PRIVACY POLICY
Effective: 21/01/2020

Welcome to use EZVIZ Services. EZVIZ Services may include: (a) online services accessible through https://ezvizlink.com and the assosiated sites held by EZIVZ connected with it (“the Sites”); (b) software applications that can be downloaded to a mobile device or computer (“the Apps”); (c)embedded firmware that can be embedded into the Devices for connection with EZVIZ Services and updates (“the Software”),and(d)any services available on the Sites, the Apps and the Software(all of them hereinafter referred to as “EZVIZ Software ”).We provide EZVIZ Services for use in conjunction with Internet of Things devices of various brands and/or manufacturers(hereinafter referred to as “Third-party IOT Devices” or “Devices’).

This Privacy Policy describes how we collect, use and handle your personal information when you use our EZVIZ Services. It also applies to any personal information we collect from the operation and use of Devices while connected to our EZVIZ Services.

EZVIZ Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by us. This Privacy Policy does not apply to how third parties collect, use, disclose or retain information. We encourage you to review the privacy policies of these third-party websites or services.

We may modify this Privacy Policy at any time, provided certain provisions of this Privacy Policy prove to be incomplete or outdated and further provided that these changes are reasonable for you, taking into account your interests. If we make material changes to this Privacy Policy, we will notify you by the email address specified in your account or by means of notice on the EZVIZ Software of any such changes.

By using EZVIZ Services and Devices connected to EZVIZ Services or other acting permitted by the applicable laws, you are deemed to have read, acknowledged and accepted all the provisions stated here in this Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation (e.g. General Data Protection Regulation in Europe Union), we will specifically seek prior express consent to the particular processing (e. g. providing marketing materials to you) of personal information. Furthermore, we are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.In this Privacy Policy, “Personal Information” shall have the same meaning as “personal data” and shall means the information that can be used to identify an individual, either from that information alone, or from that information and other information we have access to about that individual.

1. What Information We Collect and Why We Collect the Information

We collect the following information to provide, improve, and protect our Services:

Account information. We collect, and associate with your account, the information you provide to us when you do things such as sign up for your account, login in EZVIZ Software through a third-party account ,subscribe for premium services (if applicable), and set up two-factor authentication, e.g. your user name, your phone number, email address, payment information and physical address. When you sign up for your account, we will also collect your location, e.g. which country or district you resident. We use this location to decide the nearest data center to support your use of EZVIZ Services. In addition, when you install and activate Devices, we will collect certain basic information via our EZVIZ Services, such as the Device’s name, verification code and/or serial number which are unique to the Devices connected to EZVIZ Services and associated with your Account.

Your Devices information. Our EZVIZ Services are designed to make it simple for you to manage your Devices. To make that possible, we need to associate your Devices with your Account by collecting your Devices information when you scan your Devices Code or enter your Device name, the Device’s verification code and/or serial number which are unique to the Devices connected to EZVIZ Services and associated with your Account. We also collect the parameter and configuration information of your Devices when you configure your Devices in your Account.

Your Content. Our EZVIZ Services may enable you to view, save and share content through EZVIZ Services, like video clips, live video streams, images and captions (“Your Content”), for other individuals to access. To make that possible, we store, process, and transmit Your Content. If you share the video link with others, we will further collect the phone number or email address of you and the person you elect to share Your Content with. To clarify, for the streaming video you preview in real time, we only transmit it, rather than store it.

Usage information. We collect information related to how you use EZVIZ Services and manage your Devices, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities. We use this information to improve our EZVIZ Services, develop new services and features, and protect our users. For example, to improve EZVIZ Services, we collect information about how you interact with EZVIZ Services to understand what features are most useful to you and improve them. To protect our users, we analyze things like IP addresses, device type, login history, and password changes to detect and respond to abusive behavior.

Device information. We also collect information from and about the devices you use to access EZVIZ Services. This includes things like the browser, device name, type of network and Operator you use, and the UUID, model, system version, language and time zone of your device. We may also receive information through device settings that you turn on, such as access to your GPS location.

Cookies and other technologies. We also use cookies, web beacons, pixel tags, and other technologies to keep records, store your preferences, and collect information such as log data and device data. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our EZVIZ Services, and improving them based on that information. This allows us to better understand how you use our EZVIZ Services, diagnose and troubleshoot any problems you have, and otherwise administer and improve our EZVIZ Services. For more information about cookies, please refer to our Use of Cookies.

2. How we use your information

We process your information (1) to provide EZVIZ Services described in Terms of Use; (2) in furtherance of our legitimate interests in operating EZVIZ Services and business; and (3) with your consent. In some cases, we may process your information to comply with applicable law, legal process, or regulation; protect any person from death or serious bodily injury; or to carry out a task in the public interest.

Examples of EZVIZ processing your information to provide you with EZVIZ Services include:

a. Providing, updating, maintaining, and protecting EZVIZ Services and business. For example, When you use the Device’s recording or streaming features (if any), we may record and process video and/or audio content from the Devices. This may include capturing and sending you portions of this data as part of a notification or analyzing the data to identify motion or other events. We may process information from your Devices so that we can send you alerts when something happens.

b. Troubleshooting issues you may encounter with EZVIZ Services. If you contact us with questions or concerns about EZVIZ Services, we may use your personal information to verify your identity and respond. If you contact us via EZVIZ Customer Services, depending on your stated needs, we may further require certain personal information. When there are reasonable doubts regarding your identity, you might be asked to provide further information, which help us to verify your identity. Our use of the information on your identification document is strictly limited: the information will only be used to verify your identity and will not be stored for longer than needed for this purpose.

c. Billing, account management, and administrative purposes. If you subscribe for premium services, we may collect and process payment information, including your name, credit or debit card information, billing address, and details of your transaction history.

d. Sending you emails and other communications. We may contact you about important changes to EZVIZ Services and Service-related notices, including alerts, software update notices, and policy and terms modification notices. These communications are considered part of EZVIZ Services and you may not opt out of them.

Examples of EZVIZ processing your information in furtherance of our legitimate interests in operating EZVIZ Services and business include:

a. Understanding how you use our Services and improving them.

b. Investigating and preventing security issues and abuse of EZVIZ Services or EZVIZ users.

c. Analyzing issues you may encounter with EZVIZ Services and improving them. For example, we may analyze the connection speed between your Devices and your Account to troubleshoot the issue and improve them.

d. Managing our everyday business needs, such as auditing, administration of our EZVIZ Services, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Service.

Examples of EZVIZ processing your information with your consent include:

a. Sending you marketing materials relating to EZVIZ Services. You have the right to opt out of our proposed use of your personal information for this marketing purpose.

b. Collecting feedback or answers to our questionnaires from you to improve our Services, and develop new features.

3. Whom We Share Information with

We do not sell any personal information to third parties and we never will.

We may share your personal information with third parties as discussed below:

Others working for and with EZVIZ. EZVIZ uses certain trusted third parties (for example, providers of customer support and IT services) to help us process, store, and protect some of your information and otherwise help us administer our Services effectively, facilitate payments, provide a better user experience, and increase the quality of EZVIZ Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions. For a list of trusted third parties that we use to process your personal information, please contact us.

New Owner. If EZVIZ and/or all or part of our assets are ever sold or transferred, your personal information may be among the items sold or transferred. Under such circumstance, we will notify you by sending an email to the email address associated with your account or via an in-app notification of (i) the identity and contact information of the purchaser or transferee, (ii) your right to revoke your consent to the provision of personal information, and (iii) the means by which you may revoke such consent.

Law and Order; the Public Interest. We access, preserve and share your information with regulators, law enforcement or others:

a. In response to a legal request (e.g. a search warrant, court order or subpoena) if we have a good-faith belief that the law requires us to do so;

b. When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorised use of EZVIZ Services, breaches of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or EZVIZ Services), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off EZVIZ Services.

4. Securing and Retention Your Information

Security. We have implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We have a team dedicated to keeping your information secure and testing for vulnerabilities. We conduct periodic reviews and assessments of the effectiveness of our security controls. We also continue to work on features to keep your information safe in addition to things like two-factor authentication and encryption of videos.

Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, EZVIZ cannot guarantee that your information is under absolute security with the existing security technology. If you have any further questions about the security of our EZVIZ Services, Please contact us.

Retention. Generally, we store your information on EZVIZ’s servers which is established upon third-party servers until you delete or edit it, or for as long as your account is in existence or we need it to provide you the services, unless a longer retention period is required or permitted by applicable laws.

5. Your Rights

Keeping your personal information current helps ensure that we provide you with the most relevant offers. You can access, update or delete your personal information by logging into your EZVIZ Account and going to your account setting page.

You can limit the information you provide to EZVIZ as well as the communications you receive from EZVIZ through your Account preferences. Notwithstanding, we may still e-mail you non-commercial e-mails related to your Account and your transactions on EZVIZ Services.

If you close your account, we will initiate deletion of this information immediately. But please note: (a) there might be some latency in deleting this information from our servers and back-up copies; and (b) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

You may manage how your mobile device and browser share certain device data with us by adjusting the privacy and security settings on your device. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

If you are located in the European Economic Area (EEA), subject to limitations in applicable law, you have certain rights in respect to your personal information, such as a right of access, rectification, restriction, opposition, and portability. In order to exercise your rights, please contact us. You also have the right to withdraw your consent at all times, free of charge. You can do this by opting out by rejecting the use of cookies through your browser settings. However, your withdrawal may affect your continued use of EZVIZ Services. If you have concerns about how we handle your personal information, you have the right to lodge a complaint with the data protection authority in your country/region of residence.

6. Children’s Privacy

We do not intend that any portion of its EZVIZ Services will be accessed or used by children under the age of 18, or equivalent minimum age in the relevant jurisdiction and such use is prohibited. Our EZVIZ Services are designed and intended for adults. By using EZVIZ Services, you represent that you are at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction and understand that you must be at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction in order to create an account and purchase the goods or services advertised through our EZVIZ Services. If we obtain actual knowledge that an account is associated with a registered user who is under the age of 18 years old, or equivalent minimum age in the relevant jurisdiction, we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us, please contact us. A parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction may review and request deletion of such child’s personal information as well as prohibit the use thereof.

7. Global Operations

We transfer and process your information globally both in our own facilities and with service providers, or partners, regardless of where you use our Services. As EZVIZ operates globally, we may transfer your personal information to our affiliates worldwide, when processing that information for the purposes described in this Privacy Policy, e.g. if you request for customer services from EZVIZ, our colleagues in China may access certain of your information (wherever you are located) in order to provide the requested services to you. We shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You hereby agree to the data transfer and you have the right to be informed of the appropriate safeguards taken by EZVIZ for this transfer of your personal information.

Currently we have data centers in the U.S., Singapore, Brazil and Ireland and your account information (like your account name, email address, phone number, and Devices serial number) will be stored in all these four data centers, regardless of where you use our Services. The laws, regulations, and standards of the country in which your information is stored or processed may be different from those of your own country. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However, this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.

If you are located in the EEA, then whenever EZVIZ shares your personal information with a third party outside the EEA, or transfer such information to a third party outside the EEA, EZVIZ will put in place contractual protections (https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087), approved by the European Commission, to secure your information.

In certain jurisdiction, we may also deploy local servers in accordance with local law requirements.

8. California Consumer Privacy Act Notice

California residents have additional privacy rights under the California Consumer Privacy Act, which are described in the California Consumer Privacy Act Notice.

9. Contact Us

If you have questions or concerns about EZVIZ, EZVIZ Services, or privacy, please do not hesitate to contact our Data Protection Officer at [open-team@ezvizlife.com]. Please provide: (i) your name (or nickname), your country/region of residence and your preferred method of contact; and (ii) the details of your request or comment along with any corresponding website links or pages.

If they can’t answer your question, you have the right to contact your local data protection supervisory authority.

Hangzhou EZVIZ Network Co.,Ltd

Room 301, Unit B, Building 2, 399 Danfeng Road, Binjiang District, Hangzhou, Zhejiang, China