Privacy Policy
Posted: July 15th 2024
Effective: July 18th 2024
Introduction
Hangzhou Huacheng
Network Technology Co., Ltd. (¡°Imou¡±, ¡°we¡±, ¡°us¡± or ¡°our¡±)
respects your privacy and is committed to protecting it through our compliance
with this Privacy Policy (the ¡°Policy¡±).
This Policy describes how we process your personal data when you use Imou Partner
(the "App"), or use the
service(s) as provided by us or our affiliates in connection with the App (the
¡°Service¡±). For specific usage or
service scenarios, we may release a
dedicated privacy policy to describe how to process your personal data and
exercise your rights.
Please read this Policy
carefully to understand our policies and practices regarding your personal data
and how we will treat it. If you have any issues regarding this Policy, please
contact us at privacy@imoulife.com.
Table of
contents
1. How We Process
Your Personal Data and Purpose of Processing
2. How We
Share, Assign and Disclose Your Personal Data
3. Third Party
Products and Services
4. How We Protect and Retain Your Personal Data
5. How We Protect Children¡¯s Personal Data
6. International Transfers
7. Your Rights
8. Changes to Privacy Policy
9. How to Contact Us
1. How We Process Your Personal Data and Purpose of Processing
We may process several
types of data from you, including data that identifies you personally, such as personal
name, physical address, e-mail address and telephone number, etc. (¡°Personal Data¡±). We may also process data
that is about you, but individually does not identify you, such as demographic
data, data about your internet connection, the equipment you use to access our services
and usage details.
You have right to choose whether or not to provide the data we requested.
However, we may not be able to provide you relevant services if you reject to
provide your personal data.
1)
Personal data processing
details
|
Activity |
Type of Data |
Processing Purposes |
Lawful Basis for Processing |
|
When you, on your own
or by authorizing us, sign up with [Imou Partner] for the first time
|
Email address;
nickname; |
To allow us complete
your registration, communicate with you and administer your account. |
Consent
|
|
When you log in and
use services in App |
GPS, mobile device¡¯s
operating system, unique model and its unique identifier, IP address, MAC
address, software version, network access mode & type, latitude &
longitude (if necessary), accelerator (gravity-activated device) and
operation logs |
To offer our services
to you, maintain our services¡¯ normal operations, optimize our services and
secure the safety of your account. |
To perform contract with
you and provide you services
|
|
When you provide feedback |
Phone number |
Used to contact you
to resolve the issue you have provided feedback on |
To perform contract with
you and provide you services |
|
When you make a
purchase |
Name of recipient£¬Phone number£¬Street Address |
Used to send products
to you |
To perform contract with
you and provide you services |
2)
Processing in compliance with
applicable laws
Apart from the
detail activities specified above, we may process your personal
data which is permitted or required by applicable laws:
Ÿ
Processing is necessary for the performance of a contract or in order to
take steps at your request prior to entering into a contract.
Ÿ
Processing is necessary for compliance with a legal obligation.
Ÿ
Processing is necessary in order to protect the vital interests of data
subject or of another natural person.
Ÿ
Processing is necessary for the performance of a task carried out in the
public interest or in the exercise of official authority vested.
Ÿ
Processing is necessary for the purposes of the legitimate interests
pursued by us or by a third party, except where such interests are overridden
by the interests or fundamental rights and freedoms of data subject, in
particular where the data subject is a child.
Ÿ
Other lawfulness of processing as specified in applicable laws.
2. How We Share, Assign and Disclose
Your Personal Data
We may share,
assign or disclose your personal data with our affiliated companies or third
parties in the following circumstances:
1)
Upon your explicit consent:
We may share,
assign or disclose your personal data with third parties after obtaining your
explicit consent or where you provide initiatively to us. You shall be fully
responsible and liable for the personal data obtained from other resources or from
other data subjects.
2)
Trusted third parties:
We may share, assign or disclose your personal data with certain trusted third parties that perform business functions for us
or provide services to us, being our subsidiaries and affiliates; or
contractors, service providers, and other third parties we use to support our
business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which
we disclose it to them.
3)
Required by applicable laws:
We may share,
assign or disclose your personal data to comply with applicable legal
requirements such as court order, legal process, including to respond to any
government or regulatory authority¡¯s request or for investigations (e.g.
disclosure to prevent crime or fraud, or to comply with a court order or legislation).
4)
Merger, acquisition or
bankruptcy:
We may share,
assign or disclose your personal data where there is a merger, acquisition or
bankruptcy procedure. We will require the successor who holds your personal
data to continue to perform the obligations in accordance with this Policy.
5)
Public Interest:
We may share,
assign or disclose your personal data for public interest purpose, such as to
deal with public health emergencies, or, in case of emergency, to protect the
health of natural persons and the safety of their property.
3. Third Party Products and Services:
Third party¡¯s product
or service may also be integrated or embedded on our App. We cannot control
over the third parties¡¯ activities and the personal data you provide to the
third parties is not governed by this Policy. Before providing your personal
data to the third parties, please refer to their privacy
policies and decide carefully whether to use third party¡¯s product or service. We will not be liable for third party¡¯s product or
service in any event.
|
Geetest
Verification SDK |
||
|
Name |
Wuhan Geeyee
Network Technology Co., Ltd. |
|
|
Purpose: |
Provide
secure identity verification during registration or login. |
|
|
Type of data
collected: |
IP address,
device information, operating system. |
|
|
Privacy
Policy |
||
|
Object
Storage SDK
|
||
|
Name |
Alibaba
Cloud Computing Ltd. |
|
|
Purpose: |
Upload data
to object storage. |
|
|
Type of data
collected: |
Device model
and device operating system information. |
|
|
Privacy
Policy |
||
4. How We Protect and Retain Your Personal
Data
1)
Data security measures
We attach
great importance to the security of your personal data. We have taken appropriate
physical, technical and management security measures to prevent your personal
data from accidental losses and from unauthorized access, use, alteration and
disclosure. For instance, we use encryption technology to improve the security
of personal data and trusted protection mechanisms to prevent personal data from
being maliciously attacked.
2)
The retention of personal
data
We will retain
your personal data for no longer than it is necessary for the purposes stated
in this Policy, unless otherwise extending the retention period is required or
permitted by law. To determine the appropriate retention period for personal
data, we may consider the amount, nature and sensitivity of the personal data,
the potential risk from unauthorized use or disclosure of your personal data,
the purposes for which we process your personal data and whether we can achieve
those purposes through other channels. If you want to learn more about the
retention period of your personal data, you may directly contact us at privacy@imoulife.com.
5. How We Protect Children¡¯s Personal Data
Our App is not
designed for children under 16 years of age, or equivalent minimum age in the
relevant jurisdiction (refer to ¡°Child¡± or ¡°Children¡± below). If we become
aware of any personal data related to Children, we will delete that Children¡¯s personal
data unilaterally, unless otherwise the processing is permitted by applicable
law, explicitly consented by the Children¡¯s parents or guardians, or deemed
necessary for the protection of the Children.
6. International Transfers
Since we
have affiliates around the world to offer you services and we may store your personal
data on our servers located in different countries, including
Singapore. In light of this, your personal data may be transferred outside the region or
country where you use the App or Service, which may
have different legal rules
and level of protection on personal data. In such circumstances, we will take necessary measures to ensure that
your personal data is processed in conformity with the
applicable laws, including obtaining your consent to the cross-border transfer
of your personal data, signing standard contractual clauses
approved by the EU Commission when necessary, and taking appropriate technical
security measures to safeguard your personal data.
7. Your Rights
You can send us an email at privacy@imoulife.com to request exercising your rights in
relation to your personal data.
You may also
object to or request us to restrict the processing of your personal data. If we
process your personal data based on consent, you may withdraw your consent at
any time by contacting us at privacy@imoulife.com. A summary of
your legal rights is set out below
Ÿ
Request access to your personal data (commonly
known as a ¡°data subject access request¡±). This enables you to receive a copy
of the personal data we hold about you and to check that we are lawfully
processing it.
Ÿ
Request correction of the personal data that we hold
about you. This enables you to have any incomplete or inaccurate data we hold
about you corrected, though we may need to verify the accuracy of the new data you
provide to us.
Ÿ
Request erasure of your personal data. This
enables you to ask us to delete or remove personal data by entering into¡¾Homepage ¨C Chat Online¡¿where there is
no good reason for us continuing to process it. You also have the right to ask
us to delete or remove your personal data where you have successfully exercised
your right to object to processing (see below), where we may have processed
your data unlawfully or where we are required to erase your personal data to
comply with local law. However, for specific legal reasons, such as it is
mandatory for us to retain your personal data as required by laws, we may not
be able to comply with your request of erasure but we will notify you at the
time of your request in such circumstance, if applicable.
Ÿ
Object to processing of your personal data where we are
relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your personal data which
override your rights and freedoms.
Ÿ
Request restriction of processing of your
personal data. This enables you to ask us to suspend the processing of your
personal data in the following scenarios: (a) if you want us to establish the
data's accuracy; (b) where our use of the data is unlawful but you do not want
us to erase it; (c) where you need us to hold the data even if we no longer
require it as you need it to establish, exercise or defend legal claims; or (d)
you have objected to our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
Ÿ
Request the transfer of your personal data to you or to
a third party. We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format. Note
that this right only applies to automated data which you initially provided
consent for us to use or where we used the data to perform a contract with you.
Ÿ
Withdraw consent at any time where we are relying on consent to
process your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain Apps or services to you. We will
advise you if this is the case at the time you withdraw your consent.
For security reasons,
we will take steps to authenticate your identity before providing access to
your personal data. You also have the right to lodge a complaint with the
relevant Data Protection Authority.
8. Changes to Privacy Policy
We keep this Privacy Policy under review and may
modify this Privacy Policy from time to time. If we make major changes to this
Policy, we will notify you through different channels, for example, by posting
a pop-out notice on the App to notify the major changes.
9. How to Contact Us
If you have any questions or comment on
this Privacy Policy or our privacy practices, please contact us through email
at privacy@imoulife.com, or by mail at:
Hangzhou Huacheng Network Technology
Co., Ltd
13th Floor, Building 3, No. 582, Liye Road, Binjiang District
Hangzhou, Zhejiang Province, P.R. China
310053