Privacy Policy

1. Who we are

DJM Trading Limited is a body corporate incorporated in Hong Kong, with its registered office at RM 701, Unit 108, 7/F, Tower B, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui, Kowloon, Hong Kong.

We publish the LU&BA Android application and act as the data controller for the personal data described in this policy. We have engaged Shenzhen DJM Innovation Industrial Co., Ltd. to operate the application servers on our instructions, under a written data processing arrangement.

2. Scope of this policy

This policy applies to the LU&BA Android application and the account service it connects to. It also covers this website, which sets no cookies and runs no tracking script. It does not apply to third-party sites or applications you may reach through links in the app or on this site.

3. Information we collect

We collect only what is needed to sign you in, to operate the device and to keep the records you ask us to keep. The complete list is set out below. It is organised by the point at which the data reaches us.

3.1 Account: email address

Your email address is the only account identifier in LU&BA. It is required: there is no way to create or use an account without it. We also process the one-time verification code we send to that address when you sign in, and the access token our server issues to keep you signed in. The token is held on your phone (see section 14).

3.2 Bluetooth device identifiers

When you pair and bind a compatible device, we receive and store:

• the device's Bluetooth hardware address (MAC address). We strip the colon separators and store the result as the device identifier device_id, so the identifier we keep is the 12-character hexadecimal form of the address;
• the Bluetooth device name advertised by the device;
• the device model code assigned by the manufacturer;
• the firmware version installed on the device.

This identifier is what links a physical device to your account, and it is what our after-sales team uses to identify the unit when you ask for service.

3.3 Camera and the consumable code

The app uses the camera for one purpose only: to read the QR code printed on a consumable, so that you can check that the consumable is genuine and see how much of it remains. The camera is opened only when you start a code check yourself, and it closes when the check ends. If you never start a check, the camera is never used.

• Live scanning. While the check screen is open, the app shows the camera preview and decodes the QR code on your phone. The preview frames are not stored.
• Choosing an existing image. Instead of scanning, you may pick one picture through the Android system photo picker. The app receives the URI of the single image you chose, decodes the code from that image, and nothing more. It does not read, browse or index the rest of your gallery, and it does not request broad storage access in order to do this.
• What leaves your phone. Only the consumable code decoded from the image, together with your account and device identifier, is sent to our server for validation. No photograph and no camera frame is uploaded, and we keep no copy of the image on our servers or on your phone.

The app does not recognise faces, does not record video or audio, does not read any text other than the QR code, and never switches the camera on in the background or while the check screen is closed. You can withdraw the camera permission in Android Settings at any time; the rest of the app, including device control, keeps working, and only the code check becomes unavailable.

3.4 Precise location at device binding

When you bind a device to your account, the app reads your phone's precise location — latitude and longitude — and sends it to our server together with the device identifier. We use it to record the region in which the device was bound, which determines the service region and the partner responsible for your device.

Location is read only at the moment of binding, and only while the app is open on screen. We do not read location in the background, we do not keep a movement history, and we do not use location for advertising. You may decline the location permission at any time in Android Settings; if you decline it before binding a device, the app tells you on screen whether the binding can still be completed, and without a location we record only the account and the device identifier.

3.5 Device operation records

While you use the app we record how the device was operated, so that your session history is available to you and to our service team: session start and end time, session duration, the intensity level used, the operating mode used, and cumulative usage counters for the device and its consumables.

3.6 App and system information

To find and fix faults, and to keep the app compatible with the phones our customers use, we collect the app version, the Android version and the phone model. A technical error record is written to a log file on your phone only when the app fails to start or loses its connection to the device; it is used to reproduce the fault and is not uploaded to us. This information is not combined with advertising identifiers, and we do not build a profile of your behaviour from it.

3.7 What we do not collect

• We do not read your contacts, SMS or other messages, or your call log.
• We do not read, browse or index your photo library. The only image the app ever receives is the single picture you pick yourself for a consumable code check (section 3.3), and it is decoded on your phone.
• We do not use the microphone, and we do not record audio or video. The camera is used only as described in section 3.3.
• We do not collect identity documents, passport or ID card images, or any government identifier.
• We do not collect payment card details. Purchases, where offered, are handled entirely by the app store.
• We do not collect health records, and the app is not designed to record them.
• We do not collect biometric data; the app uses no fingerprint or face recognition.
• We do not display advertising, and we do not use advertising identifiers.
• We do not track your location in the background or over time.

4. App permissions

The list below covers every permission that has a privacy effect or that Android asks you to grant. The app also declares ordinary permissions that never prompt you and carry no personal data, such as internet access and the ability to keep a connection alive while a session runs.

You can withdraw any permission at any time in Android Settings. Withdrawing the Bluetooth permission stops the app from controlling a device; withdrawing the camera permission disables the consumable code check but leaves everything else working. Declining location means we cannot record where a device was bound, which can delay a warranty claim for that unit. We never ask for a permission that has no function in the app. Ordinary permissions (vibration, wake lock, keeping the screen state during a session) are used only for device operation and carry no personal data.

5. How we use information

• To create and secure your account — sending the verification code, issuing and validating the access token, preventing abuse.
• To operate your device — pairing, sending commands for level, mode and duration, reading status back.
• To register ownership — linking a device identifier to your account and recording where the binding took place.
• To provide after-sales service — identifying the unit, checking warranty coverage, handling service requests.
• To keep your records — storing the session records you choose to save so that you can review them later.
• To maintain the app — finding and fixing faults and compatibility problems.
• To meet legal obligations — retaining records where the law requires it, and responding to lawful requests.

We do not use your personal data for automated decision-making that produces legal or similarly significant effects, and we do not use it for advertising or behavioural profiling.

6. Legal bases for processing

Where the EU or UK General Data Protection Regulation applies, we rely on the following bases.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that already took place, and it does not affect processing carried out on another legal basis.

7. Sharing and disclosure

We do not sell personal data, and we do not share it for anyone else's marketing. We disclose it only in these cases:

• Within our service platform. Account, device and record data are stored on the platform described in section 9, which is operated for us under contract for the sole purpose of running the app.
• Authorised service partners. If you ask for warranty or after-sales service, the device identifier, the binding region and the relevant service record may be shared with the distributor or service centre handling your request.
• Legal requirements. Where disclosure is required by law, regulation or valid legal process, or where it is necessary to protect safety or our legal rights.
• Business transfer. If the business or its assets are transferred, data may move as part of that transaction, and will remain subject to this policy.

8. Third-party software

The app contains no advertising SDK and no analytics SDK. We do not embed any component that reports your behaviour to a third party, and no third party receives your data for its own marketing or profiling purposes.

Two external parties are involved in delivering the app:

9. Storage and international transfers

Where personal data is transferred out of the European Economic Area, the United Kingdom or another jurisdiction with transfer restrictions, we rely on appropriate safeguards, including standard contractual clauses with the processor, and we apply the technical and organisational measures described in section 11. You may contact us to obtain further information about these safeguards.

10. Retention

When the applicable period ends, the data is deleted or irreversibly anonymised, unless a longer period is required by law.

11. Security

• Traffic between the app and our servers is protected by TLS encryption.
• Access to your account data requires an authenticated access token bound to your session.
• Access to stored data is limited to personnel who need it to operate and support the service, under access control and audit logging.
• The server environment is reviewed periodically, and access credentials are rotated.

No method of transmission or storage is completely secure. If a breach affects your personal data, we will notify you and the competent authority as required by applicable law.

12. Your rights

Depending on where you live, you may have the right to:

• access the personal data we hold about you, and receive a copy;
• correct data that is inaccurate or incomplete;
• delete your data;
• restrict or object to certain processing;
• receive your data in a portable format;
• withdraw consent where processing is based on consent;
• lodge a complaint with your local data protection authority.

To exercise any of these rights, write to dejichuangxin@djmiot.com.cn with the subject line Data request, or call +852 5647 5385. We respond within 30 days. We may ask you to verify control of the email address on the account before we act, so that we do not disclose or delete data belonging to someone else.

Deleting your account and your data. You can request deletion at any time through the address above. Once we have verified the request we delete your account record, your device bindings and the operation records saved to your account, except where retention is required by law or is needed to resolve an open service or warranty case. Deletion is completed within 30 days of verification, and we confirm it to you by email.

13. Children

LU&BA is not directed to anyone under 16, and we do not knowingly create an account for or collect personal data from anyone under 16. Where the law of your country sets a lower age for digital consent, that lower age applies. If you believe a person under that age has provided us with personal data, write to us and we will delete it and close the account.

14. Cookies and local storage

This website sets no cookies. It loads no font, script, image or style from a third-party server, and it runs no analytics or tracking code, so there is nothing to consent to and no cookie banner.

In the app, the access token and your app settings (language, last selected device) are stored locally on your phone using Android SharedPreferences. This local storage is not a cookie; it stays on the device, it is readable only by the app, and it is removed when you sign out or uninstall the app. Clearing the app's data in Android Settings removes it as well.

15. Changes to this policy

We may update this policy when the app's functionality or applicable law changes. The revised version is published on this page with a new Last updated date, and the previous version is replaced. Where a change materially affects your rights, we will notify you in the app before it takes effect, and where the law requires it we will ask for your consent again. Continuing to use the app after a change takes effect means you accept the updated policy.

16. Contact