Privacy Notice

Last updated in September 2022

robatherm (“we”, “our”, “us”) respects and protects your personal information and privacy. When you use our website, APP, mini program or other services, or when we conclude and perform contract with you, we will process your personal information in accordance with this privacy policy (“Policy”). We will explain to you, through this Policy, how we process and protect your personal information and what rights you are entitled to. Please read carefully and understand this Policy before using our website, APP, mini program or other services, or concluding and performing contract with us.

In addition to general information (Part 1), this Policy will help you understand how we collect and process your Personal Information (Part 2), how we protect and retain your Personal Information (Part 3), how we share and transfer your Personal Information (Part 4), how you exercise your rights (Part 5), how we update this Policy (Part 6) and how to contact us (Part 7). 除了一般信息(第1部分),本政策还将帮助您了解我们如何收集和处理您的个人信息(第2部分),我们如何保护和留存您的个人信息(第3部分),我们如何分享和转移您的个人信息(第4部分),您如何行使您的权利(第5部分),我们如何更新本政策(第6部分)以及如何联系我们(第7部分)。

Part 1 – General information
第一部分 — 一般信息

Under this Policy, the following terms shall have the meaning as defined below:

1. Personal Information

“Personal Information” (“PI”) refers to any type of information recorded in electronic form or otherwise that can be used independently or in combination with other information to identify specific natural persons. Typical examples of PI include but are not limited to a natural person’s name, date of birth, ID number, biometric information, address, telephone number, email, health information, and tracking information.

2. Sensitive Personal Information

“Sensitive Personal Information” (“SPI”) refers to PI that, if leaked or illegally used, could easily result in infringement of a natural person’s dignity or endangering of personal/proprietary security, which includes but is not be limited to biometric information, religious belief, special identity, medical and health information, financial account, tracking and whereabouts, information of minors below the age of 14. Processing of SPI is only allowed for specific purposes with sufficient necessity and shall be subject to strict security measures.

3. Process

“Process” refers to actions such as collection, storing, use, refinery, transmission, provision, publishing and deletion.
“处理” 是指收集、存储、使用、加工、传输、提供、公开和删除等行为。

Before you use the website, APP, mini program or other services provided by our entities located within the People’s Republic of China (“PRC” or “China”, which for the purpose here shall exclude Hongkong, Macao and Taiwan) or conclude and perform contract with our PRC entities, please carefully read this Policy and confirm that you have fully understood and agreed to this Policy by clicking “agree” or “accept” button on the corresponding interface. Your use of our website, APP, mini program or other services, or conclusion and performance of any contract with us shall be deemed that you have fully understood and agreed to this Policy including its future update which shall become an integral part of our contract with you and will be notified to you in due course, or the terms and conditions for your use of our website, APP, mini program or other services.

Part 2 – How we collect and process your Personal Information
第二部分 — 我们如何收集和处理您的个人信息

1. For Usage of Website, APP, and Mini program

When you visit our website or use our APP and mini program, we may collect and process the following information in order to offer you the functions thereon:

(1) IP address, referrer, URL, browser;
(2) information concerning start and duration of use, click-path, user behavior;
(3) telecommunication services used by you;
(4) date and time of inquiry;
(5) time zone;
(6) content of the request;
(7) access status / HTTP status code;
访问状态 / HTTP状态代码;
(8) the respective transmitted data volume;
(9) operating system and its interface;
(10) language and version of the browser software;
(11) your interaction with us on website, APP and mini program, e.g. comments, posts;
(12) information about your social media profile which you use to access our website, APP and mini program, e.g. your WeChat no., name and profile;

The purpose of collecting and processing the above information is:

(1) to ensure seamless connectivity and use of our website, APP and mini program;
(2) to evaluate the security and stability of our system;
(3) to enable the functions for you and establish communication with you;
(4) fulfilling obligations prescribed by laws.

2. Scope of collecting and processing for offering products and services

When you gather information on our products via our website, APP, mini program or other means, we may further collect and process the following PI:

(1) name;
(2) address;
(3) phone number;
(4) fax number;
(5) e-mail address;
(6) information about the products purchased (e.g. quantity, price, specifications);

The purpose of collecting and processing the above information is to enable to provide you with our services and proceed with an actual or potential contract for a purchase of our products and services, which includes but is not limited to:

(1) providing specific services for or product information to you via our website, APP or mini program;
(2) preparing offers and processing inquiries, orders and delivery of the goods;
(3) invoicing and payment;
(4) credit assessment;
(5) after-sales service;
(6) marketing e.g. send your information about our products and services via email;
(7) fulfilling obligations prescribed by laws.

As far as SPI (e.g. financial information) is concerned, we will obtain your separate consent in advance by e.g. asking you to execute a separate consent form or click through a separate privacy notice page.

If the above information provided by you is PI of a third party, you shall ensure that you have obtained lawful consent from the PI subject of concern and shall provide respective proof to us upon request. Otherwise, we shall be entitled to reject your provision of third party’s PI and you shall undertake all consequences and liabilities arising therefrom, including but not limited to failure to use any services, functions as well as other support provided by us.

Part 3 – How we protect and retain your Personal Information
第三部分 — 我们如何保护和留存您的个人信息

We undertake to maintain our information protection at a leading security level. To safeguard your PI, we use various security technologies and supporting management systems to reduce the risks of your PI being divulged, corrupted or lost, misused, revised, accessed or disclosed without authorization. We regularly update and improve our security technologies to better serve the purpose of safeguarding your PI.

We have formulated emergency plans for PI security incidents. If, unfortunately, any PI security incident occurs, we will act in accordance with the laws and regulations as well as our emergency plans and inform you in a timely manner of the basic information and possible impact of the security incident, measures taken or to be taken by us, suggestions for you to take precautions and to reduce risks, etc. We will promptly update you on the status of the incident by email, SMS, or other reasonable means. Where it is difficult to inform all PI subjects individually, we will take a reasonable and effective approach by making a public announcement. At the same time, we will take the initiative to report, as required by the regulators, how the PI security incident is being handled.

Except as otherwise permitted or required by applicable law or regulatory requirements, we retain your PI only for a minimum period as necessary to fulfill the purposes for which it was collected (unless any legal, regulatory, accounting or other reporting requirements or obligations permit or require us to retain PI for a longer period).

Part 4 – How we share and transfer your Personal Information
第四部分 — 我们如何分享和转移您的个人信息

We transfer your PI to our affiliates or third parties either within or outside China only when it is necessary to achieve certain purposes as mentioned in this Privacy Policy. In such cases, we will obtain your separate consent in advance by e.g. asking you to execute/click through a separate consent form.

As far as cross-border transfer of your PI is concerned, on top of the separate consent as mentioned above, we will also fulfill other applicable obligations provided for by laws, e.g. entering into data processing agreements with offshore recipients, ensuring that your PI is fully protected in the same way as it is within China.

Part 5 – How you exercise your rights
第五部分 — 您如何行使您的权利

You may exercise the following rights over your own PI according to applicable laws and regulations:

1. Accessing and duplicating your Personal Information

You have the right to access and duplicate your own PI, unless otherwise stipulated by laws and regulations. You may contact us via email as specified in section VII. How to Contact Us. Within the period permitted by applicable laws, we will respond to your requests as soon as possible.
您有权访问和复制自己的个人信息,但法律法规另有规定的除外。您可以通过第七部分 — 如何联系我们中载明的电子邮件与我们联系。在适用法律允许的期限内,我们将尽快回复您的请求。

2. Correcting your Personal Information

If any PI of yours is incorrect or incomplete, you may also contact us via email as specified in section VII. How to Contact Us. We will respond to your requests and correct your PI as soon as possible.
如果您的任何个人信息不正确或不完整,您也可以通过第七部分 — 如何联系我们中载明的电子邮件与我们联系。我们会尽快回复您的请求并更正您的个人信息。

3. Deleting your Personal Information

Under any of the following circumstances, you may raise a request for deleting your PI:

(1) if our processing of your PI is in violation of applicable laws or regulations;
(2) if we process your PI without your consent when such consent is the only legal basis we rely on to process your PI;
(3) if you cancel the account you registered on our website, APP or mini program, or we cease to provide you with website, APP or mini program;
(4) if our processing of your PI violates our agreement with you (if any) or our agreement with you (if any) has expired or been terminated.

Upon our receipt of your requests, we will review the legal ground of such requests as soon as possible. If the legal ground is verified, we will delete or anonymize your PI in a timely manner. We will also notify the third parties who obtain your PI from us as much as possible and ask them to delete your PI unless otherwise stipulated by laws and regulations or these subjects have obtained your separate authorization.

4. Changing and withdrawing your consent

You are entitled to give or withdraw your consent or change the scope of your consent at any time (which withdrawal or change shall be duly notified to us via contact detail as specified in section VII. How to Contact Us).
您有权在任何时候给予或撤回您的同意或变更您的同意范围(该等撤回或变更应通过第七部分 — 如何联系我们中载明的联系方式正式通知我们)。

When you withdraw your consent, we will no longer process the corresponding PI if such consent is the only legal basis we rely on to process your PI. When you change the scope of your consent, we will process the corresponding PI within the new scope as consented to by you. To the extent the corresponding PI is necessary for providing our services to you, in case of withdrawal and if in addition no contract is concluded between you and us, we no longer will be able to prepare an offer or provide services to you.

However, your change or withdrawal of consent does not affect the lawfulness of any processing that occurred prior to the change or withdrawal.

5. Requesting explanation and rejecting automated decision-making

We currently do not use automated decision-making. However, for some business functions, our decisions in future may be made solely based on an automated decision-making mechanism (e.g. algorithm). If these decisions have a significant impact on your legal rights and interests, you have the right to request an explanation and reject decisions made solely based on automated decision-making mechanism.

6. Responding to your above requests

For the sake of security, you may be required to file written requests and/or prove your identity before we can process your request.

We will not charge any fees for your reasonable requests. However, if your requests are lodged repeatedly or beyond a reasonable extent, we may, at our own discretion, charge fees of a proper amount. We may also reject requests that are unreasonably repetitive, require excessive technical means (for example, the need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical.

Part 6 – How we update this Policy
第六部分 — 我们如何更新本政策

This Policy may change from time to time. Without your explicit consent, we will not reduce or restrict the rights you are entitled to under this Policy. We will publish any change to this Policy on our official homepage on the website, APP, or mini program. If changes are significant, we will also provide a more prominent notice, incl. sending such notice via email, subject to having been provided with your email address based on this Policy, as the case may be.

For the purpose of this Policy, significant changes may include:

(1) significant changes to our service mode e.g. the purposes of processing your PI, the types of your PI being processing, the ways of using your PI;
(2) significant changes to the recipients we share with, transfer to or publicly disclose your PI to;
(3) significant changes to your rights as specified in this Policy and your ways of exercising the rights;
(4) significant changes to our internal department responsible for PI security, contact info. of such department, or complaint channels;
(5) any security impact assessment indicating or revealing high risk.

Part 7 – How to contact us
第七部分 — 如何联系我们

If you have any questions or concerns about this Privacy, you may contact us via:


I have read the Privacy Policy and expressly agree to it.