Privacy Policy — 22 System

22 System by Bocci · Mobile app. Effective date: [DATE]

Controller: Bocci Design & Manufacturing Inc. ("Bocci", "we"), [REGISTERED ADDRESS — to confirm]. Privacy / data-rights contact: service@22system.com.

1. Scope

This policy explains how the 22 System mobile app ("App") collects, uses, and shares personal information when you use it to set up and control Bocci smart switches and related devices. It covers the App only. Purchases on 22system.com are governed by the separate store Privacy Policy at 22system.com/pages/privacy-policy.

2. Information we collect

• Account data: email and/or phone, and authentication data, to create and secure your account (provided through our technology provider, Tuya).
• Device & usage data: device identifiers, device names, on/off and status data (data points), firmware version, online/offline status, pairing/control activity.
• Network & technical data: IP address, Wi-Fi network name (SSID) used during pairing, OS/app version, crash and diagnostic logs.
• Approximate location: required by the OS to scan for nearby devices over Bluetooth/Wi-Fi during pairing — used for pairing, not to track you.
• Push token: to deliver notifications you enable.
• Analytics & usage data: with your consent where required, app-usage events and crash diagnostics via third-party analytics providers to improve the App.
• Camera: only if you scan a QR code to add a device; images are not stored by us for that purpose.

We do not intentionally collect special-category data, and the App is not directed to children under [13/16, per region].

3. How we use information

To create/secure accounts; pair and control your devices; sync settings; send notifications you enable; provide support; maintain security and prevent abuse; diagnose and improve reliability; and comply with legal obligations.

4. How information is shared

• Tuya (processor): our IoT platform provider stores and processes account, device, and network data on our behalf. Data for this App is processed in the Western America data center.
• Platform services: Apple (APNs) and Google (FCM) for push; [map provider] if maps are used.
• Analytics providers: [e.g., Firebase / Google Analytics] for app-usage and crash analytics, used with your consent where required.
• iOS tracking: where tracking is used for analytics/ads, the App requests permission via Apple's App Tracking Transparency (ATT) prompt before tracking.
• Legal/safety: where required by law or to protect rights and safety.
• U.S. state laws: sharing with analytics/ads partners may be a "sale" or "sharing" under certain U.S. state laws; you can opt out via [App Settings → Privacy] or a Global Privacy Control signal. We do not otherwise sell your personal information.

5. Data location, retention, and security

Data is processed in the data center noted above. We retain personal data while your account is active and as needed for the purposes above or as required by law, then delete or anonymize it. We use encryption in transit and other safeguards; no method is 100% secure.

6. Your rights

Depending on your region (including GDPR (EU/EEA), UK GDPR, CCPA/CPRA (California), and PIPEDA (Canada)), you may request access, correction, deletion, portability, or restriction, and may object to certain processing. You can delete your account and associated data from within the App (Settings → Account → Delete Account), via 22system.com/delete-account, or by contacting service@22system.com. EU/UK representative: [Bocci's appointed EU/UK representative — name & address to fill in].

7. International transfers

Where data is transferred across borders, we rely on appropriate safeguards such as [Standard Contractual Clauses / other mechanism].

8. Changes

We will post updates here and, where required, notify you in-app. Continued use after changes means you accept the updated policy.

9. Contact

Privacy / data requests: service@22system.com · Technical support: support@22system.com · [Postal address — to confirm] · EU/UK representative: [name & address to fill in]