Victure Home Privacy Policy
Last updated as of [ May，21], 2021
Effective Date: [ May，21], 2021
Victure Home (the "Product") is a smart device product and service developed, operated and managed by Shenzhen Apeman Innovation Science & Technology Co., Ltd. ("Apeman" or "we") . Our registered address is at 18/F, Henglu E Times Building, No. 159 North Pingji Avenue, Pinghu Sub-district, Longgang District, Shenzhen, China. We fully respect and will protect the privacy of our users. While providing quality services to you, we will collect, use, disclose, store and protect your personal data in accordance with this Privacy Policy (the "Policy"). Through this Policy, we wish to provide you with an introduction to how we process your personal data and to provide you with access to and control over your personal data.
This Policy will help you understand the following:
I How we collect and use your personal information
For the purposes of this Policy, "personal data" refers to any information relating to an identified or identifiable natural person.
Before using this Product and submitting your personal data, please read this Policy carefully, so as to understand our practices with respect to customer privacy. If you have any questions about this Policy, or have any complaints or suggestions, please contact us at the contact information disclosed in this Policy.
I How we collect and use your personal informationApeman collects information in order to operate more efficiently and provide you with better product experience. The personal data is collected from (1) your direct provision of personal data, (2) data we record about how you interact with our products, and (3) third parties which we obtain your personal data indirectly.
The information we collect depends on the environment in which you interact with the Apeman, the choices you make, including your privacy settings, and the products and features you use.
Some of our services will need you to provide us with your information directly:
- When you are in the process of registering an account, you need to provide your user nickname, email address [regional information] to complete the account registration.
- If you make an after-sale or warranty request, you will need to provide the product order information, your contact information, address, email address, mobile phone number, so that we may respond to your request.
- During the [login] process, you need to provide your [email address, regional information, cell phone model, cell phone system language] to complete the [login function].
(2) Data we record about how you interact with our products
In addition to the information you provide directly, we may also collect information about your use of our services through your device and other means, so as to analyze the status of your use of our products. For example, we may collect:
- Device information: including device attribute information, such as the model of the phone you are using, operating system version, device screen size, unique device identifier, International Mobile Equipment Identity Code IMEI, network device hardware address (MAC); device location information, such as location information obtained through GPS, Bluetooth or WIFI signal; device other information, such as the type of browser, telecommunication carrier, the device setting language, device setting time zone, device application list, unique application number, [phone push code, phone brand]
- Log information and operation record information: including your use of our products or services, your operation record of using various functions of the products, such as registration time, recent login time, logout time, time and number of device additions, use of video viewing, recording, photo taking, intercom, mute, timer function, number of verification code requests, video/photo download records, as well as your IP address, download and installation or use of mobile applications, software information, [crash information]
- Location information. When you turn on your smart device location function and use our location-based services, we may collect and process information about your actual location, so that you will be able to access services without manually entering your own geographic coordinates. We use various technologies to determine your location, including IP addresses, GPS and other sensors that can provide relevant information (such as information about nearby devices, Wi-Fi access points and base stations).
- Environmental information captured by the camera: including indoor layout, ground object information, distribution of objects, indoor people and pets, etc. Depending on the specific scenario in which you use the product, this information may contain personal data of you or other subjects, including personal facial information, [motion detection information, sound detection information], etc.
- Voice information: the voice information that you produce when you use remote conversation functions, voice information of other individuals having remote conversations with you via our smart device and voice information that you produce when you use the smart voice control function.Please be noted that due to your use of the Product, the Product may collect information containing others’ personal data, including other persons’ facial and voice information, which will be depended on your use of the Product under certain circumstances. Please obtain the consent of such persons in advance when you use the Product and reasonably expect that such other persons’ information will be collected.
- Bluetooth information:When you use with Bluetooth device connection, this product uses cell phone Bluetooth to search and connect the device.
(3) We obtain your personal data indirectly from a third party
- When you log on the Product using a third party account, we shall, based on your authorization, obtain your nickname, mobile phone number, email address, gender, photo, birth date, domicile, age, current city where you are located and personal statements you provided to the third party platform.
- When you purchase our products on a third-party e-commerce platform (Amazon), we obtain information about your nickname on the platform, order number, mailing address, payment amount and payment time from the third-party e-commerce platform and payment service provider.
Please note that in the specific circumstances disclosed above, certain personal data about you may be received and stored by third party service providers working with us. We will use commercially reasonable efforts to ensure that such third parties do not use this information for any other purpose.
When we fulfill our obligations to you under the user agreement and/or service contract, or our bound legal obligations, or we think it is necessary to protect the legitimate interests of us or any third party through evaluation, we will process your personal data for the purposes described in this Policy with your consent.
We will use your personal data in strict accordance with this Policy and its updated versions. Your personal data is only used for the purposes explicitly stated upon collection and to the extent you agreed. Any use for other purposes shall be subject to your prior consent.
The relevant scenarios of using your personal data are as follows:
(1) To provide you with the functions or features of our products and services:
- We will create an account for you using the user name, email address provided by you, or information about your account on a third party account that we obtain from such third party platform.
- In order to provide you with video surveillance, video/picture capture, live video, video storage, video download, remote conversation functions, our smart device will take videos and provide you with video content, or transmit sounds/voices in real time based on the way you operate the Product. We take or record such video and sound/voice information only for the purpose of performing the relevant functions of the smart device. Without the consent of you or any other relevant persons, we will not access or process such information, nor use such information to recognize the identity of you or any other person, or use such information for any other purposes.
- This product is equipped with Amazon Alexa, Google Assistant voice services, when you enable intelligent voice services, third-party intelligent voice service providers will collect and process your voice information based on your operation, so that our smart devices can respond to your voice commands. We do not collect, access, or process this voice information in any way.
- This product provides automatic wifi name acquisition, which requires location access to obtain the name of the wifi to which the phone is connected.
- This product provides avatar setting function and scanning QR code function, which requires device camera permission to take photos.
- This product provides the function of saving to the cell phone album, which requires the device cell phone album read/write permission to save and read photo and video files.
- This product provides intercom functions for cell phones and security equipment, requiring equipment microphone privileges to collect and transmit data.
(2) To maintain, improve or enhance the performance of products or services: we use your personal data to maintain the normal operation of products or services, to troubleshoot products or services, to improve the security performance of products or services, and to update the function of products or services, etc.
(3) To send you selected products: when you purchase our products or services through online sales channels, we will use the address and contact information provided by you to contact you and deliver the products to you.
(4) To provide after-sale service or warranty service: when you make a request for after-sale service or extension of warranty, we will need you to provide the order and the product information for verification, and to provide the specific contact information so that we may contact you in time.
(5) Information subscription and push:we will send information and notices to you, including but not limited to verification code necessary to ensure the completion of a service, push notices necessary for using our products or services, news about our products or services, product marketing campaigns and promotions, product or service surveys or other content that may be of interest to you. If you do not wish to continue receiving the information above, you may opt out in accordance with the method provided in the information we send to you.
(6) Statistical Analysis of Product Use: in order to understand the use of various functions of our products and services, we may conduct statistics and analyze our users' use of our products or services.
(7) To protect the security of your account and our products or services:we may comprehensively analyze the information we collect and determine the security of your account and trading risks based on your using habit, carry out identity verification, detection and prevention of security incidents, and take necessary recording, auditing, analysis and handling measures according to the law to better prevent security risks such as website phishing, fraud, network loopholes, computer virus, network attack, network intrusion and other security risks and to more accurately identify actions in violation of laws and regulations or the relevant product or service agreements to protect the legitimate rights and interests of you, other users and us.
(8) To respond to law enforcement requests as required by applicable laws, court orders or government regulations.If we intend to use the information for other purposes not specified in this Policy, we will seek your consent in advance. We will also seek your prior consent when we use information collected for a specific purpose for other purposes. We will not provide personal data and behavioral data of users to third parties without their consent.
We may also provide additional information about our personal data practices through product notes, supplementary privacy statements, or notices before or during data collection. Some of our websites or features may have a separate privacy statement that specifically describes how these websites or features process personal data. If there is a conflict between the notice or the privacy statement of a specific website or feature provided at the time of collecting information and this Policy, the specific notice or supplementary privacy statement will prevail.
II How we use cookies and similar technologies
A cookie is a small file that our application or service transfers and stores on your device. The Product may use cookie technology. Cookies may be stored on your device for a shorter or longer period of time, or even years. Except for using cookies set by the browsers, we don't set any cookies in websites, applications or services.
(2) Cookies we useApeman uses cookies or similar tracking technologies to better understand how often you use the product, what happens within the product, cumulative usage, performance data, and overall audience profile of the user group so that we can analyze trends, manage websites, and track user behavior on the site.
(3) Clean /Disable cookiesManaging cookies and cookie preferences must be done within your browsers’ options/preferences. Here are guidelines on how to do this in commonly used browser software:
For more information about cookies and instructions on how to set up your browser to accept, remove, or disable cookies, see www.allaboutcookies.org.
In addition to cookies, we will use similar technologies on our websites such as beacons and pixel labels. For example, we may send you an email that contains a click URL that links to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service.
A beacon is usually a transparent image embedded in a website or email. With pixel labels in an email, we may identify whether the email is open. If you do not want your activity to be tracked in this way, you may opt out of our mailing list at any time.
Many web browsers have the Do Not Track feature, which allows you to send Do Not Track requests to websites. Currently, major Internet standards organizations have no policy in place to govern how websites should respond to such requests. But if your browser has enabled the Do Not Track feature, all of our websites will respect your choices.
III How we share, transfer and disclose your personal information
Our authorized partners include the following types:
(1) Technical Service Providers: We work with third-party technical service providers who will provide technical support for specific features of our products or services to you, as well as back-office support for our smart devices. In this sense, third-party technical service providers may need to obtain your user name, email address, log and operations, and location information.
(2) Smart Voice Service Providers: This product is equipped with Google and Amazon Smart Voice Services. When you enable Smart Voice Services, third-party Smart Voice Service Providers will collect and process your voice information based on your actions so that our smart devices can respond to your voice commands. We do not collect, access or process this voice information in any way. If you would like to know how third-party smart voice service providers collect and process your personal data, please visit Google Assistant Privacy Agreement at https://developers.google.com/assistant/console/policies/privacy-policy-guide?authuser=1, Alexa Privacy Agreement at https://www.amazon. com/gp/help/customer/display.html?nodeId=468496&pop-up=1.
(3) Cloud Service Providers: we engage third-party cloud storage service providers, so as to provide you with video and audio content storage services. Please be noted that without your prior consent, neither we nor any of our third-party service providers will access, process or use such information, or to use such information to recognize the identity of you or other persons or for any other purpose.
(4) Advertising Service Providers:in order to promote our marketing information to you, we may share your email address to third-party advertising service providers, so that they may push marketing information that may be of interest to you. If you do not wish to continue receiving such information, you may opt out in accordance with the methods disclosed within such information;
(5) Message Push Service Providers: We share your email information and device push codes with third party message push service providers to push product or service related information or notifications to you on our behalf.
(6) User data analysis: We may use a third-party analysis service provider (Google Analytics) to analyze your data. Therefore, during your use of this product, the provider may obtain your [Used functions, Information such as the result of the performed operation, the time, frequency and duration of its online activities, and crash log] will be stored in the third-party server. We will obtain data analysis reports based on the above information from the supplier to optimize the performance of our products and provide you with services more in line with your needs. These third-party services and functions may operate independently of us. The privacy practices of relevant third parties, including detailed information about the information they may collect about you, are governed by the privacy statements of these third parties. We strongly recommend that you carefully read these statements on the third party's official website.
IV How we store and protect your personal data
(1) At present, we have taken measures to ensure the security of data transmission and storage, such as encrypting the data itself or encrypting the documents, and we have adopted strict management measures and access restrictions for our servers, which can only be accessed in our LAN environment.
(2) We have set up authority allocation for internal data access and data export within the company,and we only allow the employees necessary to know the personal data for purpose of processing such information to access such personal data. Where high-sensitivity information such as user privacy is involved, the relevant personal data may be accessed only upon the approval of superior managers;
(3) The security of your information is very important to us. Therefore, we will continue to ensure the security of your personal data, and implement security measures such as encryption throughout the storage and transmission process to prevent your information from being accessed, used or disclosed without authorization. Meanwhile, the details of some encrypted data are not accessible to anyone other than the user.V Your rights to your personal data
Apeman respects your rights to your personal data. Below is a list of your rights under the law, and how we will protect them. Please note that for security reasons, we may verify your identity before processing your request.
You can inquire and access your personal data through the following ways: [Victure home personal information page, app feedback and sending customer service email (email address: app.support@govicture.com) to inquire personal data].
You can correct your personal data in the following ways: [Victure home personal information page, app feedback and sending customer service email (email address: app.support@govicture.com) to correct your personal data].
You can delete your personal data through the following ways: [app feedback and send customer service email (email address: app.support@govicture.com) to delete personal data].
You can realize your right to restrict processing by sending an email to the following address [email address: app.support@govicture.com].
After providing a formal authorization, you can realize your data portability rights by sending an email to the following address [email address: app.support@govicture.com]
You can realize your right of refusal by sending an email to the following address [email address: app.support@govicture.com].
You may also submit your request to withdraw your consent by sending an email to:[email address: app.support@govicture.com]. .
We will respond to your request within 30 days from the date of receiving your request and communicate with you in an appropriate way. We may extend the aforementioned period (up to 60 days), if necessary, and inform you of the reasons for the extension within 30 days from the date of receiving your request. If we have reason to believe that there is no need to take any measures against your request, we will inform you of our decision within 30 days from the date of receiving your request and explain it accordingly. If you are not satisfied with the reply you received, you can also complain or report to the competent supervisory authority in jurisdiction, or bring a lawsuit to the judicial organ with jurisdiction.
VI How we process children’s personal data
VII Third-party service providers and their services
VIII How we transfer your personal information globally
IX How we update this Policy
We reserve the right to update or modify this policy from time to time. We will send you a change notification via a message reminder in our app.
This policy allows adjustments, but without your express consent, we will not weaken your rights in accordance with this policy.
If you have any questions or concerns about our privacy policies or practices, please contact us at:
Address: 18/F, Henglu E Times Building, No. 159 North Pingji Avenue, Pinghu Sub-district, Longgang District, Shenzhen, China
Email: app.support@govicture.com
You may also contact our European Data Protection Officer (DPO) at:
Email: app.support@govicture.com