PRIVACY POLICY
Version: v1.0
Effective Date: 2026-03-20
Last Updated: 2026-03-20
1. Introduction
This Privacy Policy explains how personal data is collected, used, disclosed, and protected when you use the Fubao Smart Healthcare and Companion Robot, mobile application, and related services (collectively, the "Service").
This Policy applies globally, subject to applicable Regional Addenda.
2. Definitions
For the purposes of this Privacy Policy:
  1. "Company", "we", "us", or "our"
    2. means Zhejiang Fubao Intelligence Technology Co., Ltd., a company incorporated in the People’s Republic of China, with its registered address at:
    Building 6, No.42 Tianhe Road, Donghu Subdistrict, Linping District, Hangzhou City, Zhejiang Province, China.
    Contact email: ytm@fubaorobot.com
    For purposes of applicable data protection laws, the Company acts as the Data Controller unless otherwise specified in a Regional Addendum.
  2. "User", "you", or "your"
    3. means any individual who accesses or uses the Service.
  3. "Device"
    4. means the Smart Healthcare Robot hardware and any compatible health testing equipment connected to it.
  4. "Application" or "App"
    5. means the mobile software application provided by the Company.
  5. "Service"
    6. means collectively the Device, Application, cloud infrastructure, AI interpretation tools, communication functions, and related features.
  6. "Personal Data"
    7. means any information relating to an identified or identifiable individual.
  7. "Health Data"
    8. means Personal Data relating to a User’s physical or mental health condition, including but not limited to temperature, blood pressure, blood oxygen, blood glucose, uric acid, ECG readings, medical history, medication records, and uploaded hospital records.
  8. "Sensitive Personal Data"
    9. means Personal Data that is considered sensitive under applicable law, including Health Data where applicable.
  9. "AI Report", "AI Analysis", or "AI Interpretation"
    10. means a user-initiated automated health interpretation report generated upon the User clicking the "Generate AI Report" function.
  10. "Regional Addendum"
    11. means jurisdiction-specific supplementary provisions applicable based on the User’s location.
3. Categories of Personal Data We Collect
We collect Personal Data from the following sources:
3.1 Information You Provide Directly
This includes Personal Data that you voluntarily provide when creating an account, using the Service, uploading information, or interacting with us.
(a) Identity Information
  1. Name
  2. Gender
  3. Date of birth
  4. ID number (if voluntarily provided)
(b) Contact Information
  1. Phone number (AES encrypted)/li>
  2. Email address
(c) Profile Information
  1. Profile photo (avatar)
  2. Nickname
(d) Health and Medical Information Entered by You
  1. Manually entered health measurements
  2. Health history (family and personal)
  3. Medication records
  4. Blood type
  5. Height and weight
  6. Hospital medical records voluntarily uploaded
(e) AI-Related Actions
  1. Requests to generate AI Reports
  2. User-submitted inputs used for AI interpretation
3.2 Information Obtained from Third Parties
We may receive Personal Data from third parties where authorized by you or where necessary to provide the Service.
(a) Connected Health Devices
  1. Temperature readings
  2. Blood pressure
  3. Blood oxygen (SpO2)
  4. Blood glucose
  5. Uric acid
  6. ECG readings
Such data is transmitted from compatible health testing equipment connected to the Device.
(b) Authorized Caregivers or Family Members
Where applicable, information provided by caregivers authorized by the User.
(c) Distribution and Activation Partners
Basic activation or purchase-related information provided by authorized distributors or resellers.
(d) Service Providers
Limited Personal Data processed by hosting providers, cloud service providers, and technical support vendors under contractual safeguards.
3.3 Information Automatically Collected During Use of the Service
When you use the Device or Application, certain information is automatically collected.
(a) Technical and Device Data
  1. Device model
  2. Serial number
  3. Application version
  4. Operating system
  5. Log files
(b) Usage Data
  1. System activity records
  2. Feature interaction data
  3. AI report generation timestamps
(c) Communication Metadata
  1. Call time
  2. Call duration
  3. Contact identifiers
We do not record audio or video call content unless required by applicable law.
(d) Network Information
  1. IP address
  2. Time zone
We collect only the Personal Data that is necessary to provide and improve the Service in accordance with applicable data protection laws.
4. How We Use Personal Data
We use Personal Data for:
  1. Providing health testing functionality
  2. Generating AI Reports upon request
  3. Maintaining health records
  4. Enabling reminders and medication logs
  5. Enabling audio and video communication
  6. System maintenance and security
  7. Compliance with legal obligations
We do NOT:
  1. Automatically generate AI reports
  2. Use Health Data for AI training without explicit consent
  3. Sell Personal Data
  4. Use Health Data for targeted advertising
5. Legal Bases for Processing
Depending on jurisdiction, processing is based on:
  1. User consent
  2. Performance of contract
  3. Legal obligation
  4. Legitimate interests (security, fraud prevention)
Additional details are provided in applicable Regional Addenda.
6. Data Retention
We retain Personal Data:
  1. While the User account remains active
  2. As necessary to provide the Service
  3. As required by law
Users may request deletion, subject to legal retention requirements.
7. Data Security
We implement technical and organizational safeguards including:
  1. Encryption (including AES encryption of phone numbers)
  2. Access controls
  3. Secure server infrastructure
  4. Security monitoring
No system is completely secure.
8. Cross-Border Transfers
As the Company is based in China, Personal Data may be processed in China or other jurisdictions.
Where required, we implement appropriate safeguards including:
  1. Standard Contractual Clauses (SCC)
  2. Contractual safeguards
  3. Additional technical measures
Further details are provided in Regional Addenda.
9. Your Rights
Depending on applicable law, Users may have rights to:
  1. Access Personal Data
  2. Correct inaccuracies
  3. Delete data
  4. Restrict processing
  5. Withdraw consent
  6. Data portability
  7. Object to certain processing
Requests may be submitted to: ytm@fubaorobot.com
10. Children’s Privacy
The Service is not directed to children without parental supervision.
We do not knowingly collect children’s Personal Data where prohibited by law.
11. Third-Party Devices
Some health testing equipment may be manufactured by third-party suppliers.
We are not responsible for third-party privacy practices unless explicitly stated.
12. Changes to This Policy
We may update this Privacy Policy.
Material changes may require renewed consent where required by law.
13. Regional Addenda
This Privacy Policy is supplemented by Regional Addenda applicable to Users based on their jurisdiction.
🇪🇺 ADDENDUM A – EU/EEA
Applicable Law:
General Data Protection Regulation
Health Data is processed based on:
  1. Article 6(1)(a) – Consent
  2. Article 9(2)(a) – Explicit consent
Users may lodge complaints with their local supervisory authority.
The Company intends to appoint an EU Representative prior to commercial launch within the European Union.
🇺🇸 ADDENDUM B – CALIFORNIA
Applicable Law:
California Consumer Privacy Act
California Privacy Rights Act
We do not sell or share Personal Data.
California residents may:
  1. Access
  2. Delete
  3. Correct
  4. Limit use of Sensitive Personal Data
🇦🇺 ADDENDUM C – AUSTRALIA
We comply with the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs).
🇦🇪 ADDENDUM D – UAE / MIDDLE EAST
We process Personal Data in accordance with applicable regional data protection laws.