Privacy Policy for Owy's Fun

Privacy Policy for Owy's Fun

Last Updated: January 1, 2026

Effective Date: January 1, 2026

1. Introduction

Xito Technologies ("Company," "we," "us," or "our") operates the Owy's Fun mobile application (the "App"), the website located at www.owysfun.com, and associated hardware connectivity services (collectively, the "Service").

We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at service@owys.fun.

This comprehensive Privacy Policy describes our policies and procedures on the collection, use, disclosure, and protection of your information when you use the Service. It also tells you about your privacy rights and how the law protects you. We recognize the sensitive nature of the data we collect, particularly as it relates to children and physical health. As such, we have adopted a "Privacy by Design" and "Privacy by Default" philosophy, ensuring that data protection is integral to our technology and business practices.

BY ACCESSING OR USING THE SERVICE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION.

2. Interpretation and Definitions

2.1 Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

2.2 Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service (if applicable).
  • Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
  • Application means the software program provided by the Company downloaded by You on any electronic device, named Owy's Fun.
  • Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Xito Technologies, 123 Innovation Drive, Tech Park, Shenzhen, Guangdong, China.
  • Country refers to: China, and for purposes of GDPR compliance, refers to the jurisdiction of the user.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Application and the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

3. Collecting and Using Your Personal Data

3.1 Types of Data Collected

3.1.1 Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address (only for support or optional newsletter opt-in)
  • First name and last name (optional for profile creation)
  • Phone number (only for hardware warranty registration)
  • Address, State, Province, ZIP/Postal code, City (for hardware shipping)

3.1.2 Usage Data

Usage Data is collected automatically when using the Service.

  • Mobile Device Data: When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
  • Log Files: We may collect log information about Your use of the App, such as the time and duration of your sessions, search terms entered, and crash reports.

3.1.3 Information form the Use of the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Information regarding your location: We use Bluetooth Low Energy (BLE) technology to connect to smart bikes. On some operating systems (specifically Android), accessing Bluetooth requires Location Services permissions. We do not use this data to track your physical movements or store your location history.
  • Pictures and other information from your Device's camera and photo library: Used strictly for QR code scanning for device pairing or AR game features. Images are processed locally and not uploaded to our servers.

3.1.4 Health and Fitness Data

To provide the "Educational Fitness" experience, the App processes:

  • Cycling Metrics: Cadence (RPM), Speed (km/h or mph), Power (Watts), and Resistance Levels.
  • Physical Metrics: Estimated Calories burned, Distance traveled, and Heart Rate (if a compatible HRM is connected).
  • Processing: This data is primarily processed and stored locally on your device to generate real-time game feedback.

3.2 Tracking Technologies and Cookies

We use Cookies (on our website) and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

  • Cookies or Browser Cookies. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent.
  • Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about your preferences or your activity on our Service.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics.

If You are from the European Economic Area (EEA), Xito Technologies's legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process Your Personal Data because:

  • Contractual Necessity: We need to perform a contract with You (e.g., providing the App's core functionality).
  • Permission: You have given us permission to do so (e.g., opting into newsletters).
  • Legitimate Interests: The processing is in our legitimate interests and it's not overridden by your rights (e.g., improving App security, fraud prevention, analytics).
  • Legal Compliance: To comply with the law.

5. Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  1. To provide and maintain our Service: including to monitor the usage of our Service.
  2. To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  3. For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  4. To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  5. To provide You with news: special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  6. To manage Your requests: To attend and manage Your requests to Us.
  7. For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
  8. For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

6. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

  • Personal Data: We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
  • Usage Data: We will retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
  • Local Data: Data stored locally on your device (Game saves, High scores) resides there indefinitely until You uninstall the App or clear the device storage.

7. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information. We utilize Standard Contractual Clauses (SCCs) approved by the European Commission for data transfers from the EEA to other countries.

8. Disclosure of Your Personal Data

8.1 Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

8.2 Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

9. Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

We implement the following security measures:

  • Encryption: All data in transit is encrypted via SSL/TLS protocols.
  • Access Control: Access to our servers and databases is restricted to authorized personnel with a need-to-know basis.
  • Minimization: We only collect data that is absolutely necessary for the App's function.

10. Children's Privacy (Detailed COPPA/GDPR-K)

Our Service addresses Under 13s (in US) and minors under 16 (in EU). We adhere to the Children's Online Privacy Protection Act (COPPA) and General Data Protection Regulation (GDPR).

  1. No Collection: We do not knowingly collect personally identifiable information from anyone under the age of 13.
  2. Parental Gate: We use a neutral age-gate or "Parental Gate" to restrict access to external links and commerce.
  3. Removal: If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

11. Your Data Protection Rights under GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights. You have the right under this Privacy Policy, and by law if You are within the EU, to:

  • Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You.
  • Request correction of the Personal Data that We hold about You. You have the right to have any incomplete or inaccurate information We hold about You corrected.
  • Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
  • Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
  • Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
  • Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

12. California Residents Specific Privacy Rights (CCPA / CPRA)

This section provides additional details for California residents under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

12.1 Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information:

  • Identifiers: Device ID, IP address.
  • Internet/Network Activity: Interaction with our App.
  • Note: We have NOT collected "Sensitive Personal Information" such as Social Security Numbers, precise geolocation, or racial origin.

12.2 Your Rights under CCPA

  • Right to Know: You may request that we disclose what personal information we have collected, used, shared, or sold about you, and why we collected, used, shared, or sold that information.
  • Right to Delete: You may request the deletion of your personal information, subject to certain exceptions.
  • Right to Opt-Out of Sale: We do not sell your personal information. Therefore, we do not provide an opt-out mechanism for the sale of personal information.
  • Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise these rights, email us at service@owys.fun.

12.3 "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

14. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

15. Contact Us

If you have any questions about this Privacy Policy, You can contact us: