Victure Home Privacy Policy

Last updated as of [May,21 ], 2021

Effective Date: [ May,21], 2021

Victure Home (the “Product”) is a smart equipment 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, North 159 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 information in accordance with this Privacy Policy (this "Policy"). In connection with this Policy, we wish to provide you with an introduction to how we process your personal information and provide you with access to and control over your personal information.

This Policy will help you understand the following:

I. How we collect and use your personal information
II. How we use cookies and similar technologies
III. How we share, transfer and disclose your personal information
IV.  How we store and protect your personal information
V. Your rights to your personal information
VI. How we process children’s personal information
VII. Third-party service providers and their services
VIII. How we transfer your personal information globally
IX. How we update this Policy
X. CCPA special notice

    For the purposes of this Policy, "personal information" refers to means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

    Please read this Policy carefully before using this Product and submitting your personal information, 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 information

      Apeman collects information in order to operate more efficiently and provide you with better product experience. The personal information is collected from (1) your direct provision of personal information, (2) data we record about how you interact with our products, and (3) third parties which we obtain your personal information indirectly.

      The information we collect depends on the environment in which you interact with Apeman, the choices you make, including your privacy settings, and the products and features you use.

      1. Personal information we collect

        (1) Personal information directly provided by you

        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 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.

        2Data 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 equipment and other means, in order to analyze the status of your use of our products. For example, we may collect:

        - Device information, including information about the attributes of your device, for example, your mobile phone’s model number, operating system version, device screen size, unique device identifier, international mobile device ID  (IMEI) number, network device hardware address (MAC address); device location information, for example, location information obtained via GPS, Bluetooth or WIFI signals, and other device information such as type of browser, carriers, device language, device time zone, device application list, unique application number(s), phone push code, phone brand.
        - Log information and operation log information, including your use of our products or services, and operations logs of your use of various functions of the products, such as registration time, recent logon time, exit time, time and number of device addition, video viewing, recording, photo taking, intercom, mute, use of timing function, request times of verification code, records of downloading of videos/photos, and your Internet Protocol (IP) address, information about the mobile applications and software downloaded, installed or used, 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).
        - Information regarding the environment captured by the camera, including indoor layout, information about items on the ground, distribution of such items, indoor personnel and pets, etc. Due to your use of the Product in certain scenarios, such information may contain personal information of you or other persons, including personal facial 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 information, 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 information 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, the 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 information 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.

              2. How do we use your personal information

              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 information for the purposes described in this Policy with your consent.

              We will use your personal information in strict accordance with this Policy and its updated versions. Your personal information 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 use of your personal information 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 platform 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 information 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 the warranty, we will need you to provide the order and the product information for verification, and to provide your 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 information and behavioral data of users to third parties without their consent.

                We may also provide additional information about our personal information 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 information. 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

                1. Cookie

                (1) What is a cookie?

                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 use

                Apeman 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) Clear/Disable cookies

                Managing cookies and cookie preferences must be done within the settings/preferences in your browsers. Here are some guidelines on how to do this in commonly used browser software:

                • Microsoft Internet Explorer
                • Microsoft Edge
                • Mozilla Firefox
                • Google Chrome
                • Safari for macOS
                • Safari for iOS

                (4) More about cookies

                For more information about cookies and instructions on how to set up your browser to accept, remove, or disable cookies, see www.allaboutcookies.org.

                         2. Beacons and pixel labels

                  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.

                          3. Do Not Track

                    Many web browsers have the Do Not Track feature that 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 our sites will respect your choices.

                     III    How we share, transfer and disclose your personal information

                    1. Apeman may share some personal information with third parties from time to time. Your personal information will not be shared with third parties for their own marketing or business purposes.
                    2. Only for the purposes stated in this Policy, some of our services will be provided with the assistance of authorized partners. We may share some of your personal information with our partners to provide better customer services and user experiences. We will share your personal information only for legal, legitimate, necessary, specific, and explicit purposes, and will only share personal information necessary for provision of our services. Our partners are not allowed to use shared personal information for any other purpose.

                    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 Provider: 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.

                    1. If the transfer of personal information is involved in a merger, acquisition or bankruptcy liquidation, we will require the new company or organization that hold your personal information to continue to be bound by this Policy; otherwise, otherwise, additional authorization and consent will be obtained from you by said company or organization.
                    2. We sign stringent confidentiality agreements with companies, organizations and individuals to which we share your personal information and require them to use personal information in strict accordance with the purposes set forth in this Policy, and take relevant confidentiality and security measures to process personal information.
                    3. We will comply with relevant laws and regulations and keep your personal information confidential. We will not disclose your personal information to a public extent we obtain your prior explicit consent or authorization or as required by law. We will only disclose your personal information to the public where the disclosure are required by law, or when we need to comply with a subpoena or other legal process, lawsuit, or when we are mandatorily requested by a government authority. We may disclose your personal information to the public if we believe in good faith that such disclosure is necessary to protect our rights, the security of you or other persons, investigate fraud or respond to a government request.

                     IV     How we store and protect your personal information

                    1. The personal information we collect will be retained for the minimum period necessary to achieve the purpose of collection stated in this Policy, unless a longer retention period is required by law. We will delete or anonymize your personal information when the aforementioned retention period expires. For example, we will continuously retain your personal information during the period you register and use our products or services. If you cancel your account, we will delete or anonymize your personal information once you have finished account cancellation, unless otherwise required by laws and regulations.
                    2. If we cease to operate some or all of our products or services for special reasons, we will promptly notify you and cease the collection and processing of personal information of the related products or services, and delete or anonymize personal information in our possession in relation to that products or services, unless otherwise required by laws and regulations.
                    3. We take reasonable and practical management and technical measures to protect the information we collect which relates to our products or services. Please note, however, that, although we take reasonable steps to protect your information, no website, internet transport, computer system or wireless connection is absolutely secure.
                    4. We have used security measures which are in compliance with industry standard to protect the personal information of you against unauthorized access, public disclosure, use, modification, or damage or loss of data. We will take all reasonably practicable steps to protect your personal information, including:

                    (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 information for purpose of processing such information to access such personal information. Where high-sensitivity information such as user privacy is involved, the relevant personal information 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 information, 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.

                    1. In the event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the incident, the measures we have taken or will take to deal with it, suggestions that you can take on your own to guard against and mitigate the risks, and our remedial measures to you. We will inform you of the relevant information of the incident in a timely manner by email, letter, telephone, push notice or otherwise. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective means to issue announcements. At the same time, we will also follow the requirements of the regulatory authorities, and take the initiative to report the handling of personal information security incidents.

                    V     Your rights to your personal information

                    Apeman respects your rights to your personal information. The following 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.

                    1. Right to know:se inform you of how we process your personal data by releasing the Policy. We are committed to ensuring the transparency in use of your information.
                    2. Right to access:you can directly inquire or access your personal information in our product or service interface. You can login your account at any time through the product or App page, to access your account related personal information, including basic information, operation records, audio and video information, etc.

                    You can query and access your personal information through the following channels: Victure home personal information page, app feedback and sending customer service email (email address: app.support@govicture.com).

                    1. Right to rectification: you have the right to ask us to rectify or supplement any incorrect or incomplete processing of your personal data (if any). You can directly rectify and modify part of your personal data on the related function pages of products or services. Otherwise, you can contact us via the contact information disclosed herein to request the rectification or supplement of your personal data, provided that the self-modification channel is not provided. In such circumstances, we will process your request and give feedback in time according to the laws and regulations.

                    You can rectify your personal information through: app.support@govicture.com 

                    1. Right to erasure/deletion: You can directly erase/delete your submitted information in the product interface under your account, such as email address, etc. You can contact us via the contact information disclosed herein to request the erasure/deletion of your personal information collected and used by us in violation of our agreement with you (if any), and we will deal with it in a timely manner according to the requirements of laws and regulations.

                    You can erase/delete your personal information by the following means: [app feedback and send customer service email (email address: app.support@govicture.com) 

                    1. Right to restriction of processing: you have the right to ask us to restrict our processing of your personal information. This means that we can store your personal information, but cannot further process it. We only keep the data necessary for responding to your request in the future.

                     You can execute your right to restriction of processing by sending an email to: [email address: app.support@govicture.com

                    1. Right to data portability: you are entitled to obtaining your personal information in structured, commonly used and machine-readable formats to the extent permitted by laws and regulations. For example, if you decide to change to a new service provider, you can move, copy or transfer your personal information between our IT system and their IT system in a reliable, secure and easy way without affecting its use.

                    Upon providing formal authorization, you can exercise your right to data portability by sending an e-mail to: app.support@govicture.com

                    1. Right to object: Even if your data is processed for our legitimate interests, exercise of public authority, direct marketing (including data pooling), and statistical reasons, you have the right to deny creative processing of your personal information by apes.

                    You may decline your offer by sending an email to the following address(email address: app.support@govicture.com).

                    1. Right to withdraw consent: If you agreed to our processing of your personal information, but changed your mind later, you may withdraw your consent at any time, and we must stop processing your personal information. You can change the scope of your consent for us to continue to collect your personal information or withdraw your consent by deleting information, turning off device permission settings, changing related product or feature settings, cancelling your account, etc.

                    You may also submit your request to withdraw your consent by sending an email to:app.support@govicture.com. 

                    If you do not want to accept our commercial advertising, you can cancel it at any time in the following way:

                    1. Right to refuse automated decision-making:you have the right not to be subject to decisions made by automated processing, including profiling. If these decisions significantly affect your legitimate rights, you can refuse to automated decision-making by sending an e-mail to the following address(email address: app.support@govicture.com) and we will respond to your request and take appropriate measures if necessary.
                    2. Right to complaint:You are entitled to contacting us to make a complaint via the contact information disclosed herein, or make a complaint to the data protection agency in your country about our processing of your personal data.

                    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 30 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 information

                    1. The Product is not intended for children under the age of 13. For such children, we will only process their information with the consent of the child's guardian to the extent legally permissible.
                    2. We will use our best efforts to verify that a child's personal information has been processed with the consent of our guardian. If we find that personal information has been collected on a child without first obtaining a verifiable guardian's prior consent, we will endeavor to delete relevant information as soon as possible.
                    3. Please note that while you use our product with a camera or a smart voice control product, our product, or the relevant smart voice service provider, will photograph or record certain content that may contain personal information about a child, including a child's facial information, voice information, etc., solely due to implementation of the product function. Although we will not access or process this information, we will remind you in a prominent way of what personal information about a child might be photographed or recorded by such function when you activate relevant feature and obtain the explicit consent of you, as the child's guardian, or prompt you for the child's verifiable guardian’s explicit consent.

                     

                    VII    Third-party service providers and their services
                      1. Our websites, products, and services may contain links to third-party websites, products, and services. You may choose whether to visit third-party websites, products, and services.
                      2. We cannot control the privacy and data protection policies of third parties, and such third parties are not subject to this Policy. Before submitting your personal information to these third parties, please refer to their privacy policies.

                       

                      VIII    How we transfer your personal information globally
                        1. In principle, your personal information will be stored within the United States.
                        2. As we provide products and services worldwide, for global business needs, your personal information (including the types of data we list in the 'How we collect and use your personal information' section) may be transferredto other jurisdictions outside the country/region where you use the Product, or may be accessed by users from these jurisdictions. These jurisdictions include, but are not limited to: Mainland China, Hong Kong, etc.
                        3. When your personal information is transferred to a country or region outside the United States, we will ensure that appropriate protective measures are taken to ensure the security of your personal information, including but not limited to encryption measures, requiring overseas recipients to provide security for your information by signing an agreement with them or take other means.

                         

                        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, North 159 Pingji Avenue, Pinghu Sub-district, Longgang District, Shenzhen, China

                          Email Address: app.support@govicture.com

                           

                          X      CCPA special notice

                            Please refer to Appendix 1.

                             

                            Appendix 1: California Consumer Privacy Act Special Notice

                            This Special Notice is intended as an additional provision to our Victure Home Privacy Policy (“the Policy”) and forms an integral part of the Policy applicable to residents of the State of California in the United States who visit and use our Victure Home (hereinafter referred to as "California residents" or "you"). The most recent update date for this Special Notice is  [ May,21], 2021. 

                            This Special Notice will explain to you:

                            1. Categories of personal information we collect about you in the past 12 months and its sources
                            2. Purpose of our collection of your personal information
                            3. Sharing of your personal information for business purpose in the past 12 months
                            4. No sale of personal information
                            5. Your rights under the CCPA
                            6. Non-discrimination
                            7. California Shine The Light Law

                            Please read this Special Notice carefully and understand our practices for protection of users’ personal information and privacy before using our products (or services) and provide personal information to us. 

                            1. Categories of personal information we collect about you in the past 12 months and its sources

                            You have the right to know what categories of personal information we collect about you and the specific purpose for which we collect it. The categories and sources of your personal information we collected in the past 12 months are as follows:

                            (1) The personal information you provide to us, including:

                            • Identifiers, such as user name, e-mail address and contact address;
                            • Commercial information, such as order information for goods to be provided when you ask for after-sale or warranty service.

                            (2)The personal information we collect about you in the course of your use of the Product, including:

                            - Identifiers, including information about the attributes of your device, for example, your mobile phone’s model number, operating system version, device screen size, unique device identifier, international mobile device ID  (IMEI) number, network device hardware address (MAC address); device location information, for example, location information obtained via GPS, Bluetooth or WIFI signals, and other device information such as type of browser, carriers, device language, device time zone, device application list, unique application number(s), cell phone push code, cell phone brand.

                            - Internet or other electronic network activity information, including your use of our products or services, and operations logs of your use of various functions of the products, such as registration time, recent logon time, exit time, time and number of device addition, video viewing, recording, photo taking, intercom, mute, use of timing function, request times of verification code, records of downloading of videos/photos, and your IP address, information about the mobile applications and software downloaded, installed or used, crash information.

                            - Geolocation data. 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).

                            - Information regarding the environment captured by the camera, including indoor layout, information about items on the ground, distribution of such items, indoor personnel and pets, etc. Due to your use of the Product in certain scenarios, such information may contain personal information of you or other persons, including personal facial information, etc.

                            - Biometric information, 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 information, 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) The personal information we obtained from third parties:

                                - 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, the order number, mailing address, payment amount and payment time from the third-party e-commerce platform and payment service provider.

                                  1. Purpose of our collection of your personal information

                                  We use the personal information we collect primarily for the following purposes:

                                  (1) To provide you with the function or features of our products or 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 platform 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 information 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 the warranty, we will need you to provide the order and the product information for verification, and to provide your 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.

                                    We will not collect categories of personal information other than the information disclosed in this Special Notice without your consent, nor will we use the personal information collected by us for any purposes irrelevant to the abovementioned purposes.

                                    1. Sharing of your personal information for business purpose in the past 12 months

                                    You have the right to know if your personal information is being shared with any third parties. We may disclose your personal information to third parties for business purposes. We will sign agreements with such third parties in achieving those business purposes, requiring such third parties to perform obligations of confidentiality in relation to the personal information that we disclose to them, and not to use the personal information for any purpose other than the fulfillment of the agreements.

                                    The details regarding your personal information that we have shared over the past 12 months are as follows:

                                    (1) Identifiers:

                                    - We share your email address with third party advertising service providers in order for them to provide us with the online marketing service.
                                    - We share your email information and device push codes with third party push service providers to push product or service related information or notifications to you on our behalf.

                                      (2) Information regarding the environment captured by the camera:

                                      - We engage third-party cloud storage service providers in order to provide you with storage services for video and audio content. 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.

                                        (3) Voice information:

                                        - As mentioned above, when you enable the Smart Voice Control service, Google and Amazon voice service providers collect and process your voice information directly based on your actions. We do not collect, access or process this voice information in any way. If you would like to know how third-party intelligent voice service providers receive and process your personal information, please visit Google Assistant

                                           

                                          Privacy Policy at https://developers.google.com/assistant/console/policies/privacy-policy-guide?authuser=1, Alexa Privacy Policy at https://www.amazon. com/gp/help/customer/display.html?nodeId=468496&pop-up=1.

                                          (4) In addition, 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, the third-party technical service providers may need to obtain identifiers of you, Internet or other electronic network activity information, and your geolocation information, etc.

                                          1. No sale of personal information

                                          You have the right to know whether your personal information has been sold. As defined in the CCPA, “sell,” “selling,” “sale,” or “sold” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. 

                                          We do not sell personal information, and therefore we have not sold any personal information about you in the past 12 months.

                                          1. Your rights under the CCPA

                                          (1) Your rights

                                          In accordance with the CCPA, you have the following rights:

                                          - Right to know/access: knowing the collection and usage of your personal information in the past 12 months.

                                          -Right to portability: obtaining a copy of your personal information.

                                          - Right to request deletion: deleting your personal information.

                                          - Right to opt-out of the sale of personal information: we do not provide opt-out mechanism as we do not sell your personal information.

                                            (2) Approach for exercising your rights

                                            You can exercise your rights in the following way. We will give response to your request as per CCPA once we receive, verify and confirm your request:

                                            - Toll-free hotline: 0755-36894114
                                            - email address: app.support@govicture.com

                                              (3) Exercising your rights

                                              It should be noted that only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

                                              It should be noted that according to the CCPA, we are not obligated to respond to request for access or data portability of the same consumer more than twice in a 12-month period. 

                                              We may deny your deletion request if it is necessary for us or our service providers to retain your information based on the following circumstances:

                                              - Complete the transaction for which we collected the personal information, comply with written warranties or product recalls under federal law, provide the products or services you requested or reasonably anticipated from our ongoing business relationship with you, or perform a contract between us and you.

                                              - Detect security incidents, guard against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

                                              - Debug products to identify and repair errors that impair existing intended functionality.

                                              - Exercise freedom of expression, guarantee the right of another consumer to exercise that consumer's right to freedom of expression, or exercise another right provided for by law.

                                              -Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

                                              - If you’ve provided the informed consent form for using your personal information for public or peer-reviewed scientific, historical or statistical research for the sake of public interest in accordance with all other applicable ethics and privacy laws; however, the deletion of the said information may result in failure or serious damage to the results of such research.

                                              - To allow internal use only based on our relationship with you, provided that such internal use is reasonably consistent with your expectation.

                                              - To comply with obligations prescribed by law.

                                              -To use your personal information internally in a legal way compatible with the environment in which you provide the information.

                                                (4) Response to your request

                                                We may need to verify your identity and the authenticity of your request before responding to your request. Verifiable consumer requests should:

                                                - Provide sufficient information to enable us to reasonably verify that you are the person whose personal information is collected or you are an authorized representative of such person.

                                                -Describe your request in detail so that we can understand, evaluate, and respond to it correctly.

                                                  We are unable to respond to your request or provide you with the personal information if we cannot verify your identity or authorization, and confirm that the personal information is related to you.

                                                  We will respond to your verifiable request within 45 days upon receipt or a longer period (up to 90 days) if necessary. In the latter case, we will notify you in writing with specific reasons and the extension period stated. We will give a written reply to your registered account if you are a registered user, or the written reply will be given by email or electronic means as you chose.

                                                  The feedback information we provide will only cover 12 months before the verifiable request is received. If we decide to refuse your request, we’ll explain the corresponding reason(s) in our replay. For your request for the right to portability, we will provide the personal information in an easy-to-use format and in a way allowing you to transfer the said information from one entity to another easily.

                                                  We will not charge any fee for processing or responding to your request unless your request is excessive or repetitive. If we confirm that the relevant fee will be charged in response to your request, we will inform you of the reasons and provide you with a cost estimate before replying to your request.

                                                   

                                                  1. Non-discrimination

                                                  We will not discriminate against you because you exercise the rights granted by the CCPA. Unless otherwise stipulated by the CCPA, we will not:

                                                  (1) Refuse to provide you with products or services;

                                                  (2) Charge you different prices or fees for goods or services;

                                                  (3) Provide goods or services of different levels or quality;

                                                  (4) Take other discriminatory measures.

                                                  However, if we provide some financial incentives permitted by the CCPA, such incentives may result in different prices, discounts or quality levels. Any incentive we offer will be reasonably related to the value of your personal information to be collected. Where we offer these financial incentives, your participation is optional. If you choose to participate, your participation will be subject to relevant applicable terms, and you may withdraw at any time. 

                                                  1. California Shine The Light Law

                                                  We will not disclose your personal information to any third parties for their direct marketing of products or services to you.