes such as to assist in addressing your inquiries, troubleshooting, training, and analytics to identify trends and make improvements to our products. We will do so to the extent necessary to respond to and communicate with you about your comment, question, or complaint and in improving our products and services.

PUSH SERVICE AND MARKETING

We may offer you the ability to sign-up to receive marketing and promotional communications, including news, product updates, and offers from us. If you sign-up, we collect certain personal information (such as first and last name and email address) which we use to send you such communications. You can unsubscribe from receiving promotional emails from us at any time by simply clicking the “unsubscribe” link provided at the bottom of such emails or by contacting us via our contact information below or the mailing address provided below. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your account or transactions with us.

Notifications may be se nt out with your consent via an in-app announcement, a push notification, or email to encourage, motivate, teach, or otherwise engage you with our Products. These may be turned off in the settings section of our apps.

REFERRAL

The referral features on the Products may permit you to send an email to other individuals that might be interested in the Products. This feature requires you to submit your name and email address, as well as the name and email address of the recipient. We do not use the names or email addresses submitted in these circumstances for any other purpose without the consent of you or the email recipient to do so. Please ensure that you only submit email addresses of individuals with whom you have a personal or family relationship and who would want to receive the message. Our referral features may also allow you to post or share an update with your network through social media platforms.

CONTESTS AND GIVEAWAYS

BrainUp may offer you opportunities to participate in contests, giveaways, and other promotions. We may collect your name, address, email address, and other information that you provide to us. This information is used to the extent necessary to administer your participation in the contest, giveaway, or other promotion. Any personal information you submit in connection with these activities will be treated in accordance with this Privacy Policy and any additional terms set out in the rules for such offers.

SURVEYS

BrainUp may also ask you to participate in surveys that help us understand our customers and the use of our Products. The information obtained through our surveys is used to help us enhance our product and service offerings. Any personal information you submit in connection with these activities will be treated in accordance with this Privacy Policy and any additional terms associated with such surveys.

SOCIAL TOOLS

Within our applications, we may provide you with social tools that allow you to share personal information with others. For example, in the KANG Sleep app, you can share data from a Guide to sleep session on Facebook or Twitter. When you interact with others through these tools, you may be publicly displaying your personal information. Please ensure you take appropriate measures to protect your personal information.

INFORMATION THAT WE SHARE

We will not disclose, trade, rent, sell, or otherwise share personal information, without consent, except as otherwise set out herein, in any special consent you have provided, or as permitted or required by law.

VOLUNTARY PRODUCT RESEARCH AND TESTING

From time-to-time you may choose to participate in voluntary product research and testing and share with us certain personal information such as your name and email address. Unless you expressly agree to the contrary, we will not use your personally identifiable information shared in this context for any purpose other than to administer the research and/or study.

LEGAL AND OTHER REQUIREMENTS

We and our Chinese, US, or other service providers may provide personal information in response to a search warrant or other legally valid inquiry or order (which may include lawful access by China, US, or other foreign governmental authorities, courts, or law enforcement agencies), or to other organizations in the case of investigating a breach of an agreement or contravention of law, or detecting, suppressing, or preventing fraud, or as otherwise required or permitted by applicable Canadian, US, or other law. We may also disclose personal information where necessary for the establishment, exercise, or defense of legal claims and to investigate or prevent an actual or suspected loss or harm to persons or property.

BUSINESS TRANSACTIONS

We may transfer personal information as an asset in connection with a proposed or completed merger or sale (including transfers made as part of insolvency or bankruptcy proceeding) involving all or part of our group of companies or as part of a corporate reorganization, financing, or other change in corporate control.

COOKIES, TRACKING TECHNOLOGIES AND ADDITIONAL INFORMATION ABOUT OUR PRODUCTS

When you use our Products, we collect certain information by automated means, such as through server log files, cookies (text files sent to and stored on your Personal Device when you access our websites), web beacons (also known as clear gifs and pixel tags, which may be used to transmit information back to our Products), Personal Device ID (if you use one of our mobile applications) and embedded scripts (programming code that is designed to collect information about your interactions with the Products, such as the links or features you click on or select, and which is active only when you are using the Products) (collectively, the foregoing are referred to as “Tracking Technologies”).

The information we collect in this manner may include details about the Personal Device used to access the Products (such as browser type, device type, operating system and version, and IP address), referring urls and information on actions taken or interactions with our Products.

We use the following Tracking Technologies in connection with the Products:

Necessary Tracking Technologies: These are Tracking Technologies that are required for the operation of our Products, to enhance your user experience when you use our Products, and to embed third-party features. They include, for example, Tracking Technologies that enable you to log into your account or access the features or web pages you select, remember your preferences (for example, your choice of language), pre-fill form fields you have previously completed, and integrate useful services provided by third party providers into our Products, such as social media features.

Analytics Tracking Technologies: We use third party web and mobile analytics services such as Google Analytics and Firebase Analytics, to help us analyze how visitors use the Products. We may permit these third parties to operate directly on or through our Products, using their own Tracking Technologies, and to collect information about you on our behalf. These Tracking Technologies allow us to measure and analyze behaviors and usage patterns of our customers, such as which pages or features are visited or used most often, for how long, and whether an error message is received by a customer. These analytics services may also provide us with other data they collect outside of our applications in an aggregated, de-identified form. We use this information to help us with Product performance monitoring and enhancement, and technical troubleshooting.

Interest-Based Advertising Tracking Technologies: When you visit our websites or apps, we may allow some third parties to (such as advertising networks and data analytics companies) collect information about your online activities over time and across different websites and apps (such as websites and apps you visit and response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant to you, both on and off our websites. In some instances, we may also combine information we receive about you from third parties with information we collect through our websites. To opt-out of interest-based advertising, please see “Opting-out of Interest-Based Advertising” below.

You may set your web browser or Personal Device settings to notify you when you receive a cookie or to not accept certain Tracking Technologies. In our apps, we provide the ability to opt-out of Tracking Technologies, typically found in the settings. However, if you decide not to accept Tracking Technologies in connection with our Products, you may not be able to take advantage of all the features of our Products.

To find out more about cookies, including how to see what cookies have been set, and how to adjust your browser settings to block cookies, visit www.aboutcookies.org or www.allaboutcookies.org. Your browser settings may also allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.

HOW DOES BRAINUP KEEP YOUR INFORMATION SAFE?

We take data privacy seriously and have implemented physical, technical, and administrative safeguards designed to appropriately protect the security and privacy of your personal information against loss, theft, and unauthorized access, copying, use, disclosure, or modification.

We limit access to your personal information to employees and authorized service providers with a need to know to fulfill their designated functions.

Data Sharing and Disclosure

In order to provide you with one-click sharing service, our App has integrated Umeng+ U-Share SDK , which will collect your device identifiable information (such as IMEI/android ID/IDFA, etc.) and public information of social account in order to share information with social account. For your information security, we have made data security confidentiality agreements with Umeng+, who will strictly abide by our data privacy and security requirements. We will not share your personal identifiable information unless authorized by you. For more information, please log in https://www.umeng.com/policy to learn privacy policy of Umeng+.

BRAINUP's POLICIES FOR CHILDREN

Our Products are only directed to persons of the age of 16 or over. We do not knowingly collect any personal information from children under 16. If we become aware that we have unknowingly collected personal information from a child under the age of 16, we will make commercially reasonable efforts to delete such personal information from our records. If you are concerned and are aware of a user under the age of 16 using our Products, please contact us by our contact information below.

LANGUAGE

If this Privacy Policy is translated in a language other than English, to the extent of any conflict between the English version and the translated version, the English version will prevail.

CONTACTING US

If you have any questions, comments, or concerns about this Privacy Policy or about how we or our service providers treat your personal information, or if you would like to exercise your choices and rights in relation to your personal information, please contact us using the following contact information:

Beijing BrainUp Technology Co., Ltd. (“BrainUp”)

Attn: Data Privacy Officer

Block B, Dongsheng Building,

Haidian District, Beijing, China

Email: privacy@naolubrain.com

Hardware Warnings

(a) Do not dispose of KANG Sleep into fire or hot oven, or mechanically crush or cut the KANG Sleep2 or the battery contained within as this may result in an explosion.

(b) Do not expose the KANG Sleep to an extremely high temperature environment as this may result in an explosion or the leaking of flammable liquid or gas.

(c) Do not expose the KANG Sleep to extremely low air pressure as that may result in an explosion or the leakage of flammable liquid or gas.