360 Smart Camera Privacy Policy

This Privacy Policy was last changed on May 25, 2018.
1 Who we are
Beijing Vision World Technology Co., Ltd., (“we”) respects your privacy and values the trust you place in us when you share your personal data with us. This policy sets out how we, as data controller, collect and use your personal data, why we use it, with whom we share it, the rights to which you may be entitled and your choices about our use of your personal data.
This policy covers our use of your personal data arising from use of 360 Smart Camera, 360 Smart Camera application (“APP”) and our official website (“Website”) (https://jia.360.cn/wap/index_en_US.html).
If you have any questions or need any further clarity, please get in touch. Contact details are set out below.

2 Your information
We will collect and use your personal data to allow your access to and use of 360 Smart Camera, the APP and Website and in accordance with the purposes set out in more detail in this section.

	What we collect	How we use it
1	Information provided as part of your account including: • Your username; • Your password; • Your mobile phone number; • Your email address; • Your 360 Smart Camera serial number; • Your account settings; • Your account preferences.	We use this information, including to: Register an account for you and enable you to log in the account; Associate your account with your 360 Smart Camera; Enable network-enabled features of 360 Smart Camera and provide our services; Verify users’ identity and to prevent fraud; Identify how you'd like to use your account.
2	Information automatically collected about the way you use 360 Smart Camera including: • IP address of your 360 Smart Camera; • The features you use; • Your 360 Smart Camera serial number; • Wi-Fi network information.	We use this information, including to: • Enable network-enabled features of 360 Smart Camera and provide our services; • Associate 360 Smart Camera with the APP; • Identify issues with 360 Smart Camera; • Monitor how 360 Smart Camera is used; • Improve our products and services; • Statistical analysis and research.
3	Information automatically collected about the way you use the APP including: • IP address of your mobile device; • Features you use in the App; • The information of your mobile device such as unique device identifiers (e.g. mac address, IMEI, or IOS token), operation system, etc.; • The pages of the APP you requested and viewed; • The amount of time spent on particular pages; • Whether you've clicked any links of electronic communications from us; • Whether you’ve clicked any marketing communication (including advertisement links) displayed in the APP.	We use this information, including to: • Identify issues with the APP and your experience of them; • Monitor how the APP is used; • Develop new products and services; • Improve our products and services; • Know more about your interest for the purpose of marketing communications; • Personalise our service of things you're interested in and how you use our services; • Statistical analysis and research.
4	Information automatically collected through your use of our Website including: • Date and time of requests; • The requests you make; • The pages you visit; • IP address.	We use this information, including to: • Provide our services; • Develop new services; • Improve our services; • Identify issues with the Website and user's experience of it; • Monitor the way our website is browsed.
5	Video transmission from 360 Smart Camera to our APP: • The primary mode of transmission of video from 360 Smart Camera to our Apps is through a point-to-point direct connection; • If the network condition is unable to support point-to-point transmission, 360 Smart Camera product would relay videos through our servers to the APP to achieve optimal viewing experience. Our servers only serves as a relay agent in such circumstance and would not store any video content transmitted.	The information is transmitted for the purpose of showing videos on our APP. We will not store the video or use it for any other purposes.
6	Cloud video recording. 360 Smart Camera will be activated to record when the algorithm in the camera detects a triggering event, most likely a change in the environment or the happening of an event (such as baby crying, family moment, or unknown person passing by). This feature is optional and you can turn off whenever you want. If you choose to turn on this feature, when a triggering event is detected and recorded by 360 Smart Camera, a video footage up to 5 seconds (up to 30 minutes for users subscribing for our cloud service) will be encrypted and transferred to the cloud storage. Such videos will be stored on the cloud server for up to 7 days (30 days for users subscribing for our cloud service) (“Storage Period”), so that you can playback, download or share the videos.	The video will be activated and recorded to: • Enable more accurate cloud-based analysis and identification of unusual events and security threat and whether any notification or alert should be sent to you; • Send you notifications and alerts of the unusual event (for example baby crying) or security alert (for example unknow person passing by); • Enable you to playback, download or share the videos on the cloud during the Storage Period.
7	Videos and images you choose to label including: • You may label the facial images of your family members with 360 Smart Camera. Such facial images will be uploaded to our cloud so the camera can identify and remember the faces of your family members and won’t report the movement of your family members as unusual events or security threat. • You may choose to label video clips of wrongly reported unusual events and security threat (for example, when 360 Smart Camera reports your family members as strangers and send you an alert).	The videos and images will be used to: • Authenticate and identify your family members; • Train our algorithm and improve our services, so we can detect and identify unusual events or security threat with higher accuracy; • Enable more accurate cloud-based analysis and identification of unusual events and security threat and whether any notification or alert should be sent to you.
8	If you purchase our cloud storage, you provide the information including: • Your account name; • Your bank account or credit card information (which will by collected and processed by the payment processing company and not by us); • Your payment result and the cloud storage plan you purchased.	We use this information, including to: • Take payment from or give you a refund; • Help us ensure that our users are genuine and to prevent fraud; • Statistical analysis and research; • Provide services based on the cloud plan you purchased.
9	Information when you communicate with us whether in person, through our website or via email, over the phone, through social media or via any other medium, including: • Your contact details (this may include your social media account if that's the way you communicate with us); • The details of your communications with us; • The details of our messages to you.	We use this information, including to: • Answer your questions; • Monitor customer communications for service improvement and training purposes; • Develop new services; • Improve our services; • Personalise our services.

Why we collect and how long we keep your information
We collect and use your information for a variety of reasons. We need your information to enter into and perform our contract – for example we need your account information and payment result to perform your purchase of our cloud storage plans.

Some information processing is required by law due to our anti-fraud screening obligations or in the public interest such as making sure we verify our users’ identities.
Some information is processed because you've given your consent to that, for example, the upload of the facial images of your family members. You may withdraw your consent and delete these images through Delete Buttom.
Other information we collect because we have legitimate business interests, for example, in:
•   Understanding how our users use 360 Smart Camera, the APP and website;
•   Delivering our services and communications to you as well as our other users and partners
•   Understanding and responding to customer feedback;
•   Researching and analysing the services our users want;
•   Developing new services and improving our services;
•   Understanding the type of products and services our users buy or use and how they use them;
•   Providing security over our business and who we trade with.
How long we keep your information
We will keep your information for as long as it is reasonably necessary (except cloud video recording as stated above). It will depend on factors such as whether you have an account with us or have interacted with us. We will also routinely refresh our information to ensure we keep it up-to-date. In particular,
•   The video footage uploaded to our cloud through cloud video recording will only be stored during the Storage Period specified in Section 2.6 and you may delete such video footage whenever you want during such period.
•   The facial images you upload will be stored until you deregister your account and stop using our service, but you may delete such record of images whenever you want during the period of storage.

Uses for compliance with legal requirements
Your personal data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defence of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

3   Special information we collect
Certain types of personal data are more sensitive than others, such as health, disability, race, ethnicity, biometrics, etc.
As we set out above in Section 2.6, you may authenticate the facial images of your family members with 360 Smart Camera. Such facial images will be uploaded to our cloud so the camera can identify and remember the faces and won’t report the movement of your family members as an unusual event and security threat. It is solely your responsibility to ensure you have obtained the consent of the data subjects of the facial images to authenticate and upload their facial images.
The images and videos recorded by 360 Smart Camera may contain information of race, ethnicity, biometric or other sensitive information of the persons captured by it. The video will be uploaded only if the cloud recording is enabled and will only be used for providing you with our service, as described by Section 2.6 of this Privacy Policy.

4   Information we share
There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties.

•   We may also share your information with certain contractors or service providers, for example, our database service providers. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function.
Your personal data may be transferred to other third-party organisations in certain scenarios:
•   If your purchase our cloud storage plan, your payment information will be processed the payment processing companies.
•   If we're discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
•   If we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
•   If we're required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
•   If we are defending a legal claim your information may be transferred as required in connection with defending such claim.
360 Smart Camera allows you to share the access to your camera by permitting other people to connect to your camera. These permitted users are able to access the camera and record videos from the camera until you withdraw your permission. We encourage you to exercise discretion and caution with respect to permitting others to access your cameras because we do not control their actions and cannot stop them from sharing videos obtained from your camera with someone else.

5   Where your information will be stored
Some information we collect may be transferred to other countries. If you reside in the European Union, your video and image information (including cloud recording video) would be stored within the European Union, and such information may be accessed from China by us and our external IT services providers. Your account information and other log data would be transferred to China. It does not have equivalent data protection laws to those applicable in the European Union. We do, however, ensure an adequate data protection level by agreements with our data base provider and other arrangements. Please feel free to contact us for further details.

6   Your rights
You may have certain rights in relation to your information including a right to access or to correct the information we hold on you. We've listed the rights you have over your information and how you can use them below. These rights will only apply in certain circumstances. They will generally not be available if there are outstanding contracts between us, if we required are by law to keep the information or if the information is relevant to a legal dispute.
•   You can ask us to confirm if we are processing your information.
•   You access to and correct your account information through Me Tab-clicking of the APP.
•   You can access, watch, download, or delete your video during the Storage Period through My Cloud Record in the APP
•   You can disable Cloud Recording Feature through My Cloud Record in the APP.
•   You can withdraw your consent and delete the facial images of you and your family members uploaded through Delete Buttom.
•   You can ask us to restrict how we use your information.
•   You can ask us to stop using your personal data, but only in certain cases.
•   You have the right to complain to the relevant supervisory authority.

7   Cookies
We use cookies that identify your browser or device. A cookie is a small text file that is stored on a user’s computer or mobile device. We use cookies to record information about your activities on our Website to “remember” you when you return to the Website. You may set your browser setting to attempt to reject cookies and you may still use our Website.

8   Security
We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.
•   We are the first large-scale internet company which appoints the Chief Privacy Officer (“CPO”) in China. CPO is responsible for various affairs related to the users’ personal data that our software and hardware products and services may involve, including formulating privacy policies for various products and services, reviewing the terms of use for the products and services, and supervising implementation of the working principles and data processing mechanism of the products and services. In addition, we have established a department in charge of personal data protection and act under supervision of the public.
•   We transfer and store personal data using encryption to ensure the privacy of such data. 360 Smart Camera uses HTTPs between our APP and server with 2-way authentication interaction to protect your data. All the video stream uses private encryption protocol for anti-hacking and anti-peeping to ensure the security of data transmission.
•   If you have a 360 account, we may analyse the login time, IP address, login times and other relevant information for our risk control and management. If our application adopts WebView technology, we conduct URL verification on all file agreements used in the WebView and restrict the access to the personal data and SD Card data to avoid the malicious misuse of any private documents and sensitive data of our products without special permission.
•   We implement access control mechanism in our service end. We require our employees who may have access to your personal data to obey the principle of data minimization and examine the access list and access records on a regular basis.
•   Our server systems used to store your personal data are equipped with strengthened safeguards. We conduct account audit and monitoring on the operation of our servers. Where any security problem of the server systems is reported, we will immediately complete security upgrades for the server systems to ensure the security of our server systems and applications.
•   We conduct regular training on the relevant laws and regulations related to personal data protection to strengthen our employees’ awareness of privacy protection.
•   If any destruction of our physical, technical or management safeguard measures occurs, we will launch our emergency plan in a timely manner to prevent the spreading effect of the security incident and will report the same to the competent authority in accordance with the relevant laws and regulations. We will also notify you, in a timely manner, of the security incident, potential impacts and the measures we have taken or will take to deal with the incident, in a reasonable and effective way such as pushing notifications and publishing announcements.

9   Changes to the policy
This policy will be changed from time to time.
If we change anything important about this policy (the information we collect, how we use it or why) we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change.
You can email the Data Protection Department for previous versions, you can get in touch at the following email address: privacy@360safe.com
10 How to contact us
If you have any questions about this policy please contact our Data Protection Department: privacy@360safe.com