Pugongying BRAND PRIVACY POLICY

Effective Date: September 30, 2025

Last Updated: September 30, 2025

Introduction

Welcome to Pugongying (“Pugongying,” “we,” “us,” or “our”), a brand operated by Alliot IoT. We are committed to protecting your privacy while providing secure and reliable services through our smart pet tracking devices and other Internet of Things products (“Smart Devices”), mobile applications (“App”), and official websites (“Website,” together with the App and Smart Devices, the “Services”).

This Privacy Policy explains how we collect, use, disclose, transfer, store, and protect personal information when you use our Services, as well as the rights and choices available to you. By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Policy, please do not use the Services.

Important Notice:

Our Services—particularly pet location tracking—require the collection and processing of sensitive data such as geolocation information. As a globally operated business, your information may be processed outside your country or region of residence. We implement internationally recognized security measures to protect your data, as described in this Policy.

Table of Contents

Information We Collect

How We Use Information

Information Sharing and Disclosure

Your Rights and Choices

International Data Transfers

Data Security and Retention

Children’s Privacy

Changes to This Policy

Contact Us

Jurisdiction-Specific Disclosures

1. Information We Collect

The information we collect depends on how you interact with the Services and is collected in accordance with principles of transparency and data minimization.

1.1 Information You Provide Directly

Account Information: name, email address, password, phone number.

Pet and Device Information: pet profiles (name, breed, photos), Smart Device serial numbers and nicknames.

Profile Information: optional information you choose to provide.

Communications: information you provide when contacting customer support or communicating with us.

Transaction Information: payment-related details (processed directly by payment providers), shipping addresses, and order history.

1.2 Information Collected Automatically

Device and Log Data: device model, operating system, unique device identifiers, IP address, carrier information, crash logs, browser type, and referral URLs.

Location and Movement Data (Core Functionality): precise or approximate location, movement paths, speed, direction, and dwell time collected via GPS, Wi-Fi, Bluetooth, or cellular networks when permissions are enabled.

Device Performance Data: battery level, network status, firmware version, and usage frequency.

Cookies and Similar Technologies: data collected through cookies, pixels, and similar technologies to analyze usage, manage the Services, and improve functionality.

1.3 Information from Third Parties

Social Login Providers: basic profile information such as username and profile photo, subject to your authorization.

Analytics and Marketing Partners: aggregated or analytical data used to evaluate and improve marketing performance.

2. How We Use Information

We process personal information based on lawful grounds and for legitimate business purposes, including:

Providing and Maintaining Services: activating devices, enabling location tracking, geofencing, alerts, and diagnostics.

Service Operations and Improvements: account management, transaction processing, system maintenance, analytics, and product development.

Personalization: tailoring content, features, and recommendations based on usage patterns.

Communications: responding to inquiries and, with your consent, sending product updates and promotional messages.

Security and Compliance: fraud prevention, system integrity, legal compliance, and responding to lawful requests.

3. Information Sharing and Disclosure

We share personal information only as described below and require recipients to provide appropriate data protection safeguards.

3.1 Affiliates

We may share information with our parent company, subsidiaries, and affiliates for purposes consistent with this Policy.

3.2 Service Providers

We engage third-party vendors to perform services on our behalf, including cloud hosting, data storage, payment processing, analytics, email delivery, and customer support. These providers may access personal information only as instructed and are contractually obligated to protect it.

3.3 Third-Party SDKs and Partners

Our App integrates third-party SDKs to provide specific features, including but not limited to:

You may review the privacy policies of the above third parties to understand their independent data processing practices and to exercise your personal rights in accordance with their policies.

3.4 Legal Requirements

We may disclose information to comply with applicable laws, regulations, court orders, subpoenas, or lawful government requests.

3.5 Business Transfers

In connection with a merger, acquisition, reorganization, financing, or sale of assets, personal information may be transferred as part of the transaction.

4. Your Rights and Choices

Depending on the laws applicable in your jurisdiction (such as the General Data Protection Regulation (GDPR) in the European Union or the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA)), you may have the following rights:

Access and Correction.

You may access and update your personal information by logging into your account.

Right to Deletion.

You may request that we delete some or all of the personal information we maintain about you.

Data Portability.

You may request a copy of the personal information you have provided to us in a structured, commonly used, and machine-readable format.

Restriction or Objection to Processing.

In certain circumstances, you may request that we restrict the processing of your personal information or object to processing based on our legitimate interests.

Withdrawal of Consent.

Where processing is based on your consent (such as marketing communications), you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to such withdrawal.

Opt-Out of Marketing Communications.

You may opt out of receiving marketing communications by using the “unsubscribe” link included in our emails or by disabling push notifications in the App settings.

Opt-Out of Targeted Advertising / “Sale” of Personal Information.

Under certain state laws, the sharing of certain information with advertising partners may be considered a “sale” or “sharing” of personal information. You may opt out through the methods described in the “Jurisdiction-Specific Disclosures” section below.

How to Exercise Your Rights

You may submit a request by emailing  questxteg@163.com . For security purposes, we may verify your identity before processing your request. We will respond within the time period required by applicable law, which is typically 30 to 45 days.

5. International Data Transfers

Our headquarters are located in China, and our servers and authorized service providers are located in various countries around the world, including but not limited to the United States, Europe, and Singapore. As a result, your personal information may be transferred to, stored, and processed on servers located outside of your jurisdiction.

Regardless of where personal information is processed, we implement reasonable and appropriate legal, technical, and organizational safeguards to protect such information and to ensure compliance with this Privacy Policy. Where personal information is transferred across borders, we comply with applicable data protection laws in both the originating and destination jurisdictions.

For example, transfers of personal information from the European Economic Area, the United Kingdom, or Switzerland to countries outside those regions are carried out using legally recognized transfer mechanisms, such as standard contractual clauses approved by the European Commission or other lawful safeguards. We also comply with applicable laws of the People’s Republic of China relating to cross-border transfers of personal information.

6. Data Security and Retention

6.1 Security Measures

We implement industry-standard physical, technical, and administrative safeguards designed to protect personal information against unauthorized access, disclosure, use, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

6.2 Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy and to comply with applicable legal, tax, and audit obligations. When you request account deletion (exercise your right to deletion), the following process applies:

Account Deactivation and Cooling-Off Period

Upon submission of an account deactivation request, your account will enter a thirty (30) day cooling-off period, during which:

Your account will be temporarily suspended and unavailable for core services (such as viewing pet location data or receiving alerts), while login access will remain available to allow you to withdraw the deactivation request at any time;

You will receive relevant notifications and may log in to the App to select “Restore Account” (to cancel deactivation and resume all services) or “Continue Deletion” (to immediately proceed to final deactivation);

If no action is taken upon expiration of the thirty (30) day cooling-off period, deactivation will be deemed confirmed and the account will automatically proceed to final deactivation.

Final Deactivation and Data Processing

If the cooling-off period expires and you do not choose to restore your account, your account will be permanently deactivated. We will then initiate final data processing procedures, under which personal information associated with your account—including profile information, pet data, location history, and related personal data—will be systematically deleted or anonymized.

Legal Retention

Notwithstanding the foregoing, we may retain certain information for a longer period where required to comply with legal obligations, resolve disputes, enforce agreements, or protect security and prevent fraud. Such information will be isolated, securely stored, and used solely for these limited purposes, and will not be subject to the cooling-off or deletion processes described above. Once the applicable retention period expires, such information will be deleted or anonymized.

6.3 Retention Period Examples

Examples of retention periods for key categories of information include:

Location History Data: To support route playback functionality, we generally retain detailed location records for the most recent 30 days, after which such data is automatically deleted or aggregated and anonymized on a periodic basis.

Account Information: Retained for the duration of the account’s existence. Upon account deactivation, such information will be anonymized unless retention is required for legal compliance (such as transaction record keeping), dispute resolution, contract enforcement, or fraud detection and prevention.

Log Information: Generally retained for six (6) months for security analysis and troubleshooting purposes.

7. Children’s Privacy

The Services are not directed to children under the age of 16 (or such higher age as may be required by applicable law in your jurisdiction). We do not knowingly collect personal information from children without verifiable parental consent. If we become aware that personal information of a child has been collected inadvertently, we will take reasonable steps to delete such information from our systems as soon as practicable.

If you are a parent or legal guardian and believe that your child has provided personal information to us, please contact us using the information set forth below.

8. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, Services, or legal requirements. When we do so, we will revise the effective date at the top of this Policy and, where required by law or where the changes are material, provide notice through the Services or by email. We encourage you to review this Privacy Policy periodically. Your continued use of the Services after the effective date of an updated Policy constitutes your acceptance of the revised Privacy Policy.

9. Contact Us

If you have any questions, comments, concerns, or requests regarding this Privacy Policy, our privacy practices, or the exercise of your data protection rights, please contact us using the following information:

Alliot IoT

Email:   questxteg@163.com 

Mailing Address:

RM H2, 4/F, Century Industrial Centre

33–35 Au Pui Wan Street

Fotan, Shatin, NT

Hong Kong

We have appointed a Data Protection Officer (DPO) to oversee privacy-related matters. You may contact the DPO using the email address above and indicate “Attention: Data Protection Officer” in the subject line.

10. Jurisdiction-Specific Disclosures

(a) Residents of Certain U.S. States (Including California, Colorado, and Virginia)

If you are a resident of a U.S. state subject to applicable U.S. privacy laws, such as the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), you are entitled to the additional rights described below:

Right to Know and Access.

You have the right to request information regarding the categories and specific pieces of personal information we have collected, used, and disclosed about you during the preceding twelve (12) months.

Right to Deletion.

You may request that we delete personal information we have collected about you, subject to applicable legal exceptions.

Right to Correction.

You may request that we correct inaccurate personal information we maintain about you.

Right to Opt Out of the “Sale” or “Sharing” of Personal Information for Targeted Advertising.

Although we do not sell personal information for monetary consideration, certain laws may define the sharing of certain information (such as device identifiers or cookie data) with advertising partners for purposes of personalized or targeted advertising as a “sale” or “sharing.” You may opt out of such activities by enabling the Global Privacy Control (GPC) signal when visiting our website, or by contacting us as described in the Contact Us section.

Right to Non-Discrimination.

You will not be discriminated against for exercising any of your privacy rights.

(b) Residents of the European Economic Area, the United Kingdom, and Switzerland

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have the rights described in Section 4 (Your Rights and Choices) in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Legal Bases for Processing.

Our legal bases for processing personal information generally include:

(i) performance of a contract with you (such as providing device tracking and related services);

(ii) compliance with legal obligations;

(iii) our legitimate interests (such as improving our Services and preventing fraud); 

(iv) where applicable, your explicit consent.

Right to Lodge a Complaint.

You have the right to lodge a complaint with the data protection authority in your country or region of residence regarding our processing of your personal information.