Privacy Policy

This privacy policy (“Policy”) describes how Wonder Ladies Limited (“WL”, “we,” “our,” or “us”) collects, uses, and discloses “personal information” about you (as that term is defined by applicable law) under our lostmarycircle website (“website”) and the service we provide for you (collectively, the “Services”). You can access the current version of this Privacy Policy at any time under lostmarycircle.com

Where applicable under local law, U.S. residents may have certain rights with respect to their personal information. Please refer to Section 9 on “U.S. State Privacy Disclosures” below for more information.

1. What Information We Collect

We collect the information about you either directly from you or, where applicable, from our service provider used for age verification.

Information we collect from you

• product identifiers (e.g., product MAC address);
• product usage data (e.g., battery level, usage level, resistance value, activation duration, number of activations, activation time, activation power, child lock status);
• communication content and data (e.g., content of emails that we exchanged with you or notes on phone calls in the context of customer support requests);
• age verification data, in particular a relevant government issued ID document and selfie provided by you during the age verification process;
• technical information we collect from your smartphone or other device connected with your product (e.g., IP address, location on country level based on your IP address, device ID, system bluetooth permissions, and logfile data);
• Firebase Crashlytics data, including the Crashlytics Installation UUID, Firebase installations ID, crash traces and breakpad minidump formatted data (NDK crashes only); and
• inferences drawn from any of the above information

2. How and Why We Use Your Information

The website allows you to use Bluetooth technology to connect and communicate with your product(s), including to monitor and control the usage of your product.

We may use your personal information for the following business purposes:

Purpose	Type of data
To provide you with the requested functionalities and services via the website and enable you to monitor and control the usage of your product;  This includes: -       Technical delivery of our website’s content to your device; -       Enabling users to adjust device settings, including to synchronize time and date settings of your products with your connected device’s clock; -       Enabling users to view the status and performance of their product (such as resistance value, battery level, usage level and other device information); -       Tracking and analyzing product usage to help users monitor and manage their using habits, including frequency, duration and consumption patterns;  -       Receiving product status notifications, including battery level, system alerts, etc. (where the user has provided permissions for device status notifications); and Providing over-the-air (OTA) firmware updates for your product(s) via the website, to provide you with the latest software and security features.	(a) Product identifiers (b) Product usage data (c) Technical information collected from your connected device
To perform age verification services	Age verification data
To provide you with legally compliant information (e.g., our terms or privacy notice) and features of our website	Technical information collected from your connected device (location on country level based on your IP address)
To administer our relationship with you, which will include notifying you about changes to our terms or privacy notice.	Technical information collected from your connected device
To maintain and ensure security of the website and products (including troubleshooting, software updates, system maintenance and support, and cybersecurity protection) This includes that our website may receive information about you from the Firebase Crashlytics service for the purpose of crash collection and helping debug crashes; see further details at: https://firebase.google.com/support/privacy.	(a) Product identifiers (b) Product usage data (c) Technical information collected from your connected device (d) Firebase Crashlytics data
To improve and optimize our website and develop related products and services, including data analytics to understand user preferences	(a) Product identifiers (b) Product usage data (c) Technical information collected from your connected device
To comply with applicable legal requirements, including data retention obligations, to demonstrate compliance with applicable laws and regulations, and to respond to requests by courts and authorities.	All data as described in section 1
To establish, exercise and defend legal claims.	All data as described in section 1

3. Information We Disclose to Other Parties

We may disclose certain categories of your personal information to other parties, including our service providers, business partners, or affiliates in order to achieve our business purposes as follows:

• Service providers: We may disclose your personal data to our service providers, which process your personal data on our behalf and under our instructions. These companies are contractually obliged as processors in accordance with applicable data protection law and may only use your personal data to the extent necessary to provide the services requested by us. For instance, we may share your personal data with our service providers that perform IT services (including hosting services or other operational technical support) or other business operations for us which are carried out in accordance with our instructions.
• Age verification service provider(if applicable):Where necessary in order to perform age verification services, our age verification service provider will collect age verification data directly from you via the website and process the data for age verification purposes. This service provider acts as independent controller in relation to the age verification check, and as our processor in relation to storing certain data for compliance purposes in an audit trail. Our service provider is contractually obliged to process your data in accordance with applicable data protection law.
• To comply with law or cooperate with reasonable legal requests:We may disclose your personal information to law enforcement agencies, courts, other government authorities or other third parties where we believe necessary to comply with a legal obligation. We may disclose personal information as we deem reasonably necessary to support lawful investigations or otherwise to protect our rights or the rights of you or any other party.
• In the context of a transaction: We may disclose your personal information to potential transaction partners, service providers, advisors, and other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell or transfer all or a portion of our assets or business.

4. Retention of Personal Information

For information about our data retention practices, please refer to the “Retention of Personal Information” section of the U.S. State Privacy Disclosures section.

5. How We Safeguard Your Information

We maintain administrative, technical, and physical measures designed to safeguard the personal information you provide against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. However, we cannot guarantee the security of your information as no measures are failsafe.

6. Our Policy Towards Children

The Services are not directed to individuals under 21. We do not knowingly collect personal information from users under 21. If we become aware that a user under 21 has provided us with personal information, we will take steps to delete such information. If you believe that a user under the age of 21 may have provided us with personal information, contact us as specified in the “Contact Us” section of this Policy.

7. U.S. State Privacy Disclosures

This section provides additional information for residents of the United States.

Retention of Your Personal Information

We will keep your personal information for as long as we have a relationship with you or until we no longer need it to fulfil the purposes for which it was collected. Once our relationship with you has come to an end or we no longer need the information to fulfil the purposes for which it was collected, we will retain your personal information for a period of time that enables us to:

• Maintain business records for analysis and/or audit purposes;
• Perform internal research to assess and improve our business;
• Comply with record retention requirements under the law or other relevant legal requirements or our internal document retention policy;
• Defend or bring any existing or potential legal claims; or
• Deal with any complaints regarding the services.

Your Privacy Rights

You may have certain choices regarding your personal information, subject to certain exceptions, as described below.

• Access.You have the right to request, twice in a 12-month period, that we disclose to you the categories of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of (or specific, if applicable) third parties to whom we disclose your personal information, and the specific pieces of personal information we have collected about you.
• Data Portability.You have the right to request that we provide you with a copy of your personal information that we have collected about you in a structured and machine-readable format.
• Correction.You have the right to request that we correct the personal information we maintain about you if that information is inaccurate.
• Deletion.You have the right to request that we delete certain personal information we have collected from you.
• Non-discrimination: You have the right not to be discriminated against for exercising your rights.
• Appeal.You have the right to appeal our decision to deny your request, if applicable.

To exercise these rights, including to submit a request as an authorized agent on behalf of another individual, you may email us at support@lostmarycircle. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Authorized agent. You may authorize an agent to exercise your rights on your behalf. To do this, you must provide the authorized agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from the agent when they make a request on your behalf. We may also ask you to verify your own identity and directly confirm with you that you have granted permission to the authorized agent.

Verifying Requests. To help protect your privacy and maintain security, we will take steps and may require you to provide certain information (such as your name, address, email address, and relationship to us) to verify your identity before granting you access to your personal information or complying with your deletion or correction request. If you designate an authorized agent to make an access, correction, deletion, or opt-out request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described above).

8. Changes to the Policy

We may modify or update this Policy from time to time. We encourage you to visit this Policy at least once per year to learn about any changes to the way we collect, use, or disclose your personal information. If we make a material change to this Policy, we will take reasonable steps to notify you, as required by applicable law.

9. Contact Us

If you have questions about this Policy or our use of your personal information, please contact us at support@lostmarycircle.com.