Mobile App Privacy Policy

Last modified: April 11 2022

Introduction

Hangzhou CE-soft Technology Co., Ltd (“CE-soft,” “we,” or “us”) respects your privacy and is committed to protecting it through our compliance with this Mobile App Privacy Policy (the “Policy”). This Policy describes the types of information we may collect or that you may provide to us when you download, install, register with, access or use the [DMSS] software application for mobile devices and tablets (the “App”), and our practices for collecting, using, maintaining, sharing, protecting and disclosing that information.

This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.

 Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it.

BY CHECKING THE CONSENT BOX FOR THIS POLICY AND THE TERMS OF USE OR USING OR ACCESSING THE APP, YOU (A) ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS POLICY AND THE TERMS OF USE; (B) REPRESENT THAT YOU ARE 18 YEARS OF AGE OR OLDER; AND (C) ACCEPT AND AGREE THAT YOU ARE LEGALLY BOUND BY THIS POLICY AND THE TERMS OF USE.  IF YOU DO NOT AGREE TO THIS POLICY OR THE TERMS OF USE, DO NOT ACCESS OR USE THE APP AND DELETE IT FROM ALL OF YOUR MOBILE DEVICES AND TABLETS.

WE MAY MODIFY THIS POLICY FROM TIME TO TIME (SEE “CHANGES TO OUR PRIVACY POLICY” BELOW).

Children Under the Age of 16

The App is not intended for children under 16 years of age, and we do not knowingly collect personal data from children under 16. If we learn we have collected or received personal data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [[email protected]]

Video and Audio Data

The App allows you to access and view surveillance data captured or recorded by Compatible Hardware (as defined in the Terms of Use).  This “Surveillance Data” comprises (a) video (and in some cases audio) recordings or live feeds or streams and still photographic images; and (b) readings or data from physical or virtual sensors (to the extent offered by or included with Compatible Hardware and supported by the App), including motion detection sensors, event sensors, temperature sensors, window/door sensors, passive infrared sensors, water sensors, carbon dioxide sensors and ambient light sensors. Your Surveillance Data is captured and stored locally on your Compatible Hardware and/or on your device where the App is installed. We treat your Surveillance Data differently than other data types.  Notwithstanding anything to the contrary in this Policy, neither we nor our service providers will access your Surveillance Data, except (a) with your consent for the limited purpose of providing support services to you in connection with the App and/or the Compatible Hardware or for such other purposes as you may authorize or designate, or (b) to the extent legally compelled, including, without limitation, as required by subpoena, judicial order, civil investigative demand, or other similar legal process.

Information We Collect, Purposes of Processing and Legal Grounds

We collect information from and about users of our App:

·         Directly from you when you provide it to us.

·         Automatically when you use the App.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We try to ensure that we only collect and hold personal data that we need for the services and products we are offering to you. Therefore, unless otherwise indicated in the table below, the provision of personal data is a requirement for us to enter into a contract with you or fulfill our contractual obligations. In case that you choose not to provide certain information, you might not be able to take advantage of our services in full or partially.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

ActivityType of data Processing purposesLawful basis for processing 
A. Use of DMSS APP and Cloud
1a. When you sign up with DMSS App for the first timeEmail address; country or region you choose; nickname you use; password (encrypted); profile photo (if uploaded);To allow us complete your registration, communicate with you and administer your account.  Profile photo may be uploaded from local photo album in your mobile phone on a voluntary basis if you desire to have a more personalized account, omission to do so, does not affect the running of DMSS App.Performance of contract for DMSS Terms of Use and legitimate interests to maintain our contractual relationship with you, provide you with services in accordance with the legal requirements of the country/region you have chosen, allow you enjoy the services features as described in the user guide , keep our products updated and relevant, to develop our business and ensure security of products and that your use of our products are in compliance with the accepted terms and conditions. 
1b. When you change the details you used for registrationIf you choose to change any of the above information, the new entries will be collected in replacement of the old ones.To allow the changes you have requested for. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DMSS App’s other functions
2. When you log in and use our servicesApart from the information mentioned under item 1, we process data related to your mobile device and Internet connection you use to log in, like 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 needed), accelerator (gravity-activated device) and operation logs, certain details of your access to and use of the App, including traffic data, logs, and other communication data and the resources that you access and use on or through the App.To offer our services to you, maintain our services’ normal operations, optimize our services and secure the safety of your account.If you do not want us to collect information as specified in item 2, you can turn off the automatic tracking by going to About in your App and disabling the feature of User Experience Plan, or you may not download the App or delete it and clear cache. 
3. When you add Compatible Hardware to DMSS App)Hardware SN; Hardware model; wifi info; Hardware Name; Hardware password (encrypted); Hardware time zone and DST status on/offTo process your request to add a hardware to your account and allow configuration of your hardware. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DMSS App’s other functions.
4. When you use Live View function which provides you a real-time video displayHardware SN; Hardware IP; Hardware Port Information; (real time) Video StreamTo provide you with the basic services of video display through DMSS App
5. When you use Playback and Video Recording functionsHardware SN, Hardware’s Channel ID, Record Files Path, (real time) video streamTo store your history record and allow you view  it
6. When you activate and configure the settings of the added Compatible HardwareMac address; IP address; Hardware SN; Hardware model; Hardware firmware version; Country information (via IP address); Hardware location (via IP); Date of Hardware register; Hardware channel information; Hardware offline/online status; Hardware configuration informationTo allow activation of your Hardware and its registration with our server
7. When you set Hardware name and cover imageCover image; Hardware name; Channel information; Hardware model; Hardware SNYou can set device name, change cover image, and view channel name, device model and SN. The processing of such information is needed for us to allow the changes you have required for and to inform you about the details of the Hardware added on your DMSS account. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DMSS App’s other functions. 
8. When you enter Hardware password or use the reset functionHardware SN; original password (encrypted), your email address (if you reset password via emailTo allow you enhance the security of your Hardware by adding a password or reset your password. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DMSS APP’s other functions.
9. When you use Hardware Share functionHardware SN; Email addressTo allow you the sharing of your Hardware with another user of DMSS App as requested by you. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DMSS App’s other functions.
10. When you use Delete Hardware functionHardware SN; Email and (or) telephone number (only of customers who sign up with DMSS App via their telephone number).To allow the removal of the Hardware from your account on DMSS App and matched accessory as you requested us for. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DMSS App’s other functions.
11. When you receive notificationHardware SN; Push notice ID/alarm snapshotTo send you alarm notifications and provide you the services you have requested us for
12. When you use DMSS App’s cloud services to extend your storage capabilityHardware SN; messages and video record; Hardware channel informationTo allow you use of the cloud storage service (either free or added value version). Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DMSS App’s other functions.
15. When you use User Experience Plan functionBrowsing history & clicking behavior, email address, mac address and your unique identifier.When you enable user experience plan, you give us consent to collect such information and help us improve our products and services and analyse your usage of different functions. Refusing to provide such information may only result in your being unable to use the user experience program, but does not affect your normal use of DMSS App’s other functions.Consent
16. When you communicate with us through email or Feedback functionContent of your communication with usTo communicate with you, provide you with information you request about us, answer your questions or handle your complaintsOur legitimate interests to communicate with you and reply your inquiries/comments
    
17. When you de-register from DMSS App and cease to use our serviceYour telephone number (only of customers who sign up with DMSS App via their telephone number), and (or) Email.To allow us to complete your deregistration, and to delete all your personal data collected by us during the period of your use of DMSS App. 
18. When you use hosting service for device trusteeship purposeYour Email address and your precise geographical locationTo notify the administrator of hosting service the device and DMSS user, and allow the administrator to confirm the location of DMSS device.Consent
B. Other uses of your information
We collect and use your product reviews and feedback for the App, as well as your responses to surveys that we might ask you to complete for research purposes. We use the information we collect to provide or improve services provided by us, our partners, or other trusted third-party vendors, such as providing, evaluating, improving, or upgrading services; participating in market research activities related to our services, developing new services, providing customer support, etc. To improve the services, we may also analyze product usage, but these statistics will not include any of your identifiable personal information.Performance of contract and legitimate interests to keep our services updated and improve them
We collect records and copies of your correspondence (including email addresses), if you contact us. We use your contact details to communicate with you, provide you with information you request about us, answer your questions or when we handle your complaints. We might use these details to send important notifications to you, such as changes in our relevant terms, conditions and policies. Since this information is very important for you to communicate with us, it is suggested that you receive and read such informationPerformance of contract and legitimate interests to administer the contractual relationship with you
We may be required by law to collect and share your identifying information and personal data with public or governmental organizations for the purpose of compliance with the law, a court order, or to respond to any government or regulatory request.Compliance with a legal obligation

 Third-Party Information Collection

When you use the App or its content, certain third parties such as your mobile device manufacturer or your mobile service provider may use automatic information collection technologies to collect information about you or your device. These third parties may use tracking technologies to collect information about you when you use the App. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions, you should contact the responsible provider directly.

Disclosure of Your Information

We may disclose aggregated or de-identified information about our users, and other information that does not identify any individual or device, without restriction.

In addition, we may disclose personal data that we collect or you provide:

·         To our subsidiaries and affiliates to deliver services or facilitate the provision of services to you.

·         To 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.

·         To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Company about our App users is among the assets transferred.

·         For any other purpose disclosed by us when you provide the information.

·         With your consent.

We may also disclose your personal data:

·         To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·         To enforce our rights arising from any contracts entered into between you and us, including the App Terms and Conditions and for billing and collection.

·         If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

·         Tracking Technology. You can turn on the tracking technology in the App by going to About in your App and disable the feature of User Experience PlanIf you disable the use of the tracking technology, you will still be able to use the App and the App will still function properly, however, you might experience issues such as minor lagging.

·         Location Information. This App does NOT collect real-time information about the location of your device. It only identifies and collects the information on the country and/or region you are located in when you are signing in to the App for assigning your app to connect with a nearest server of ours. The location information collected is not personally identifiable.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

Accessing and Correcting Your Personal data 

You can review and change your personal data by logging into the App and visiting your account profile page. If you are not able to find your personal data, you may also send us an email at

[email protected]

 to request access to, correct, or delete any personal data that you have provided to us. 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 (see below). A summary of your legal rights is set out below:

·         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.

·         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, although we may need to verify the accuracy of the new data you provide to us.

·         Request erasure of your personal data. This enables you to ask us to delete or remove personal data if 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 information unlawfully, or where we are required to erase your personal data 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 data 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 data 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 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.

·         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 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 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 products 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.

If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users. Proper access and use of information provided on the App, including User Contributions, is governed by our Terms and Conditions.

Data Security

We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure.

Your personal data will be retained for as long as required for the purposes described in this Privacy Policy or insofar as such is necessary for compliance with statutory obligations and for solving any disputes.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorised 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 means; and the applicable legal requirements.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through our App. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We reserve the right to modify this Privacy Policy from time to time in our sole discretion. If we made material modifications to the Privacy Policy, we will notify you sending you an in-App alert the first time you use the App after we make the change. The date this Privacy Policy was last revised 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 App thereafter; provided, to the extent required by law, we will seek your affirmative consent prior to applying material modifications to this Privacy Policy on how we use or disclose personal data that we collected or received prior to the date of the modification. You are expected to check this Privacy Policy frequently, so you are aware of any modifications, as they are binding on you.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Email: [[email protected]]

Postal Address: [POSTAL ADDRESS AND RECEIPENT INFO]

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