Updated: April 25, 2026

The provider and operator of the AI MindClip products/services (hereinafter referred to as "SwitchBot" or "we", including SWITCHBOT Co., Ltd., Wonderlabs Inc., and their parent companies, subsidiaries or affiliates) respects and protects the security of all users' personal information. With respect to personal information generated during your use of our AI MindClip products or services, including smart home products, accessories, computer applications, Apps, toolkits, websites, information storage platforms and related services, or personal information voluntarily provided by you, we will collect and use it in accordance with the principles of propriety, lawfulness and necessity.

Before using our products or services, please carefully read this AI MindClip Privacy Policy so that you can fully understand how, when you use our products or services, we collect, use, store, share and transmit such information, the ways in which we provide you with access to, updating, deletion and protection of such information, and so that you fully understand and agree to the contents of this Policy. Whether you agree to this Policy will affect whether we can provide the corresponding products and/or services to you. The provision of certain services requires your acceptance of this Policy. You have the right to refuse this Policy, but if you do so, we will be unable to provide our products and/or services to you. For processing activities that are not necessary for the services, such as personalized marketing, we will obtain your separate consent. When you choose to use or use again our products and/or services, you will be deemed to have accepted and acknowledged this Policy, because this is a necessary prerequisite for providing our products and/or services.

Your agreement to this Policy indicates that you understand and agree that we will collect certain personal information about you in specific scenarios. However, this does not mean that, once you agree to this Policy and use our products and/or services, we will collect and process all personal information covered by this Policy. For example, when you use certain smart products that require location information, or certain services or functions in the App, we may collect only part of your personal information based on the needs of the specific product or service.

Please note: we support starting or ending recording through the AI MindClip device itself, the App or a smartwatch. As the initiator of recording and processor of content, you undertake that before using the recording function you have lawfully obtained sufficient authorization and express consent from all participants in the recording, including but not limited to interviewees, conversation participants, on-site third parties and other relevant right holders. It is strictly prohibited to use this function in public environments where it is prohibited by law, or to use this function for illegal eavesdropping, illegal collection and use of others' personal information, illegal acquisition of trade secrets or pursuit of commercial benefits. You acknowledge and agree that you shall independently bear all legal liabilities arising from recording without authorization from the relevant right holders, including without limitation infringement of privacy rights and reputation rights.

Article 1 Personal Information We Collect and Use and App Permission Description

1.1 How we collect personal information

We collect your personal information from our official websites, stores, applications, third parties, products you register, and communications with you. The categories of information we collect include:

1.1.1 Information you provide to us

Information you provide when purchasing products, registering and setting up new products, downloading software, posting information on online platforms such as forums or communities, responding to surveys or participating in interactions. Examples include your name, email address, username and password, address and billing information.

1.1.2 Information on use of products and services

When you use our products and services, specific data may be sent to us in order to implement product functions, such as the name of your product, hardware model, firmware version, unique device identifier and IP address information. Sometimes, in compliance with applicable law and where your consent is required, we may collect data based on your activities, including your settings and configurations, usage data and crash or error data. We may also collect your information through cookies and similar tracking technologies.

1.1.3 Information obtained from third parties

We also obtain information about you from other sources. For example, when you interact with us on social media, purchase our products or services through third parties, or comment on one of our products or services, we collect information from publicly available sources. Such information includes information about your purchase of devices or services, comments posted by you, usernames of third-party services, social media profile information and similar information.

1.1.4 Information provided by product testers

When you register as a tester of our products or services, we may collect information about you, including test records, testing experience and suggestions for improvement of our products and services during product testing. We use this information to invite you to become a tester and use your feedback to develop and improve our products and services.

1.2 Contents and purposes of personal information

The contents of the personal information we collect depend on the products, functions and services you use, as well as the scenarios you may use, the activities you participate in and your interactions with us. Such data may include the following:

1.2.1 Registration, login and verification information, including:

1.2.2 Purchase information

Information required to process your order when you make purchases through our platform, such as delivery address, transaction time, ordered products, amount, payment records, contact information, payment channel and third-party payment account information (the transaction will be completed by a secure third-party institution). If you request an invoice, we will also collect the invoice information you use.

1.2.3 Usage information:

Information relating to interactions between you and your devices, and us and our products, including:

1.2.4 Support information

Information about your device hardware and software, your communications with us, data about the computers and applications you use, and system, registry and configuration data, used to support product functions and services, including:

1.2.5 Non-identifiable data

We may also collect and use "non-identifiable data", meaning data that cannot be used to identify an individual, such as aggregate access data, for the purpose of understanding how users use our websites, products and services. We will also determine the purposes and methods for collecting, using, processing, transferring or disclosing non-identifiable data in accordance with applicable laws. We will adopt technical and administrative measures to separate your personal information from non-identifiable data and use them separately. If personal information is mixed with non-identifiable data, it will still be treated as personal information.

1.3 How we use personal information

To provide you with the corresponding functions of our products and/or services, we undertake to follow the principle of data minimization when collecting and using your personal information, and not to use your personal information for purposes beyond the user service terms and this Policy.

We process your personal information on the following lawful bases:

Purposes for which we collect and use personal information: primarily to operate our business and provide, improve and personalize our products and services, including operating and using products, maintaining and improving their performance, researching and developing new functions and providing customer support. With your consent, we may use your contact information to send you communications, including promotional, account, security update and product information. We will always comply with applicable law and obtain your consent where required.

Examples include:

If you would like to learn more about the categories of information collected and the purposes for which we use such information, please refer to the Appendix.

1.4 App Permission Description

To provide complete service functions, the AI MindClip App may request the following system permissions from you during operation. All permissions are used only to implement the corresponding functions, and we will not use them beyond the purposes stated below:

Users may manage the authorization status of the above permissions at any time in the mobile phone system settings, but disabling required permissions may cause the corresponding functions to be unavailable.

Article 2 Cookies, Beacons and Other Similar Technologies

We and certain third parties that provide content, advertising or other functions through our services may use cookies, beacons and other technologies in certain areas of the services.

2.1 Cookie technology

A cookie is a small file that stores information on a computer, mobile phone or other device. The entity placing cookies on your device can recognize you across different websites, services, devices and/or browsing sessions through cookies.

Cookies have many uses, for example:

You may choose to accept or reject cookies, configure your browser to accept all cookies or reject all cookies, or communicate with us to choose to accept some cookies. Please note that certain services may be designed to operate using cookies, and disabling cookies may affect your ability to use those services or parts of them. You may also contact us through the contact details at the bottom of this page for cookie choices or other questions.

2.2 Other local storage

We and certain third parties may use other types of local storage technologies related to our services, such as local shared objects, also known as "Flash Cookies", and HTML5 local storage. These technologies are similar to the cookies described above because they are stored on your device and can be used to store certain information about your activities and preferences.

2.3 Beacons

We and certain third parties may also use technologies called beacons, or "pixels", to transmit information from your device to servers. We and certain third parties use beacons for a variety of purposes, including analyzing service usage and, in conjunction with cookies, providing content and advertisements more suited to your needs. By accessing and using our services, you agree to the storage of cookies, other local storage technologies, beacons and other information on your device. You also agree that we and the above third parties may access such cookies, local storage technologies, beacons and information.

Article 3 How We Share and Disclose Information

We do not sell your personal information. In principle, we do not publicly disclose your personal information. We will share and disclose your personal information only in the following ways:

a. Speech recognition and AI processing services: used to implement speech-to-text and AI transcription functions;

b. Cloud storage services: used for cloud storage of audio files and text content;

c. Crash analysis and performance monitoring services: used to improve App stability and performance;

d. Payment services: used to process matters related to paid subscriptions.

Article 4 Your Personal Information Rights

You may click "My Account" or "Me - Account Management" on our website or App to access, correct and update certain personal information you have provided to us.

You have the right to access and copy your personal information and to request that we modify, update, delete, object to, restrict the use of, or deactivate certain personal information about you. You may also request that we delete your personal information from blogs, community forums or other public areas under our control. In some cases, even if you request restriction of or object to our processing of your personal information, we have the right to refuse your request in accordance with law. If specific personal information cannot be deleted, we will inform you of the reason. Subject to the conditions stipulated by the competent authorities, you also have the right to request that we transfer your personal information to a designated personal information processor.

You also have the right to withdraw consent where we process your relevant personal information based on your consent.

We fully respect your personal information rights. If you wish to stop the collection of personal information, please remove the AI MindClip device from the App. The relevant functions of the AI MindClip product will then be disabled immediately. Your audio and transcription data will be stored on cloud servers on a long-term basis. You can view or manually delete such data at any time through the designated section in the App. We will not delete your data unless you choose to do so.

If you are located in the European Economic Area (EEA) or the United Kingdom, under the General Data Protection Regulation (GDPR), in addition to the rights described in Chapter IV of this Policy, you also have the following additional rights:

In addition, you have the right to exercise other corresponding personal information rights under your local data protection laws.

You may contact us directly through the contact details at the bottom of this page for the above requests. We may first ask you to verify your identity and process your request after successful verification to ensure security. We do not charge a fee for reasonable data requests, but may charge certain costs for requests that exceed a reasonable scope. We have the right to refuse data requests that require complex technical means, affect existing service systems, pose risks or losses to the lawful rights and interests of others, or are impracticable.

If you need to delete your account, please contact our customer service on the web page or click "Me - Account Management - Account deletion" in the App. Except as otherwise provided by laws and regulations, after you delete your account, we will stop providing our products and/or services to you and delete your personal information at your request. Please note that the AI MindClip App and the SwitchBot App share the same account system, and deletion of the AI MindClip App account will affect both Apps. After account deletion is completed, all audio and transcription data under your account will be permanently deleted within 30 days and cannot be recovered. For details, please refer to Article 1.6 of our User Agreement.

Article 5 Privacy Rights for California Residents

Under the California Consumer Privacy Act (CCPA), California residents have specific rights with respect to personal information we collect, use and share about them. We will not sell your personal information without providing you with notice and an opportunity to opt out.

5.1 Personal information we collect from you

For more information about the categories of personal information we have collected in the past 12 months and how we use such information, please refer to Sections 1 and 2 above.

5.2 Disclosure of personal information

We disclose your personal information to service providers for business purposes in a manner that does not constitute a "sale". For details on how we disclose data to third parties, please refer to Section 3 above. All cookies, including third-party cookies, that are not strictly necessary require prior opt-in consent from California consumers and are loaded in accordance with consumers' instructions and preferences.

As a California resident, you may exercise the following rights: after verification of your identity, the right to know any or all of the following information relating to your personal information collected and disclosed by us in the past 12 months:

You may request deletion of personal information we have collected from you, and you also have the right not to be discriminated against for exercising these rights. However, please note that exercising these rights may limit our ability to process personal information. For example, if you submit a deletion request, we may no longer be able to provide our products and services to you.

5.3 Submitting your California consumer rights request

You may submit a request through the contact details at the bottom of this page to exercise your California consumer rights. Before processing your request, we need to verify your identity, which may require you to provide additional personal information or log in to your account. In some cases, we may refuse or limit your request, especially where we cannot verify your identity, find your information in our systems, or where permitted by law.

5.4 No sale of personal information

We do not sell your personal information and do not disclose personal information to third parties for direct marketing purposes unless you first expressly consent to such disclosure.

Article 6 Protection of Children's Privacy

We do not provide services to children and do not knowingly collect or store any information relating to children under the age of 18, or the age stipulated by local law. If we become aware that someone has collected children's personal information through the website, we will take appropriate steps to delete such information. If you are the parent or legal guardian of a child under 18 and believe that your child has provided personal information to us, please contact us, and we will terminate the child's account or service and delete the personal information.

Article 7 How We Protect and Store Your Personal Information

7.1 Protection of personal information

We will spare no effort to protect your personal information. We will use various security technologies and procedures to prevent your personal information from unauthorized or accidental access, public disclosure, use, modification, damage or loss. We will take all reasonable and practicable measures, including administrative, technical and physical safeguards, to protect your personal information.

We classify and process your personal information according to its importance and sensitivity and ensure that your personal information has the highest level of security. We ensure that our employees and third-party service providers who access your personal information to provide our products and services to you strictly perform confidentiality obligations, and we regularly review our information collection and physical security measures to prevent any unauthorized access and use.

However, you should understand that communication networks are not completely secure, and therefore we cannot fully guarantee the security or integrity of any personal information transmitted by you or to you.

In any event, once a personal information breach occurs, we will handle it in a timely manner and notify the relevant regulatory authorities, or notify data subjects of the personal information breach in accordance with applicable laws, including your local data protection legislation. At the same time, once you discover any abnormality in your account, such as password tampering or unauthorized login or use by others, please notify us immediately.

7.2 Storage of personal information

We will retain your personal information in the following circumstances:

Personal information that no longer needs to be retained will be deleted in accordance with relevant laws.

The personal information we collect is stored directly in the application, on your device, and on servers provided by us or our affiliates, affiliated companies, subsidiaries or service providers, and the use of such servers is based on legal requirements and your consent.

For AI MindClip devices, audio information collected by the device will be temporarily stored locally on the device. Audio information may be uploaded to the cloud in the following two ways:

(1) Bluetooth or local network transfer: after the device establishes a Bluetooth or local network connection with the App, the audio files stored on the device will be automatically transferred to the App via Bluetooth or the local network, and the App will then transmit the audio information to the cloud server through an encrypted channel for storage and processing;

(2) Charge & Sync: when the device is charging and connected to Wi-Fi, the device may automatically upload the audio information directly to the cloud server without passing through the App.

Regardless of which upload method is used, after the relevant audio information has been uploaded, the corresponding audio files stored locally on the device will be deleted.

To implement AI transcription services for AI MindClip, audio information uploaded by you may be transmitted to third-party AI model service providers for processing in order to implement speech-to-text and related transcription functions. Third-party AI model service providers process the relevant audio information only on our behalf and according to our instructions, and will not retain the relevant data. After processing is complete, the transcription results will be returned to our cloud server and synchronized to your App so that you may view, edit, manage or delete them.

Audio information and transcription results uploaded by you will be stored on cloud servers. We will provide you with different capacities of cloud storage space according to your plan subscription, and all users have a certain amount of free storage space. Data stored on cloud servers will continue to be retained until you actively delete the relevant data.

For audio information and transcription results that you voluntarily delete, we will complete cloud deletion within a reasonable period.

We determine the retention period of personal information according to the purposes for which we collect and use personal information and relevant laws and regulations. Once the purposes of data collection and use have been completed, or after we confirm your deletion request, or after we terminate operation of the corresponding service, we will delete or anonymize your personal information, unless a longer retention period is required to comply with applicable law. Where a longer retention period is required by law, we will not further process your personal information except for the purpose of fulfilling legal responsibilities and other purposes permitted by applicable law.

Article 8 Transfer of Personal Information

8.1 Depending on your country or region, the personal information we collect may be stored and processed in facilities maintained by our companies or affiliates or service providers in Europe, the United States or other countries, or transferred to the third parties mentioned in Section III above for processing. The laws and data protection compliance requirements of these countries/regions may differ from those applicable in your country/region. Such transfers usually occur in the following scenarios:

8.2 Transfers outside the European Economic Area (EEA)

When your personal information is transferred from the EEA to a country that has not been recognized by the European Commission as providing an "adequate" level of protection, we undertake to comply with all applicable legal requirements relating to personal information processing and transfer, adopt appropriate cross-border safeguards, protect the security of your personal information, and ensure that it receives a level of protection equivalent to that within the EEA. The safeguards we adopt include but are not limited to:

8.3 Where required by relevant laws, especially where other appropriate safeguards are absent and the processing is not necessary for contract performance, we will clearly inform you before the transfer of the potential risks of the transfer and obtain your explicit consent to the specific transfer. You have the right to withdraw such consent at any time, but this will not affect the lawfulness of transfer activities conducted based on consent before withdrawal.

Article 9 Updates

We may update this Policy from time to time. If we make any changes, we will revise the date at the top of this Policy. If you continue to use our products and/or services after the revised Policy takes effect, it means that you have read, understood and agreed to the latest version of this Policy.

If our specific products or services cease, we will notify you in advance by notice, announcement, email or other means, and process your personal information in accordance with this Policy or relevant documents. If we permanently cease operations, this Policy will become invalid and we will process all your personal information in accordance with applicable regulations.

Article 10 Contact

If you have any questions, comments or requests regarding your personal information, privacy policy or data management, especially if you wish to withdraw your consent, please submit a request through https://support.switch-bot.com, or contact our Data Protection Officer (DPO) by email at privacy@switch-bot.com. We will respond within 30 business days or within the period stipulated by law. If you are dissatisfied with our response, especially if our information processing harms your lawful rights and interests, you may lodge a complaint with the local competent authority.

Appendix: Table of Purposes of Use of Personal Information and Legal Bases for Processing: