Trainco ESL App Privacy Policy

Last Updated: 2026

1. Introduction

Welcome to the Trainco ESL App (hereinafter referred to as "this App" or "we"). We highly value the protection of user privacy and personal information security. This Privacy Policy aims to explain how we collect, use, store, share, and protect your personal information, as well as the rights you have.

Please read and fully understand this Privacy Policy before using this App. Once you start using this App, it means that you have fully understood and agreed to all the contents of this Privacy Policy.

App Name: Trainco ESL
App Type: Enterprise Electronic Shelf Label Management Tool Application
Developer: Trainco
Bundle ID (iOS): com.trainco.esl
Package Name (Android): com.trainco.esl

Important Notice: B2B Enterprise Application

This App is a supporting management tool specifically designed for enterprise customers who have purchased our electronic shelf label hardware products and is not open for public registration.

This Privacy Policy applies to:

  1. Enterprise Customers: As data controllers, they have primary responsibility for the collection and use of employee data
  2. Enterprise Employee Users: As end users, they have corresponding rights to personal information
  3. The Company: As data processor and technical service provider, processes data in accordance with this policy and agreements with enterprise customers

2. Information We Collect

2.1 Information You Actively Provide

2.1.1 Account Information

Note:

2.2 Automatically Collected Information

2.2.1 Device Information

2.2.2 Network Information

2.2.3 App Usage Information


3. Device Permissions Description

This App requires the following device permissions to implement corresponding functions. We promise that all permissions will only be used after your explicit authorization and only for implementing the corresponding business functions.

3.1 Required Permissions

3.1.1 Camera Permission (CAMERA)

Includes the following specific permissions:

Purpose: Connect and manage ESL devices to perform the following operations:

Note:

3.1.3 NFC Permission (NFC)

3.1.4 Location Permission (ACCESS_FINE_LOCATION)

3.1.5 Network Permission (INTERNET)

3.2 Optional Permissions

3.2.1 Storage Permissions (READ_EXTERNAL_STORAGE / WRITE_EXTERNAL_STORAGE)

3.2.2 Microphone Permission (RECORD_AUDIO)

3.2.3 Vibration Permission (VIBRATE)

3.2.4 Overlay Permission (SYSTEM_ALERT_WINDOW)

3.3 Permission Usage Principles

  1. Minimization Principle: We only request permissions necessary to implement business functions
  2. Transparency Principle: We explain the purpose of permissions when you first use related functions
  3. Authorization Principle: We will only use permissions after obtaining your explicit consent
  4. Revocable: You can revoke granted permissions at any time in system settings
  5. Isolated Usage: Different permissions are only used in corresponding functions and will not be cross-used

4. Use of Information

4.1 Purpose of Use

We collect and use your personal information only for the following purposes:

4.1.1 Provide Core Services

Enterprise Customer Responsibilities:

4.1.2 Improve User Experience

4.1.3 Security Protection

4.1.4 Technical Support

4.2 Data Encryption

4.2.1 Transmission Encryption

4.2.2 Storage Encryption


5. Information Storage

5.1 Storage Location

5.2 Storage Period

5.3 Storage Security


6. Information Sharing, Transfer, and Public Disclosure

6.1 Sharing

6.1.1 Sharing Within the Enterprise

6.1.2 Sharing With Third Parties

We will not share your personal information with third parties, unless:

  1. Enterprise Customer Authorization: With explicit authorization from the enterprise customer

  2. Legal Requirements: According to laws and regulations, legal procedures, litigation, or mandatory requirements of government authorities

  3. Business Partners: Share necessary information with the following types of partners only to achieve the purposes stated in this Privacy Policy:

    • Cloud service providers (such as Expo, etc.): For app distribution and updates
    • Technical service providers: For app performance monitoring and error tracking

Note:

6.2 Transfer

We will not transfer your personal information to any company, organization, or individual, unless:

  1. We have obtained your explicit consent
  2. In the event of merger, acquisition, or bankruptcy liquidation, we will require the new company holding your personal information to continue to be bound by this Privacy Policy

6.3 Public Disclosure

We will not publicly disclose your personal information, unless:

  1. We have obtained your explicit consent
  2. Based on laws and regulations, legal procedures, litigation, or requirements of government authorities

7. Third-Party Services

This App uses the following third-party services and SDKs:

7.1 Expo Service

7.2 Other Technical Frameworks

This App uses the following open-source technical frameworks (which do not collect personal information):

Note: These frameworks and libraries run locally and will not send your personal information externally.


8. Your Rights

According to relevant laws and regulations, you have the following rights regarding your personal information:

8.1 Employee User Rights

8.1.1 Right of Access

You have the right to access your personal information, except as provided by laws and regulations. You can view your account information through the in-app settings.

8.1.2 Right of Correction

When you find that personal information is incorrect, you have the right to request corrections or supplements. You can modify some information in the app or contact the enterprise administrator for correction.

8.1.3 Right of Deletion

In the following circumstances, you can request deletion of personal information:

Note: Since this App account is created and managed by the enterprise customer, some rights may need to be exercised through your enterprise administrator.

You can withdraw your previously granted authorization consent (such as system permissions) at any time. After withdrawing consent, the corresponding function will be unavailable.

Exercise Methods:

8.1.5 Account Management

8.2 Enterprise Customer Rights

8.2.1 Data Access and Export

Enterprise customers have the right to access and export the enterprise's business data through the admin portal.

8.2.2 Employee Account Management

Enterprise customers have the right to create, modify, deactivate, and delete employee accounts.

8.2.3 Data Deletion

When enterprise customers terminate service, they have the right to request deletion of enterprise data. We will process it according to the service agreement.

8.2.4 Data Portability

Enterprise customers have the right to export business data during the service period or when terminating service.

8.3 Special Instructions on Rights Exercise

Due to the B2B nature of this App, the exercise of certain rights involves the relationship between enterprise customers and employee users:


9. Protection of Minors

9.1 Usage Restrictions

This App is a B2B tool application for enterprise customers and is not designed for minors. We do not actively collect personal information of minors.

9.2 Enterprise Customer Responsibilities

Enterprise customers should ensure that:

9.3 Guardian Supervision

If a minor's guardian discovers that a minor is using this App, please contact the enterprise customer and us in a timely manner.

9.4 Information Deletion

If we discover that we have collected personal information of minors without obtaining verifiable guardian consent, we will delete the relevant information as soon as possible.


10. Changes to Privacy Policy

10.1 Update Notification

We may revise this Privacy Policy from time to time. When the Privacy Policy changes:

10.2 Definition of Significant Changes

The following situations are considered significant changes:

10.3 Continued Use

If you continue to use our services, it means that you agree to accept the revised Privacy Policy.


11. Data Security Measures

11.1 Technical Measures

11.2 Management Measures

11.3 Security Incident Response

In the event of a personal information security incident, we will:

  1. Immediately activate the emergency plan
  2. Promptly inform you of the basic situation of the incident, impact, disposal measures, etc.
  3. Report to regulatory authorities as required by laws and regulations

12. Scope of Application

This Privacy Policy applies to:

This Privacy Policy does not apply to:


13. Contact Us

13.1 Employee Users

If you are an employee user and encounter the following situations:

13.2 Enterprise Customers

If you are an enterprise customer, you can contact us in the following ways:

App Name: Trainco ESL
Customer Service Phone: +86-15617676048 Customer Service Email: triancoesl@gmail.com Working Hours: Working days 08:30-17:30

13.3 Response Time

We will respond to your request within 15 business days. Urgent matters will be prioritized.

13.4 Data Protection Officer

For major matters related to data protection, you can contact our Data Protection Officer:


14. Applicable Law and Dispute Resolution

The interpretation, validity, and execution of this Privacy Policy shall be governed by the laws of the People's Republic of China. If any dispute arises regarding the content or execution of this Privacy Policy, the parties shall resolve it through friendly negotiation; if negotiation fails, either party may file a lawsuit with the people's court with jurisdiction where the company is located.


Appendix: Detailed Permission Description Table

Permission NameAndroid Permission IDiOS Permission DescriptionPurposeRequired
CameraCAMERANSCameraUsageDescriptionScan barcodesYes
BluetoothBLUETOOTHNSBluetoothAlwaysUsageDescriptionConnect to ESLsYes
Bluetooth AdminBLUETOOTH_ADMIN-Manage Bluetooth connectionsYes
Bluetooth ScanBLUETOOTH_SCAN-Scan Bluetooth devicesYes
Bluetooth ConnectBLUETOOTH_CONNECT-Connect Bluetooth devicesYes
LocationACCESS_FINE_LOCATION-Required for Bluetooth scan (Android)Yes
NFCNFCNFCReaderUsageDescriptionRead NFC tagsYes
InternetINTERNET-Network communicationYes
Read StorageREAD_EXTERNAL_STORAGE-Read cache filesNo
Write StorageWRITE_EXTERNAL_STORAGE-Write cache filesNo
MicrophoneRECORD_AUDIONSMicrophoneUsageDescriptionAudio feedbackNo
VibrateVIBRATE-Operation feedbackNo
OverlaySYSTEM_ALERT_WINDOW-Display notificationsNo

Privacy Policy Version: v1.0
Effective Date: 2026-01-15