Privacy Policy

Thank you for choosing EELUCK! The protection of personal data is important to us. We process personal data only in accordance with the applicable data protection requirements, including the EU General Data Protection Regulation (“GDPR”). In this Data Protection Information, you will find all information about the processing of your personal data in connection with your use of our websites, EELUCK smart watches, and EELUCK smartwatch’s app. Furthermore, you will find information on your data protection rights.

How Do We Process Your Personal Data?

I. When You Visit Our Website

When you visit our website, we process your personal data in order to provide you with the contents of our website, to safeguard the security of our IT infrastructure, and to send you our newsletter if you have signed up for it. We also use third-party plug-ins on our website.

1. Provision of Content

Purpose: To provide you with the requested content of the website.
Data Processed: HTTP Data.
Legal Basis: Our legitimate interest (Art. 6(1)(1)(f) GDPR) in the provision of the content.
Recipients Category: Hosting Provider.

2. Security of the IT Infrastructure

Purpose: To ensure the security of the IT infrastructure, detect, eliminate and document faults (e.g. DDoS attacks).
Data Processed: HTTP Data.
Legal Basis: Our legitimate interest (Art. 6(1)(1)(f) DS-GVO).
Recipients Category: Hosting Provider.

3. Use of Third-Party Plug-ins

Note: Plug-ins are enabled only once you click on the activation button. If you enable a plug-in, the provider may receive personal data and use cookies under their own responsibility.
Plug-ins Used:
- YouTube Player (provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
- Map Downloads (provided by AMap Foundation, Block B, Wangjing Building, Ali centre, Wangjing Es Rd., Chaoyang District, Beijing).

4. Newsletter

Purpose: To send you our newsletter.
Data Processed: Contact Data.
Legal Basis: Consent (Art. 6(1)(1)(a) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Email Service Provider.

II. Web Analytics Technologies and Pixels

Upon receiving your consent, we will use web analytics technologies on our website to collect and evaluate information about your activities, create a device profile, improve our website, and analyze sales performance.

1. Web Analysis

Purpose: To collect information about your use of our website (e.g., page views, dwell time) using “Google Analytics” to improve our website. Your IP address is anonymized before storage.
Data Processed: Web Analytics HTTP Data, Web Analytics Device Data and Web Analysis Profile Data.
Legal Basis: Consent (Art. 6(1)(1)(a) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Web Analysis Tool Provider.

III. Online Shop

When you purchase a EELUCK product online, we process your data for the shopping cart function, purchase processing, rescission (withdrawal), after-sales services, and product reviews.

1. Shopping Cart

Purpose: To provide you with the shopping cart function (using strictly necessary cookies).
Data Processed: Shopping Cart Data and Shopping Cart Device Data.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Online Shop Tool Provider.

2. Processing Your Purchase

Purpose: To fulfill our obligations under the purchase agreement (payment and shipping) and send transaction emails.
Data Processed: Order Data, Payment Data, Shopping Cart Data, Contact Data and Transaction Email Data.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Online Shop Tool Provider and Payment Service Provider.

3. Rescission of Purchase Agreements (Withdrawal/Refund)

Purpose: To refund you the purchase price and send transaction emails about the refund process.
Data Processed: Order Data, Payment Data, Shopping Cart Data, Contract Data, Contact Data and Transaction Email Data.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Hosting Provider, your local store and Payment Service Provider.

4. After-Sales Service

Purpose: To provide you with after-sales services, particularly warranty services through our local agents.
Data Processed: Contact Data, Order Data and Contract Data.
Recipients Category: Hosting Provider and Your local store agent.

5. Product Reviews

Purpose: To display your product review on your website for advertisement purposes.
Data Processed: Contact Data and Review Data.
Legal Basis: Our legitimate interest (Art. 6(1)(1)(f) DS-GVO).
Recipients Category: Product Review Tool.

IV. Your Contract with Us

When you have concluded a contract with us, we process your data for the performance of the contract, sending advertisements via email, and handling customer support inquiries.

1. Performance of the Contract

Purpose: To perform your contract regarding products and services (e.g., EELUCK smart watch, App) for accounting and warranty claims.
Data Processed: Order Data and Contract Data.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Hosting Provider.

2. Advertising via Email

Purpose: To send you advertisements for our own similar goods and services (if you provided your email during a purchase).
Data Processed: Contact Data and Contract Data.
Legal Basis: Our legitimate interest (Art. 6(1)(1)(f) DS-GVO) to advertise our own similar products to our customers.
Objection Right: You can object to this processing at any time.
Recipients Category: Email Service Provider.

3. Customer Support

Purpose: To handle your inquiry, clarify questions, and for EELUCK’s engineers to access relevant data if necessary.
Data Processed: Contact Data, Contract Data, Log-In Data, End Device Data, Account Data, Health Data, Health Status Data, Training Data and Communication Data.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR); regarding access to Health Data, your explicit consent (Art. 6(1)(1)(a), 9(2)(a) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Hosting Provider, Group Companies and Customer Support Tool Provider.

V. Use of the App and EELUCK Smart Watch

When you use our app and EELUCK smart watch, we process your data (including health data) for installation, account creation, service localization, device pairing, insights, training analysis, system error feedback, health assessments, data synchronizing, and emergency contacts.

1. Installing the App

Purpose: To ensure software compatibility and identify your country/region.
Data Processed: End Device Data.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Hosting Provider.

2. User Account

Purpose: To allow you to create a necessary user account (login info, general info, email verification) and optionally upload a profile image. You may also use WeChat or Facebook.
Data Processed: Log-In Data, End Device Data, Account Data and photos/images (if granted access).
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Social Network Provider (if used for login).

3. Selected Services that are Available in Your Location

Purpose: To identify your country/region to provide you with available services.
Data Processed: Localization Data.
Legal Basis: Our legitimate interest (Art. 6(1)(1)(f) DS-GVO) to offer you selected services based on your location.
Recipients Category: Hosting Provider.

4. Device Pairing

Purpose: To pair your EELUCK smart watch with the app (via Bluetooth or QR code scan).
Data Processed: EELUCK smart watch Device ID.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Hosting Provider.

5. Daily Use Insights for Users

Purpose: To collect and process health/environment data from watch sensors via the app to provide you with daily insights into your body and health.
Data Processed: Training Data and Health Data.
Legal Basis: Your explicit consent (Art. 6(1)(1)(a), 9(2)(a) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Hosting Provider.

6. Training Performance Analysis

Purpose: To collect training data and process location data (for sporting trail thumbnail image) to provide performance analyses.
Data Processed: Health Status Data, Training Data, Health Data and Location Data.
Legal Basis: Your explicit consent (Art. 6(1)(1)(a), 9(2)(a) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Hosting Provider and Third Party Platforms Provider (if consented to the transfer).

7. Feedback on System Errors

Purpose: To collect device info, app logs, and user-uploaded images/videos for diagnostic and troubleshooting purposes.
Data Processed: End Device Characteristics, App Log File Data and Contact Data, and photos/images/videos uploaded by yourself (if granted access).
Legal Basis: Consent (Art. 6(1)(1)(a) GDPR) AND Performance of a contract (Art. 6(1)(1)(b) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Hosting Provider and Group Companies.

8. Assessment on Your Health and Fitness Status

Purpose: To collect and analyze physical fitness and training records to provide health and fitness status assessments.
Data Processed: Health Status Data, Training Data and Health Data.
Legal Basis: Your explicit consent (Art. 6(1)(1)(a), 9(2)(a) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Hosting Provider.

9. Third-Party Platform Data Synchronizing

Purpose: To transmit your training records to third-party platforms as chosen by you.
Data Processed: Training Data, Health Data and Location Data.
Legal Basis: Your explicit consent (Art. 6(1)(1)(a), 9(2)(a) GDPR).
Withdrawal: You may revoke your consent at any time, e.g. by email to eeluck@eeluck.com.
Recipients Category: Third Party Platform Data Provider.

10. Emergency Contact

Purpose: To call your emergency contact via the SOS function on the smartwatch in an emergency.
Data Processed: Emergency Contact Data.
Legal Basis: Performance of a contract (Art. 6(1)(1)(b) GDPR).
Recipients Category: Your emergency contact and Hosting Provider.

General Information

Are Users Obliged to Provide the Data and What Would Be the Consequences of Not Providing It?

You are not obliged to provide your data. Provision is neither legally nor contractually required.
However, if you do not provide the data, you may not be able to use all of our services.
Providing data marked as mandatory in our online shop checkout is required to enter into a contract.
EELUCK watches can be used without pairing with the EELUCK smartwatch’s app, and the app/watch can be used without an internet connection for a limited duration (data syncs when connection is restored).

Does Automated Decision-Making Take Place?

We do not use automated decision-making, including profiling, on the basis of your personal data in accordance with Art. 22(1) and (4) of the GDPR.

Do We Transfer Data to Countries Outside the European Union or the European Economic Area?

EELUCK products and services are provided worldwide.
EEA and U.K. Customers: Personal data is collected and stored on servers in the EEA.
Customers outside of EEA, U.K., and China: Personal data is collected and stored on servers in the Asia, Europe and America.
International Transfer Risk: Upon receiving your explicit consent (cf. Art. 49(1)(1)(a) GDPR), we will transfer personal data to countries where our Group Companies locate outside the EU (risk of inadequate data protection) to provide customer support upon your request.

How Long Do We Store Personal Data For?

We store personal data only for as long as is necessary to achieve the above-mentioned purposes.
Statutory retention obligations (e.g., commercial and tax law documents) may necessitate longer retention periods.

Your GDPR Rights

1. Right to Object

Right to object on grounds relating to your particular situation (Art. 21(1) GDPR): You have the right to object at any time to processing based on Art. 6(1)(1)(e) or (f) GDPR (legitimate interests).
Right to object to direct marketing (Art. 21(2) GDPR): You have the right to object at any time to processing for such marketing, including profiling related to direct marketing. In the event of an objection, we will no longer process the personal data for direct marketing purposes.

2. Other Rights

As a data subject, you also have the following rights:

Right of access (Art. 15 GDPR)
Right to rectification (Art. 16 GDPR)
Right to erasure (“right to be forgotten”) (Art. 17 GDPR)
Right to restriction of processing (Art. 18 GDPR)
Right to data portability (Art. 20 GDPR)
Right to withdraw consent (Art. 7(3) GDPR)
Right to lodge a complaint with a supervisory authority (Art. 77 GDPR)

Privacy Disclosures for California Residents

1. The California “Shine the Light” Law

California residents are entitled to request and obtain certain information regarding our disclosure of certain categories of personal information to third parties for their own direct marketing purposes.
We do not share your personal information with third parties for those third parties’ direct marketing purposes.

2. The California Consumer Privacy Act (CCPA)

The CCPA provides California residents with rights to receive certain disclosures, as well as rights to know/access, delete, and limit disclosure of personal information, and the right to be free from discrimination.

Notice at Collection Regarding the Categories of Personal Information Collected

The categories of personal information collected and the purposes for use are described under “How do we process your personal data?” above.
We disclose information for business purposes to Service Providers, which are restricted from using personal information for unrelated purposes.
We do not “sell” information to third parties for monetary or other benefit under the CCPA definition.

Your Rights Under the CCPA

Opt out of sale of personal information: You have the right to opt out of our sale of your personal information to third parties. To exercise this right, please visit our [Do Not Sell My Personal Information] webpage or contact us.
Know and request access to and deletion of personal information: You have the right to request access to and, in certain circumstances, deletion of personal information that we have collected directly from you. Please contact us to exercise these rights.

Privacy Disclosures for Nevada Residents

Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties.
Currently, we do not engage in such sales.
If you are a Nevada resident and would like more information about our data sharing practices, please contact us.