Privacy Policy of AvaEye

Introduction

AvaEye  highly emphasizes protection of users’ personal information and privacy, and to this end we established this Privacy Policy to inform users how their information is collected, used, shared, stored and protected. With this Privacy Policy, you will get to know the ways of processing your personal information by us. This Privacy Policy is closely related to the products and/or services of AvaEye  you use. Please make sure you thoroughly read and fully understand this Privacy Policy before using all products and/or services of AvaEye, and accordingly make the choices you think are appropriate. You should stop using any products and/or services of AvaEye immediately if you disagree with any content herein. The use of any product and/or service of AvaEye  by you will be considered that you agree and fully understand the entire content hereof ("AvaEye" and "we/us" referred to hereinafter all represent "AvaEye" and its Partners).

If you have any questions, comments or suggestions regarding this Privacy Policy or your personal information, please contact us by sending an email to avaeyeapp@gmail.com.

This Policy will help you understand the following:

I. Scope of Information Collection

II. Ways of Information Collection

III. Use of Information

IV. Sharing of Information

V. Storage and Protection of Information

VI. Your Rights

VII. Third Party Services

VIII. Privacy of Minors

IX. Contact Us

X. Revision of Privacy Policy

I. Scope of Information Collection

Personal information and non-personal information of the user, resident and yourself may be collected by us when products and/or services of AvaEye are used by you.

Personal information refers to any information that relates to certain natural person and that may be used to identify certain natural person when combined with other information, including but not limited to name, gender, ID number, date of birth, domicile, telephone number, E-mail address, mailing address, and personal video content.

Non-personal information refers to, other than personal information, data that no direct connection to any specific person may be determined by solely relying on such data, such as profession, language, zip code, area code, serial number, URL, automatically recorded access data (e.g., type of browser, domain name, times of web browsing, referral webpage, IP address, and page navigation), unique product identifier of the product and your mobile device, video content with no personal information, the country and time zone where a product is connected, geographical location, identification of mobile phone operator, device software platform, and hardware information.

II. Ways of Information Collection

(I) AvaEye collects your personal information via the following ways:

1.1 When you log in an account and activate a product of AvaEye:

When you create an account in order to utilize services of AvaEye or register an account in order to access and view online videos, you would agree to provide your personal information, and we will collect such information as your user name, password, E-mail address and mobile phone number information. Mobile phone numbers are collected by us to meet the requirements of the network real-name system of relevant laws and regulations. In addition, when you install and activate a product, if such product needs to be connected to services of AvaEye and be bound with your account, we may ask you to provide some basic product information of uniqueness, such as the name, verification code, and serial number of the product. If you refuse to provide such information, you may be unable to use our products and/or services properly.

1.2 When you log in to the APP account through which AvaEye provides services, we will collect your following information:

Device type, user name, quantity, and device login mode; APP usage time, that is, time while the APP is on foreground; the number of live views played at one time (record multiple times and report the maximum value); current mobile phone model, mobile phone operating system and operating system version, as well as network information of current mobile phone connection.

1.3 When you save videos with services of AvaEye:

If you want to save certain content with services of AvaEye, such as video clips, live streaming, images (user content) and message alerts, we will collect the video screenshots taken by your camera and push the screenshots to you so that you can save user content. You can turn off this function through your account settings.

1.4 When you use the message alert function, we may need to collect the unique characteristic value of your Client (such as the unique value generated based on the IMEI or UDID of the device) in order to provide you with accurate alarm message push. Refusing to provide such information will only prevent you from using the alarm subscription function, but will not affect your normal use of other functions. In addition, you can choose to turn off the function and clear the unique characteristic value of your Client.

1.5 When you use the device addition function, we may need to collect the serial number, registration code, password, model and Client Wi-Fi information of your device for network configuration and binding. Refusing to provide such information will only prevent you from adding devices.

1.6 When you use our device access service, in order to ensure your normal use of our device access service, we will collect the model, unique identifier, IP address, MAC address, software version number, ways and types of access network, latitude (such as device support) and operation record information of your device, which are the basic information that shall be collected to provide services. If you fail to provide such information, you may be unable to use our services properly.

1.7 When you use the real-time preview function, we may need to collect the serial number, IP, port information and video stream information of your device, in order to provide you with the real-time stream of the device. Refusing to provide such information will only prevent you from using the real-time preview function, but will not affect your normal use of other functions.

1.8 When you use the analysis, comparison function and alarm service based on user reference information (including face/human shape recognition, license plate/vehicle recognition, fingerprint unlocking), you need to pre-enter the reference information of face image, license plate information and fingerprint. Refusing to provide such information will only prevent you from using the relevant analysis, comparison function and alarm service, but will not affect your normal use of other functions.

1.9 When you use the device sharing function, we may need to collect your device serial number, your nickname, and the user name of the person being shared, in order to share your device with others. Refusing to provide such information will only prevent you from using the sharing function, but will not affect your normal use of other functions.

1.10 When you use the related functions of device operation control, we may need to collect the serial number, status and operation behavior of your device, in order to modify the device status and control the device. Refusing to provide such information will only prevent you from modifying the device status and device configuration, but will not affect your normal use of other functions.

1.11 When you contact us for support:

When you reply to an email from us, contact us for after-sales services, or use our user support tools, we need to collect your name, contact phone/email, information of your employer, device use information, device barcode and device login account to provide support for you, and use your account information to verify your identity and confirm your product. If you fail to provide such information, we will be unable to provide support services for you. At the same time, we may record the telephone communication with you, so as to provide after-sales services for you accurately.

1.11.1 If you are required to sign the remote access consent certificate, we will collect your manual signature or employer seal.

1.11.2 When your face recognition terminal device forgets the password and needs to regenerate a new password, we will collect your photo with ID card and ID card information, and your manual signature on the disclaimer. We need to check such information to determine whether you are the current legal user of the product as far as possible, so as to decide whether to accept your application.

1.12 When you appear on specific occasions where audio/video collection devices of AvaEye are installed, it is possible that your personal information will be collected by us. You can prevent personal information from being collected by related devices by leaving aforementioned specific occasions.

(II) AvaEye collects your non-personal information via the following ways:

2.1 When you use services of AvaEye to help us understand your using behavior, improve services of AvaEye, and provide after-sales service for you:

2.1.1 When you use services of AvaEye, we will collect non-personal information as per industrial standards generally. We collect such information for the purpose of bringing you with better experience, preventing misuse, and making sure that our services can be used normally. We may also record some adjustments made by you to products with services of AvaEye. Non-personal information collected by us will be stored together with information collected by products directly. Please refer to the manual from your mobile service provider or the manufacturer of your device for adjustment of settings, if you have any question about safety and privacy settings of your mobile device.

2.1.2 We also use cookies, web beacons, pixel tags, and other technologies to record and store your settings, improve effect of our advertisings, and collect some non-personal information, such as log data and device data. In particular, cookies used by us allow us to link your behavior of using services of AvaEye with your account information that is stored by us or other information that is stored by us when services of AvaEye are used by you. It can help us better understand your using behavior, judge and solve your problems, manage and improve services and products of AvaEye, and better utilize our services of AvaEye.

2.2 When your user content flows into services of AvaEye:

When you use recording or streaming function of products, we may record and transmit videos and/or audios from products with your consent. It may include screenshot, attachment of some screenshot information in a notice that is sent via email, analysis of data to identify your purposes and other cases. We may transmit information from the product that is provided to you, so that a notice can be sent to you in the event of certain circumstances.

III. Use of Information

In the period of existence of your account or in the period of providing services to you by us, for the purpose of maintaining legitimate rights and interests of AvaEye, and performing obligations agreed by and between you and AvaEye, AvaEye may use your personal information that is collected by us for the following purposes:

1. Answering your consultation;

2. Assessing the position that is applied for by you with your information;

3. Increasing safety of the website of AvaEye, for example, user identity verification, safety protection, fraud detection, archiving and backup;

4. Carrying out audit, data analysis, and research for internal purposes of AvaEye;

5. Sending electronic information to you upon your consent so as to notify you of the latest product information and services;

6. Using non-essential cookies to better understand your behavior upon your consent, so as to increase user experience, improve functional design or provide better services.

IV. Sharing of Information

We will share your personal information in the following circumstances:

1. We will share your personal information with affiliates of AvaEye when they need to use such information to realize purposes under this Privacy Policy.

2. We will share your personal information with authorized partners only to realize purposes stated in this Privacy Policy, and our certain services will be provided together with our partners. We may share some of your personal information with partners to provide better customer service and user experience. We need to share your mobile phone number with SMS operators to complete account registration for you. We will share your collected device information and alarm information with mobile phone manufacturers to provide you with alarm push. We need to share your device information and account information with cloud service providers to provide you with core video monitoring functions. We will share your personal information only for lawful, legitimate, necessary, designated, and specific purposes, and only share personal information that is necessary for provision of services. Our partners have no right to use the shared personal information for any other purposes that are irrelevant to products or services. We will sign strict data protection agreements with companies, organizations, and individuals whom we will share personal information with, and such agreements will require them to deal with personal information according to our instructions, this Privacy Policy, and any other relevant confidentiality and safety measures.

3. You can share your videos, identity information, etc. with specific objects, and can also share your videos, location information, identity information, etc. with unspecified people based on our products and/or services. AvaEye bears no legal liability for such a serious situation as the leakage of your information due to your sharing behavior.

4. In order to comply with local laws and regulations, and to bring you with better customer experience and service quality, whenever we are sharing information, especially when we are transferring personal information to countries outside the EU, we will make sure that the information is transferred in accordance with this Privacy Policy.

5. Please understand that according to the applicable laws, regulations and national standards such as the Network Security Law and the Information Security Technology Personal Information Security Code, we can share your personal information without your consent under the following circumstances:

(1) When it is relevant to national security and national defense security;

(2) When it is relevant to public security, public health, and significant public interests;

(3) When it is relevant to criminal investigation, lawsuit, trial, and enforcement of judgment;

(4) When it is necessary for safeguarding life, property, and other major legitimate rights and interests of the subject of personal information or other individuals, but it is difficult to obtain your consent;

(5) When the collected personal information has been made public by yourself;

(6) When the personal information is collected from information that has been disclosed to the public lawfully, such as lawful news report, government information disclosure and other channels;

(7) When it is necessary for signing contracts as required by you;

(8) When it is necessary for maintaining safe and stable running of products or services provided by us, for example, detecting and handling failure of products or services;

(9) When it is necessary for academic research institutes to carry out statistical or academic research on basis of public interests, and de-identification treatment must be made to personal information contained in results when results of academic research or description are provided to the public;

(10) When it is necessary for complying with provisions of laws and government orders, legal proceedings of law enforcement authorities, regulators and courts, or similar legal proceedings, or answering subpoenas in relevant countries where our business is operated.

V. Storage and Protection of Information

(I) Duration and Place of Information Storage

Your personal information is stored by AvaEye only for the purpose of realizing purposes in this Privacy Policy and the personal information collected and generated during the operation in the applicable business place is stored in the applicable business place. Your personal information will be stored continuously by AvaEye in the period when you use products or receive services from AvaEye, unless longer duration of storage is required or allowed by applicable laws or your express authorization is obtained.

(II) Protection of Information

2.1 We highly emphasize safety of information, and have established a dedicated team to research, develop, and apply various safety technologies and procedures, adopt data encryption and deploy access control mechanism to establish relevant internal control system, in order to ensure that only the authorized personnel can access personal information, publicize safety and privacy protection requirements to the involved personnel, and publicize information security protection system and other protection measures to the whole staff. Meanwhile, we have obtained the information safety management system certification (ISO27001), and will regularly engage an external independent third party to evaluate our information security management system. Your information will be protected from being accessed, used, or leaked in an unauthorized way with all these rigorous measures. However, please understand that with technological restrictions and rapid development of as well as various malicious attack means in the industry of Internet, even all possible safety enforcing measures have been taken by AvaEye to the greatest extent, it is impossible to guarantee that information is safe absolutely. Please note that safety problems may emerge in the system and communication network, which are adopted by you when you use our products and/or services, due to other factors beyond our control.

2.2 Meanwhile, safety of your information also relies on your cooperation. We provide you with user name and password so that you can access AvaEye and relevant website, and it is your responsibility to keep such information confidential. We request you not to share such information with any one, and we will also regularly review technologies that are applied by us and strategies that are adopted to realize collection of information.

2.3 We establish special management systems, processes and organizations to ensure the safety of information. For example, we strictly limit the scope of people accessing information, request them to comply with confidentiality obligations and conduct audits.

2.4 In case of safety events such as personal information leakage, we will launch emergency plans to prevent the expansion of safety events and notify you in the form of a push notification, an announcement, etc.

VI. Your Rights

(I) Storing your personal information can help us provide you with related services that are needed most by you. You can access and update your personal information via your account, or you can contact us to obtain your information or request us to modify or delete your data by sending an email to AvaEye if you cannot find your personal information. It may be impossible for us to delete previous communication records when you set up or deregister your account, or delete your current files and data. Moreover, we may maintain backup of certain information temporarily until it is deleted permanently, in accordance with applicable laws and regulations of business, after some information is deleted by you.

(II) Subject to applicable laws, we guarantee you to exercise the following rights on your personal information: access or correct your personal information, delete your personal information, change the scope of authorization consent or revoke authorization, deregister your account, and obtain a copy of your personal information. To exercise your rights, please contact us via the contact information specified in Chapter 9 below. In principle, you will not be charged for your reasonable request, while for the repeated and unreasonable requests, you will be charged a fee, where appropriate, on a cost-recovery basis; and we may refuse the unreasonable repeated requests which require too many technical means, incur risks to the legitimate rights and interests of others or are very impractical. You may also realize this purpose by exiting direct marketing and refusing the use of cookies in browser settings. If you have any concern about the ways of processing your personal information by us, you are entitled to file a complaint with data protection authority in your country. If the use of products and/or services of AvaEye involves personal data to which the General Data Protection Regulation (GDPR) is applicable, AvaEye reminds you to pay due attention to and abide by relevant laws and regulations.

(III) AvaEye will store your personal information on our server in order to provide you with the most relevant services, provided that you continue to use the products and/or services of AvaEye. Your latest personal information is stored in order to provide you with more relevant services. You may access, update, and delete your personal information through data folders. We can help you manage your subscriptions, disable your account, and delete your activity summary and data.

VII. Third Party Services

Our products and/or services may access or link to websites or other services provided by third parties. Including:

1. You can use the "Share" button to share your information to a third-party service. These functions may collect your information (including your log information) to run the above functions properly.

2. For the purpose of realizing purposes stated in this Policy, we may access the SDK or other similar applications provided by third-party service providers, and share some of your information collected by us in accordance with this Policy to such third-party service providers, so as to provide better customer service and user experience. At present, the third-party service providers we access mainly include the following types:

(1) For message push function, including the push of mobile phone manufacturers;

(2) For obtaining device location permission, and collecting device information and log information with your consent;

(3) For third-party authorized services, sharing relevant content to third-party products, etc;

(4) For related services of account safety and product reinforcement, including data encryption and decryption services.

We will only share your information for legitimate, necessary and specific purposes. For the third-party service providers with whom we share information, we will require them to perform the relevant confidentiality obligations and take corresponding safety measures.

Such third party services are operated by the relevant third party; your use of services from such third party or provision of information to such third party shall be subject to the service terms of and/or privacy protection statement of such third party (other than this Policy).

VIII. Privacy of Minors

We provide no services of AvaEye to any minor that is under the age of 18 (or any other similar minimum age that is specified in related jurisdiction). Once we find any account is connected with or is registered by a minor under the age of 18 (or any other similar minimum age that is specified in related jurisdiction), we will immediately delete relevant account information. Once we find that we have collected personal information of a minor without the prior consent of a verifiable parent, we will try to delete the relevant data as soon as possible.

If you are a parent or guardian of a minor under the age of 18 (or any other similar minimum age that is specified in related jurisdiction) and you believe that your minor has disclosed her/his personal information to us, please contact us immediately by phone or email (relevant contact information is provided in support information of AvaEye in relevant country). Parent or guardian of a minor under the age of 18 (or any other similar minimum age that is specified in related jurisdiction) may examine and require us to delete and forbid us to use personal information of his/her minor. For the collection of personal information of minors with the consent of parents/guardians, only if it is permitted by law, expressly agreed by parents or guardians or necessary for the protection of minors will such information be used or publicly disclosed.

IX. Contact Us

If you have any questions, comments or suggestions regarding this Privacy Policy or your personal information, please contact us by sending an email to avaeyeapp@gmail.com. We will handle it within 15 working days after reviewing and verifying your identity.

X. Revision of Privacy Policy

This Privacy Policy is revised on April 28, 2020. We may revise this Privacy Policy from time to time, and such revisions shall be an integral part of this Privacy Policy. When the terms of this Policy are changed, we will show you the changed policy in the form of a push notification and a pop-up window when you log in and update the version. Please note that we will collect, use and store your personal information according to the updated policy only after you click the Agree button in the pop-up window.