Data Privacy Policy

Version No. V1.0.1

Last updated: April 9, 2024


Developer: PH Smart

We take the protection of your personal data very seriously and want you to feel secure when using our app and products. Protecting your privacy when processing personal data is an important concern for us.

Information we collect:

As part of our business relationships, we collect and process personal data that we have received directly from you. In addition, we process personal data that we legitimately obtain from publicly accessible sources, or that is legitimately transmitted to us by other third parties; insofar as this data is necessary for the provision of relevant services, we provide to you and/or within the scope of the Purposes as set forth below.

Purposes of processing (“Purposes”) and legal basis:

Your personal data will be processed according to the provisions of the applicable law for the following purposes:

For the fulfillment of contractual obligations (Art. 6 Para. 1b GDPR): Personal data is processed in the context of trade with products and services in consumer electronics. Data processing purposes depend primarily on the specific product and its software applications. Further details on this data processing purpose can be found in the accompanying operating instructions, manuals, and other terms and conditions for the purchase of such specific products.

Within the framework of balancing interests (Art. 6 para. 1f GDPR): If necessary, we process your data beyond the actual performance of the contract to protect our legitimate interests of us. For the purpose of the assertion of legal claims and defense in legal disputes; the guarantee of IT security and the maintenance of our IT infrastructure and operation; the prevention and clarification of criminal offenses; and for business management purposes and the development of services and products.

Based on your consent, Art. 6 Par. 1a GDPR): If you consent to us processing personal data for specific purposes (e.g., forwarding data or evaluating data for marketing purposes), the legality of such processing is given based on your consent. The consent can be revoked in our app (Settings: Withdraw: Consent). The revocation of the consent does not affect the legality of the data processed until the revocation.

Due to legal requirements (Art. 6 para. 1c GDPR) or in the public interest (Art. 6 para. 1e GDPR): This includes, for example, identity and age checks or the fulfillment of tax control and reporting obligations.

Special data protection at our fitness tracker: We use your data to make the fitness tracker as functional as possible so that you can benefit optimally from your fitness program. At the same time, this information will improve our Service. The application stores and processes the following data: Username, Gender, Birthday, Weight, Height, Steps, Sleeping Hours, Heart Rates (if available), Distances, Calorie Consumption, Goals, Successes, and Challenges. Your data will only be stored locally on your smartphone or device. To ensure the compatibility of your smartwatch with your smartphone or device, our smartwatch accesses the following functions of your phone:


  1. Read caller list
  2. Taking pictures and videos
  3. Reading contacts
  4. Receive SMS
  5. Read SMS or MMS
  6. Read the contents of your shared memory
  7. Changing or deleting the contents of your shared memory
  8. Only access the exact location when running in the foreground
  9. Access the approximate location (network-based) only when running in the foreground.
  10. Accept calls
  11. Retrieve phone status and identity
  12. Retrieve network connections
  13. Battery performance optimizations
  14. Perform linking with Bluetooth devices
  15. Execute foreground service
  16. Access Bluetooth settings
  17. Control vibration alarm
  18. Access to all networks
  19. Deactivate idle state
  20. Play Install Referrer API


  1. Location
  2. Photos
  3. Bluetooth
  4. Camera
  5. Siri & Search
  6. Messages
  7. Background Update
  8. Mobile Data

App permissions: To provide you with the app's functionalities, the app must be able to access various functions and data of your mobile device. To do this, it is imperative that you grant the app-selected access authorizations. Otherwise, the app cannot be used for technical reasons. Before using the app for the first time, we will explicitly inform you of the rights you requested to access. Usually, the authorizations are as follows:

Location: This permission is required to determine your current location for location-based services. It allows your phone to access your GPS data, WLAN identifiers, and/or Bluetooth, depending on which of them you have enabled, to locate your location.

Push notifications: Push notifications are messages (e.g., WhatsApp) sent from the app to your device and prioritized there. This app uses push notifications on delivery, provided the user has consented to the app during the installation or the first use. The end-user must accept the enable notifications for the first-time installation. Also, the reception of push notifications can be deactivated at any time in the app's settings.

Access smartphone contacts: This permission is required to show the caller's name when the user receives a call notification.

User behavior: Within the framework of legal regulations, we, or companies commissioned by us, create user profiles, enter a name, or insert an Avatar in our App. Users can click “skip” to avoid providing this information. The profile data is not linked to any further information about the user.

Device information: In addition to protocol data, we may also collect information about the device on which the app is used. These include device type, operating system used, settings, unique identifiers, and crash data. Whether some or all of this information is collected depends on the type of device used and its settings. This allows error messages and system crashes to be analyzed to improve future operations. You can find out from how the information is processed and protected.

We are distributing our App via the Apple App Store and Google Play Store. We have also incorporated Google Maps (for Android devices), Firebase Crashlytics, and Google Analytics into our app. GPS-related sports activities and Google Maps require Location Permissions. Firebase Crashlytics and Google Analytics collect crash data that are not linked to any of your identities. The purpose of using Google Maps is to provide the latitude and longitude information from our GPS Smartwatch and to our app; then, our App invokes Google Maps to display user activity trajectory on the app, a major function of our GPS Smartwatch. Google Analytics helps to measure and provides insight into our Watch App usage and user engagement. Analytics integrates across Firebase features and provides unlimited reporting for up to 500 distinct events that you can define using the Firebase SDK. Analytics reports help you understand users' behavior, which enables them to optimize app performance. Using Firebase Crashlytics and Google Analytics to collect crash data is to help track, prioritize, and fix stability issues that erode our app quality. Crashlytics saves our troubleshooting time by intelligently grouping crashes and highlighting the circumstances that led to them: Find out if a particular crash impacts many users, get alerts when an issue suddenly increases in severity, and figure out which lines of code are causing crashes.

As a result, usage of our apps is also subject to the following privacy policies:

  • Apple App Store:
  • Google Play Store:
  • Google Maps:
  • Apple Maps:
  • Google Crashlytics & Google Firebase Analytics:
  • Open Weather:
  • Apple Health:
  • Google Fit:,
  • Strava: https//
  • Facebook:
  • Instagram:
  • Skype:
  • Mailo:

Social Media: If you connect to this app via third-party social media sites (such as Facebook, X (Twitter), Instagram, Google+, etc.), you may be subject to the data policy of such third-party social media sites. We cannot access any of your personal data stored on such third-party social media sites.

The purpose of using weather service is that weather is a major function of our smartwatch. We use the device’s longitude and latitude information to query weather data for that location. The collected location information is not linked to your identity and will not be stored or used for other purposes. The usage of weather service and its storage duration of data are subject to their privacy policy:

Personal data and Measurement data are recorded & processed.

Username, Gender, Birthday, Weight, Height, Steps, sleeping hours, Heart rate (if available), Running Distance, Calories Consumed, Goals, Successes, and Challenges.

Data Safety:

As part of the App's functionality, this App may collect the following data and upload it to your smartwatch according to your instructions and permissions. The collected data is processed ephemerally and will not be shared with third parties.

  1. Contacts
  2. Image
  3. Media
  4. Notifications
  5. SMS

Data Protection and Limited Use Disclosure:

All data transfer and storage are encrypted to protect this App against unauthorized or unlawful access, destruction, loss, alteration, or disclosure.

Health Connect: The use of information received from Health Connect will adhere to the Health Connect Permissions policy, including the Limited Use requirements.

Storage Period:

Your data is only stored on your smartphone or device. Once the App is uninstalled, all personal data will be removed from your smartphone or device, and none will be retained. The retention period of data transmitted to third-party providers is subject to the data policy of such third-party sites. We will not actively transfer your data to any third party. With your permission, the data that has been successfully transferred to a third party [e.g., Apple Health, Google Fit, or Strava (if available)] will follow the third-party platform and privacy policy. You can turn off third-party authorization settings anytime, and data will no longer be transmitted. For firmware updates, the data stored in European servers will be stored during your use of our Watch App. You can contact us to delete it. Once you make a deletion request, we will delete or anonymize your information as soon as possible and no later than 90 days from the date of your request. The data will be stored for around six months until a further update is available if a deletion request is not made.

Affected rights: Any person concerned by the processing of personal data has the right to:

  1. Information (Art. 15 GDPR),
  2. Corrigendum (Art. 16 GDPR),
  3. Cancellation (Art. 17 GDPR),
  4. Restriction on processing (Art. 18 GDPR),
  5. Data transferability (Art. 20 GDPR)
  6. Opposition (Art. 21 GDPR).

There is a right of appeal to a competent data protection supervisory authority (Art. 77 GDPR). You also have the right to lodge a complaint with the responsible data protection supervisory authority at any time. You can contact the responsible data protection supervisory authority located in your country or state. You can revoke your consent to processing personal data at any time. You can uninstall our App anytime if you would like to revoke this consent. Please note that the revocation will only take effect in the future. Processing that took place before the revocation is not affected by this.

Automated decision-making:

In principle, we do not use fully automated decision-making according to Art. 22 GDPR for the establishment and implementation of the business relationship. Should we use these procedures in individual cases, we will inform you separately insofar as this is required by law.

Information about your right of objection according to Art. 21 Basic Data Protection Ordinance (GDPR)

Right of objection in individual cases: You have the right to object at any time for reasons arising from your situation to the processing of personal data concerning you, which is based on Art. 6 para. 1e GDPR (data processing in the public interest) applies to profiling based on this provision within the meaning of Art. 4 no. 4 GDPR. If you object, we will no longer process your personal data unless we can prove compelling reasons worthy of protection for the processing, which outweighs your interests, rights, and freedoms, or the processing serves to assert, exercise, or defend legal claims. Our app cannot be used if you revoke consent.

Withdraw your consent:

If you have given consent under this privacy policy to process your data through our app, you can withdraw consent from our App (Settings: Withdraw: Consent: Press “OK”), and none of the data will be retained. You have the right to object at any time by writing to the following points of contact:

Point of contact: If you have further questions regarding processing your data or wish to exercise any of your rights under the GDPR or under this policy, you can contact our data protection Controller at If you are based in Europe, you may also direct your inquiry to the data protection officer of our representative in Europe at Controller Details:

Shenzhen Zhilianshengya Technology Co., Ltd,

Address: 5F, Building B, Huawan Industrial, Xixiang Street, Bao’an District, Shenzhen


European Representative: Shenzhen Zhilianshengya Technology Co., Ltd,

Address: 5F, Building B, Huawan Industrial, Xixiang Street, Bao’an District, Shenzhen


Notifications from the APP:

By accepting this privacy policy, you accept push notifications from the APP, including information about upgrades and marketing. You can deny permission within your phone’s settings to opt out of receiving these notifications. By accepting this privacy policy, you accept in-app notifications from the APP, including information about upgrades and marketing. You can deny permission within the APP’s settings to opt out of receiving these notifications. 

Amendments to the Privacy Policy:

We reserve the right to amend the Privacy Policy at any time. Modifications will be posted on our website, and we suggest you review it occasionally.

09 April 2024