Privacy Policy

Effective Date: 2025.08.12
MFG Garden LLC — Neocity smart Mobile Application

MFG Garden LLC is committed to protecting your privacy. This Privacy Policy ("Policy") describes how we collect, use, store, share and transfer Personal Data when you use our Products (collectively, the “Products”), including the Neocity smart Mobile Application.

Definition

Personal Data means information that can be used to identify an individual or reflect the activity of an individual. Personal Sensitive Data includes biometric information, communications content, health information, transaction information and precise location. We will obtain explicit consent before collecting sensitive data.

Smart Devices refers to networked devices such as smart home appliances and wearables. Apps refers to mobile applications developed by MFG Garden LLC that control Smart Devices and connect to supplier IoT platforms.

What Personal Data Do We Collect

We collect Personal Data necessary to provide our services. If you do not provide required Personal Data, some services may not be available.

1. Information You Voluntarily Provide

  • Registered Account Data: name, email address, phone number, username, login credentials, nickname, profile picture, country code, language preference, time zone.
  • Non-registered Account / "Try Now" mode: you may use the App without creating an account. We collect limited data (time of entry, OS, purpose-authorized data). Data from Try Now mode will be removed when you exit.
  • Feedback: when you submit feedback we may collect your email, phone and feedback content to address issues.

Information based on additional functions

If you consent to additional functions, we may collect data to enable them. You can decline and still use basic Services.

  1. Location: real-time or approximate location for features like automation scenarios and geo-fencing. Location may be shared with Google Maps when you enable geo-fence features.
  2. Camera: used when you actively scan codes or record video. We only capture data while you use the camera feature.
  3. Photo/Video Uploads: to update avatars or report device issues; we will not analyze photos beyond troubleshooting.
  4. Microphone: collected only when you actively use voice features (e.g., voice assistant).
  5. Storage (Android): read/write access to support stable App operation, access crash logs and files when granted.
  6. Notifications: used to send alerts and messages about purchased services or device status.
  7. Alert Window: used to display real-time camera images in a separate window when enabled.
  8. Bluetooth: used for device discovery, configuration and control when enabled.
  9. HomeKit (iOS): used to discover and configure HomeKit devices when enabled.
  10. HealthKit (iOS): used to exchange health-related data (weight, steps, swimming) with HealthKit when enabled.

Turning off a permission withdraws that specific authorization; previously-collected data is unaffected unless you request deletion.

2. Information We Collect Automatically

  • Mobile Device Information: device model, IP address, OS type/version, app version, push identifier, logs, network information, installed applications where necessary for security.
  • Usage Data: visits, clicks, downloads, messages and other interaction metrics.
  • Log Information: access time, language setting, OS version, IP for troubleshooting and improving service quality.

3. Smart Devices Related Information

  • Basic Device Info: device name, device ID, online status, activation time, firmware version.
  • Connection Info: Wi‑Fi details, device MAC address where needed for connectivity.
  • Device-reported Data: data produced by the Smart Device depending on the device type.

Purposes and Legal Basis for Processing

  • Provide Services: process account, device and location data to deliver requested services (contract performance).
  • Improve Services: analyze usage, ensure safety, and prevent fraud (contract performance).
  • Non-marketing Communication: administrative notices and alerts related to services (contract performance).
  • Data Analysis: analyze product usage to improve experience — based on your consent; you may opt-out in privacy settings.
  • Marketing & Personalization: personalized recommendations and advertising — based on your consent; opt-out available in App privacy settings.
  • Legal Compliance: disclose data to comply with laws, enforce agreements, protect rights and public safety.

Who Do We Share Personal Data With?

We only share Personal Data as described:

  • Third‑party service providers (hosting, analytics, payments, infrastructure, customer support, email delivery).
  • Customers and business partners that provide your Smart Devices and related networks/systems.
  • Subsidiaries and affiliates for business operations under confidentiality safeguards.
  • In the event of corporate changes (merger, sale, bankruptcy) we may transfer Personal Data; we will notify you of changes.
  • Where required to comply with law, protect rights, or address security or fraud concerns.

International Transfer of Information

To operate our services, we may transfer, store and process your Personal Data in jurisdictions other than your residence. We will adopt safeguards such as EU Standard Contractual Clauses where required. Contact us for details about safeguards in place.

Your Rights Relating to Your Personal Data

You may exercise the following rights free of charge. We aim to respond within 30 days and may ask you to verify your identity.

  • Request access to Personal Data (App: My → Setting → Privacy Settings → Personal Data Export).
  • Request correction of inaccurate data (account changes and personal info pages described in App).
  • Request deletion (App: My → Setting → Account and Security → Delete Account).
  • Request restriction of processing or transfer of Personal Data (via App FAQ/Feedback or email).
  • Opt-out of marketing, data analysis or personalization via App privacy settings.

Withdrawing consent may limit certain features and services. To unbind third‑party services (e.g., health platforms), please unbind on the third‑party platform as well.

Security Measures

We use commercially reasonable technical, administrative and physical safeguards to protect Personal Data including encryption in transit and at rest, access controls, data isolation, and audit logging. If you suspect compromise of your account, contact us at gerelt@neocity.mn.

Data Retention

We retain Personal Data only as long as necessary for the purposes described or as required by law. Personal Data will be deleted when you request removal, and where technical limitations prevent immediate deletion we will prevent further use of the data.

Children's Privacy

Services are not directed to children under 13 (or any higher age required by local law). We do not knowingly collect Personal Data from children without parental consent. If we learn we collected such data without consent we will remove it.

Changes to this Privacy Policy

We may update this Policy. Material changes will be notified by email or an in‑app notice prior to taking effect. Please review this page periodically.

Contact Us

If you have questions about this Policy, contact:

MFG Garden LLC
3rd floor, Art House Center,
1 Subdistrict, Chingeltei District,
Ulaanbaatar, Mongolia
Email: gerelt@neocity.mn