Last modified: 2024-06-30
Introduction
This Privacy Policy (the “Policy”) applies for Dahua DoLynk Pass service (“Service”) which can be used in [DMSS, DoLynk Pro, WiLynk] platforms (“Platforms”). The Service permits you using a unified account, which you register at either of the Platforms to log in other Platforms and access corresponding services.
The Service is operated by 【Dahua Europe B.V】(“Company”, “we” or “us”). We respect your privacy and is committed to protecting it through our compliance with this Policy. This Policy describes the types of personal information we may collect or that you may provide to us when you use the Service and our practices for collecting, using, maintaining, sharing, protecting and disclosing that information.
This Policy applies only to personal information we process when you use the Service. This Policy does not apply to products or services provided by third party companies or individuals (hereinafter referred to as “Third Party Services”). Please be noted that your personal information may be processed by third parties without our control. You shall consider carefully and decide whether to use Third Party Services and we will not be liable for the Third Party Services in any event.
Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it.
We may modify this Policy from time to time (see “Changes to Policy” below). If you have any issues regarding this Policy, please contact us at [email protected].
1. Definitions
2. How We Collect Your Personal Information and Purpose of Processing
3. How We Share, Assign and Disclose Your Personal Information
4. How We Protect and Store of Your Personal Information
5. How We Protect Children’s Personal Information
6. International Transfers
7. Your Rights
8. Changes to Policy
9. How to Contact Us
1. Definitions
1) Unified Account (Account): the account you create for registration or login at either of the Platforms.
2) Personal Information: shall have the same meaning as “personal data” and shall include any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity. Examples of personal information include your name, telephone number, email address, ID number, and physical address.
3) Personal Sensitive Information: it refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, etc., depending on the definition provided by applicable laws.
4) Platform(s): it refers to a) DoLynk Pro website and DoLynk Pro APP; b) WiLynk website and WiLynk APP; c) DMSS website and DMSS APP.
Either DoLynk Pro, WiLynk or DMSS refers to “Platform” and collectively refer to “Platforms” in this Policy.
5) Service: it refers to DoLynk Pass service which permits you using Unified Account, which you create at either of the Platforms, and can be used for registration, login other Platforms and access corresponding services in the Platforms.
2. How We Collect Your Personal Information and Purpose of Processing
We may collect certain types of personal information you consent to provide to us or when it is necessary to provide our services to you or under which is permitted by applicable laws. We may also collect information that is about you, but individually does not identify you, such as demographic data, information about your internet connection, or your usage details. You have the right to choose whether or not to provide the information we have requested. However, we may not be able to provide you relevant services if you reject to provide your personal information.
1) Account Registration, Login Platforms, Change Password, Close Account
In order to access and use certain functions of our services on the Platforms, you need to create an account (“Account”, or “Unified Account”) and register either of the Platforms. Once you successfully register the Platform, you can use the Account to login other Platforms and obtain corresponding services.
The Account information may include but not limited to a user name, email address, country or region you choose, telephone number, password (encrypted), company name, company address or any other information which is necessary to create a safety Account. (“Account information”).
If you need to make any change of the Account information, the new entries will be collected in replacement of the old ones.
If you choose to close your Account of the Platforms and delete the Account Information, please forward to the channel【Me-Account Management-Delete Account】of all Platforms.
We may process your personal information to provide you Service during the procedures of Account Registration, Login Platforms, Change Password, and Close Account. Refusing to provide your personal information may result in unable to use the Service, but it will not impact your normal use of the Platform’s other functions.
You represent and warrant that: (i) all required Account information you submit is truthful, accurate and complete. (ii) you will maintain the accuracy, security, and confidentiality of Account information; and (iii) your use of the Account does not violate any applicable law or regulation. You also acknowledge that your account is personal to you and agree not to provide any other person with access to these services or portions of them using your Account information. You agree to notify us immediately of any unauthorized access to or use of your Account information or any other breach of security by contacting us at [email protected]. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing your account from a public or shared computer so that others are not able to view or record your Account information.
2) Processing Permitted by Laws
We will obtain your explicit consent before processing your Personal Information unless there is any applicable law permits the processing without your consent:
(1) processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract;
(2) processing is necessary for compliance with a legal obligation;
(3) processing is necessary in order to protect the vital interests of data subject or of another natural person;
(4) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested;
(5) processing is necessary for the purposes of the legitimate interests pursued by we or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of data subject which require protection of personal data, in particular where the data subject is a child.
(6) Other lawfulness of processing as specified in applicable laws.
3. How We Share, Assign and Disclose Your Personal Information
1) Personal Information Sharing
We may share your Personal Information with other companies, organizations and individuals in the following situations:
(1) Sharing upon explicit consent: we may share your Personal Information with other third parties after obtaining the explicit consent of you or other data subject corresponding to or associated with the Personal Information you collect, provide and upload.
(2) Sharing based on mandatory legal requirements: we may share your Personal Information externally according to laws and regulations or the mandatory requirements of government authorities.
(3) Sharing with affiliated companies or other group companies: we may share your Personal Information with our affiliated companies. We should only share your necessary Personal Information and be bound by the stated purpose of the Personal Information it collects. If our group companies intend to change the purpose of processing Personal Information, they shall obtain the explicit authorization and consent of you or other involved data subject.
(4) Sharing with our business partners, or other trusted third-party vendors, such as providing, evaluating, improving, or upgrading services; providing customer support, etc. We may also analyze Service usage, but these statistics will not include any of your identifiable personal information.
(5) We may use certain cloud server providers for purpose of providing the Service, including: Amazon Web Services. Inc. Apart from that, we ensure you that we will not share such data unless you have explicitly requested such sharing.
2) Assignment of Personal Information
We may assign your personal Information to other companies, organizations and individuals in the following circumstances:
(1) Assigning upon your explicit consent;
(2) When there is a merger, acquisition or bankruptcy liquidation, if assigning of your Personal Information is necessary, we should require the successor who holds your Personal Information to continue to perform the obligations herein. Otherwise, we shall require the successor to obtain authorization and consent from you or other data subject separately.
3) Disclosure of Personal Information
Pursuant to relevant laws and regulations, we may disclose your Personal Information without obtaining prior consent in the following situations:
(1) disclosure based on law: to comply with any court order, law or 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);
(2) 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) personal Information is publicly disclosed by you or other personal data that is already legally and publicly disclosed within a reasonable scope in accordance with the laws;
(4) other situations in which data processing is required by the applicable laws and regulations.
4. How We Protect and Store of Your Personal Information
1) Data Security Measures
(1) We shall take all appropriate physical, electronic and management security measures to prevent your Personal Information from accidental losses and from unauthorized access, use, alteration and disclosure. For instance, we shall use encryption technology to improve the security of Personal Information and trusted protection mechanisms to prevent Personal Information from being maliciously attacked.
(2) We highly recommends you to use comprehensive and complex password in protecting the security of your account. We shall ensure the security and confidentiality of Personal Information you provide.
(3) In the case of a personal information leakage and other personal information security incidents, we shall without undue delay and, where feasible, after having become aware of it, notify the personal data breach to you and/or the supervisory authority competent in accordance with the applicable laws and regulations via email, phone, push notification, announcement or any other feasible methods in a reasonable and effective way. We shall inform you including the basic situation and possible impact, the disposal measures that we has taken or will take and recommendations for risk mitigation, etc.
2) The Retention of Personal Information
(1) Storage location
Your Personal Information will be stored on our cloud servers which may be located at United States, Frankfurt Germany, or Singapore.
(2) Retention period
We will retain your Personal Information 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 Information, we may consider the amount, nature and sensitivity of the Personal Information, the potential risk from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In the event where we cease the Service, we will notify you and delete your personal data in concern or anonymize such information within a reasonable period of time.
If you want to learn more about the retention period of your Personal Information, you may directly contact us at [email protected].
5. How We Protect Children’s Personal Information
The Service does not intend to collect, store, process the Personal Information of children under 16 years of age, or equivalent minimum age in the relevant jurisdiction (refer to“Child” or “Children” below).
If we acknowledge about any processing of Personal Information from a Child when you use the Service, without verification of Consent of Guardian, we will delete that Personal Information. If you believe we might have any Personal Information from or about a Child, please contact us at [email protected].
6. International Transfers
Since we have established affiliates in different regions around the world and we may offer our services through the use of servers located in different countries. As such, your Personal Information might be transferred outside the region and country you use our products or services, including to regions/countries outside the European Economic Area (“EEA”) which might have different legal rules and might not offer an adequate level of protection as determined by the European Commission. However, we have taken the necessary measures to ensure that your Personal Information is processed in conformity with the applicable laws and appropriate technical security measures are adopted to safeguard your privacy. Your Personal Information may be stored or processed in multiple countries, including United States, Frankfurt Germany, and Singapore. For the purposes described in this Policy, your information may be transferred to these territories in accordance with applicable law.
7. Your Rights
Your legal rights to your Personal Information are set out below:
· Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you and to check that we are lawfully processing it.
· Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, although we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your Personal Information. This enables you to delete or remove your Personal Information in the Platforms via the channel【Me-Account Management-Delete Account】. Please be noted that if you have set password to your account, you have to verify your account by entering a verification code and successfully completing the verification before Delete Account. You also have the right to request us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we is required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
· Object to processing of your Personal Information where we are relying on our legitimate interest (or that of a third party), and there is something about your particular situation that makes you want to object to processing on this ground as you believe it affects your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
· Request restriction of processingof your Personal Information. This enables you to ask us to suspend the processing of your Personal Information 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.
· Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your Personal Information. 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 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 Information. You also have the right to lodge a complaint with the relevant Data Protection Authority.
8. Changes to Policy
We reserve the right to modify this Policy from time to time at our sole discretion. If we made material modifications to the Policy, we will notify you sending you an alert the first time you use the Service after making the changes. The date this Policy was last modified is identified at the top of the page. All changes are effective immediately when we post them and apply to all access to and use of the Platform thereafter; provided, to the extent required by law, we will seek your affirmative consent prior to applying material modifications to this Policy on how we use or disclose Personal Information that we collected or received prior to the date of the modification. You are expected to check this Policy frequently, so you are aware of any modifications, as they are binding on you once you providing affirmative consent.
9. How to Contact Us
To ask questions or comment about this Policy and our privacy practices, contact us at [email protected], via email or by mail at:
Dahua Europe B.V.
Louis Braillelaan 80, 2719EK Zoetermeer