GuoanVision Privacy Policy

Effective Date: November 19th, 2024

GuoanVision Inc. and its Affiliates (as hereinafter defined) ("we", "us", "our", or "GuoanVision") are committed to protecting your privacy. This GuoanVision Privacy Policy (this “Policy”) describes our practices in connection with information privacy on Personal Data (as hereinafter defined) we process through your use of our products and services(collectively, the “Services”), for instance the GuoanVision Mobile Application (the “App”) and its connected Smart Devices.

Before you start using the Services, please carefully read this Policy which details our purposes for collecting and processing your Personal Data, as well as how we use, store, share and transfer your Personal Data. In this Policy you will also find ways to exercise your rights of access, update, delete or protect your Personal Data.

When you agree to this privacy policy, or start and continue to use our products or services in an appropriate way, and do not contact us in an appropriate way to express a contrary opinion, we will consider that you fully understand and agree to this policy. During the reading process, if you have any questions, comments, suggestions or complaints, please contact us through the following contact information: support@guoanvision.net

You are not obliged to provide to us your Personal Data (as defined below). However, we may be unable to provide you with certain products and/or Services if you decline to provide such data.

Definition

In this Policy:

Affiliate means any company, firm or legal entity that: (1) is directly or indirectly controlled by GuoanVision; or (2) directly or indirectly controls GuoanVision; or (3) jointly with GuoanVision, controls the same company; or (4) is, directly or indirectly, under common control of the same company with GuoanVision. Affiliates shall include, without limitation, GuoanVision parent companies, subsidiaries, and such subsidiaries under common control of the same parent company as GuoanVision.

Personal Data:

Electronically or otherwise recorded information that can be used alone or in combination with other information to identify individuals or reflect specific personal activities.

Personal sensitive Data:

Including personal biometric data, communication records and contents, health information, transaction information, and accurate location information. When we provide you with specific products or services and involve the collection of personal sensitive data, we will obtain your consent through a significant and clear notice before collecting your personal sensitive data.

Smart devices:

Refers to non-standard computing devices produced or manufactured by hardware manufacturers, which have human-machine interfaces and can transmit information through wireless networks, including intelligent household appliances, intelligent wearable devices, intelligent air purification devices, etc.

Application:

Refers to the mobile application provided by GuoanVision Inc. which can help end users remotely control intelligent devices and connect to the supplier's Internet of things (IOT) platform

GDPR Compliance Statement

Our app strictly complies with the requirements of the General Data Protection Regulation (GDPR). Below are the detailed explanations regarding data collection and sharing.

What personal information do we collect

In order to provide you with our services, we will ask you to provide the personal data necessary for such services. If you do not provide personal data, we cannot provide you with corresponding products or services.

The information you voluntarily provided to us

Account data:

When you register or log in to our account, we will collect your account number and contact information, such as your email address, phone number, user name and login credentials. During your interaction with our products, we will further collect the nickname, avatar, country code, language preference or time zone information in your account.

Feedback:

When you use the feedback and suggestion function in our products, we will collect your email address, mobile phone number and feedback content in order to deal with your problems and equipment failures in a timely manner. At the same time, according to different application products and services, we will collect corresponding and necessary personal information to provide you with products and services.

Information collected based on the additional functions:

In order to provide you with more convenient and better products and / or services and strive to improve your experience, we will collect and use your personal information in the following additional services provided to you. If you do not provide this information, it will not affect your use of the basic services of [GuoanVision app], but you cannot obtain the user experience brought by these additional services. These additional services include:

Additional services based on location information:

When you enable the location function of mobile devices through system authorization and use location-based services, we will collect and use your location information so that you can use [GuoanVision app] to distribute networks with smart devices. And when you use our specific products or services (such as weather services), based on your consent, we will collect real-time accurate or inaccurate geolocation information about you. You can turn off the location service in the system of your mobile device and stop our collection of information about your location.

Camera / camera based add-on services:

You can use this function to scan the code after turning on the camera / camera permission, which is used to add the equipment you purchased, shoot videos and other functions. Please know that even if you have agreed to turn on the camera / camera permission, we will only obtain information when you actively scan the code, shoot, etc. to use the camera / camera.

Additional services for image / video access and upload based on photo album (image library / Video Library):

You can use this function to upload your photos / pictures / videos after opening the photo album permission, so as to realize the functions of changing avatars, reporting equipment use problems and providing certificates. When you use avatar and other functions, we will not recognize this information; However, when you report a device usage problem, we will locate your problem through the photos / pictures you upload.

Additional services related to microphone based voice technology:

You can use the microphone to realize voice functions after you turn on the microphone authority, such as shooting video, waking up the voice assistant, etc. in these functions, we will collect your voice information to identify your command needs. Please know that even if you have agreed to turn on the microphone permission, we will only get voice information through the microphone when you actively click the microphone icon in the app or record video.

Additional services based on storage permissions (Android):

We apply to you for this permission in order to ensure the stable operation of the client. After you turn on the permission that we can read / write to your device storage, we will read or write necessary information such as pictures, files, crash log information from your device storage space to provide you with functions such as information publishing or local recording of crash log information.

Additional services based on Notification permission:

The reason why we ask you for the permission is to send you notifications about using the products and services, especially if you have purchased security services and you require an alert or message so that you can capture the real-time status. You may opt-out the using of App notifications: "Me - Message Center - Setting - Switch on/off Notifications".

Additional services based on Bluetooth permission:

You can enable Bluetooth functions after turning on the permission, including controlling the Smart Devices, acquiring device status, and device network configuration. In these functions, we will communicate with terminal devices via Bluetooth. Please be aware that even if you have agreed to enable the Bluetooth permission, we will only use Bluetooth for communication in these scenarios: display device status on the home page and device panel; perform device control on the home page and device panel; we will use it on the home page and the add device page, for discovering the devices via distribution network.

You understand and agree that the above additional services require you to open the access rights of your location information (geographical location), camera (camera), photo album (Picture Library), microphone (voice), address book, calendar and / or phone status in your device, so as to realize the collection and use of the information involved in these rights. You can check the status of the above permissions one by one in your device settings, and you can decide whether these permissions can be turned on or off at any time.

Please note that by opening any permission, you authorize us to collect and use relevant personal information to provide you with corresponding services. Once you close any permission, you cancel the authorization. We will no longer continue to collect and use relevant personal information based on the corresponding permission, nor can we provide you with the services corresponding to this permission. However, your decision to close the permission will not affect the previous information collection and use based on your authorization.

Information we collect automatically

Device information:

When you interact with our products, in order to ensure your normal use of our services, maintain the normal operation of our services, improve and optimize our service experience, and ensure the security of your account, we will automatically collect device information, device model, operating system, device hardware serial number (refers to a string of strings programmed into the device by the device manufacturer as the unique identifier of the device), Android ID Login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log file and mobile network information.

Usage data:

During your interaction with our website and services, we will automatically collect usage data related to accessing, clicking, downloading, sending / receiving messages and other uses of our website and services.

Log information:

When you use our application, the system and exception logs will be uploaded, including your IP address, language, version of the operating system, date or time of access, etc.

Please note that separate equipment information and service log information are information that cannot identify a specific natural person. If we combine this kind of non personal information with other information to identify the identity of a specific natural person, or combine it with personal information, during the combined use, this kind of non personal information will be regarded as personal information. Unless otherwise authorized by you or stipulated by laws and regulations, we will anonymize and de identify this kind of information.

Location information:

When you enable the location function of mobile devices through system authorization and use location-based services, we will collect and use your location information so that you can use the GuoanVision app application to distribute the network with smart devices. And when you use our specific products or services (such as GuoanVision APP), based on your consent, we will collect real-time accurate or inaccurate geographic location information about you. You can turn off the location service in the system of your mobile device and stop our collection of information about your location.

Please note that one cannot identify a specific individual by using device information or log information alone. However, as these types of information, combined with other information, may be used to identify a specific individual, such information will be treated as Personal Data. Unless we have obtained your consent or unless otherwise provided by data protection laws and regulations, we will aggregate or desensitize such information. Additionally, please refer to section titled “Data Retention” of this Policy for data retention periods of such Personal Data.

Information about smart devices

When you use a Smart Device, we will collect some basic and pre-embedded information of the Smart Device and the information generated during your use of the Smart Device.

Basic information of smart devices:

When you use smart devices connected to our products or services, we will collect basic information about smart devices, such as device name, device ID, online status, activation time, firmware version and upgrade information.

Information collected during the process of connecting to a Smart Device:

Based on the type of Smart Device you need to connect, whether the Smart Device is connected via Wi-Fi, via Wi-Fi after establishing a local connection via Bluetooth, via Bluetooth or via Zig-bee, we will collect the Mac address of the smart device.

Information reported by smart devices:

According to the different smart devices you choose to connect with our products or services, we will collect the information reported by your smart devices. When you connect a doorbell camera, a door lock, or a smart surveillance camera through GuoanVision service to monitor the security of your residence, during the process, the device may capture the images if it recognizes someone or an object is moving around, and then provide you a playback of related surveillance content. At this time, we will automatically encrypt the captured image and save it locally on the device.

Purpose and legal basis for processing personal data

We process your information for the following purposes:

Provide services for you:

We process your account and personal data, device information, usage data, location information and smart device related information to provide the products and services you request or purchase. The legal basis for this processing is to perform our contract with you according to our User Agreement.

Safety of Our Services:

We process your mobile device information, usage data, location information and Smart Device related information to ensure the functions, and authentication, integrity, security and safety of accounts, activity, products and the Services, to develop and upgrade the Services, to study in-depth the efficiency of our operations and to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is as necessary for our (or others’) legitimate interests.

Non Marketing Communication:

We process your Personal Data to send you important information regarding the Services, changes to our terms, conditions, and policies and/or other administrative information. At the same time, we will also send you notices related to your purchase of services, such as alarm services. You can check the “App Notification” in the App (Me > Message Center > Setting) to manage these communications. When you decide not to enable the Notifications function, we will no longer process your information for such purpose. The legal basis for this processing is to perform our contract with you according to our User Agreement.

Data analysis:

In order to analyze the use of the products we provide and improve your user experience, we will analyze the data you provide and report, timely check your problems in the process of using the products, and analyze the products or use scenarios related to you, so that you can better enjoy the convenience brought by our products. We do not use user data for personalized advertising or marketing, nor do we combine user data with third-party data for such purposes. If you don't agree with our analysis of your data, you can enter the privacy settings of GuoanVision app ([me] - [settings] - [privacy settings] - [data analysis]) to close your selection. The legal basis for such treatment is based on your consent.

Legal Compliance:

We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

Comply with applicable laws and regulations;
Comply with legal procedures;
Respond to the requirements of public institutions and government authorities;
Fulfill our terms and conditions;
Protect our operations, businesses and systems;
Protect the rights, privacy, security or property of us and / or other users, including you; as well as
Seek available remedies or limit the damages we need to provide.

We also collect your personal information in other ways. We will provide specific notice at the time of collection and obtain your consent in accordance with the requirements of applicable laws. If there is any change in the purpose of processing your personal information, we will notify you of such change through email and / or a prominent notice on our website, and inform you of your choice of personal information.

Who do we share your personal data with?

At GuoanVision, we only share Personal Data in ways that we tell you about. Without your consent, we will not disclose your Personal Data to third-party companies, organizations, or individuals except in the following cases:

To our third-party service providers who perform certain business-related functions for us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us.
To our customers and other business partners who provide you, directly or indirectly, with your Smart Devices, and/or networks and systems through which you access and use our websites and Services.
Our app does not share any collected data with third-party data brokers.
To subsidiaries or affiliates within our corporate family for purpose of regular business activities based on our instructions and in compliance with applicable law, this Policy and other appropriate confidentiality and security measures.
To an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, you will be notified via email and/or a prominent notice on our website of any change in ownership, and choices you may have regarding your Personal Data.
As we believe in good faith that access to, or use, preservation, or disclosure of the information is reasonably necessary or appropriate to:
1. Comply with applicable laws and regulations;
2. Comply with legal procedures;
3. Respond to the requirements of public institutions and government authorities, including those outside the country / region where you live;
4. Fulfill our terms and conditions;
5. Protect our operations, businesses and systems;
6. Protect the rights, privacy, security or property of us and / or other users, including you;
7. Perform risk management, screening and checks for unlawful, fraudulent, deceptive or malicious activities.

Except for the third parties mentioned above, we only disclose your Personal Data to other third parties with your consent.

When you use services provided by third parties, we will make sure that sharing of your Personal Data with such third parties are based on their obtaining your authorization and/or consent, or otherwise in conformity with applicable laws and regulations. We will also make our efforts to manage sharing of any information with these third parties in order to preserve the security of your relevant personal information. For details on such third parties information sharing, please see "List of Third-party Information Sharing". We encourage you to carefully read the privacy policy of any third party with which you interact.

In addition, to ensure operations of the App or to enable certain independent functions, we may embed third-party SDKs in the App. Please note: the types of Personal Data that these third-party SDKs may process are subject to change at any time due to upgrade, updates or policy changes, and you should rely on relevant latest information on the official websites or otherwise made available by such third parties. For details of these SDKs, please see "List of Third-party SDK Services".

List of Third-party Information Sharing

Third-Party Service Providers as data processors (for EU users):

Name	Location of Data Processing	Scope of Processed Data	Purpose of Data Processing	Privacy Policy
Amazon Web Services, Inc.	EU	All data stored though the Cloud: Cloud service; phone number and Email address: SMS, Emails.	Enable cloud services via IaaS; data storage in data center instances for the data controller.	https://aws.amazon.com/compliance/data-privacy
Microsoft Azure	EU	App Version, User ID.	Notification of App version for update and App function upgrade sent to users; Push and Map services.	https://privacy.microsoft.com/privacystatement
Hangzhou Tuya Information Technology Co., Ltd.	China PR	applicable user data according to requirement to fulfill users' requests of technical support/troubleshooting or data requests.	To enable Service Provider's technical team to provide technical support, troubleshooting and/or other requested services from App users. The scope of user data is strictly limited to those necessary for the purpose and all personnel that may have access to such data are strictly subject to access control systems and contractually bound to be given access on need-to-know basis and to keep any data accessed confidential.	https://developerapp.tuyaeu.com/protocol/1479c88e9cc0101a?lang=en

List of In-App Third-party SDK Services

Name	Third party entity	Purpose of usage	Scenes to be used	Privacy Policy
Google SDK(Android)	Google LLC	Google may use different types of location information to make certain services and products more useful to you, depending on the product you use and the settings you choose. This location information includes: GPS and other sensor data from your device IP address Activity across Google services, such as your searches or places you've marked (such as your home or work address) Information about things surrounding your device, such as Wi-Fi access points, base stations, and Bluetooth-enabled devices	In order to return the user's location information to the application, display the user's location on the map, and provide developers with corresponding services based on the user's location information.	https://policies.google.com/privacy#infocollect
FCM SDK(Android)	Google LLC	Push messages to the phone system notification bar	IP address（How to help: Cloud Functions uses IP addresses to execute event handlers and HTTP functions based on end-user actions；Retention: Cloud Functions temporarily stores IP addresses solely for the purpose of providing the service.）Firebase Cloud Messaging（Firebase Cloud Messaging uses Firebase installation IDs to determine which devices to send messages to.）	https://firebase.google.com/support/privacy
Shangyun P2P SDK	Shenzhen Shangyun Internet Technology Co., Ltd.	To realize the video preview function of IPC equipment	Usage scenario: When connecting to an IPC device to use the preview function Shared information: camera device ID, network information (IP, current network type and name) Sharing method: SDK local collection, background interface transmission Information collection details: No personal information is collected	http://www.cs2-network.com
Zendesk SDK	Zendesk, Inc.	Provide customers with a rich, clean messaging experience, and facilitate customer support interactions	Usage scenario: When customers initiate a chat or submit a support ticket Shared information: device information (OS version, device type), chat or ticket content submitted by the user	https://www.zendesk.com/company/agreements-and-terms/privacy-notice/

Data Transfer

We stores the data in the corresponding jurisdiction in accordance with the data localization requirements under applicable laws and regulations. Under the Personal Data protection framework and in order to facilitate our operation, we may transfer, store and process your Personal Data in jurisdictions other than where you live.

We protect Personal Data in accordance with this Policy wherever it is processed and take appropriate contractual or other steps to protect it under applicable laws.

The European Commission has determined that certain countries outside of the European Economic Area (EEA), the UK or Switzerland can provide adequate protection of Personal Data. Where Personal Data of users in the EEA, Switzerland, or the UK is being transferred to a recipient located in a country outside the EEA, Switzerland, or the UK which has not been recognized as having an adequate level of data protection, we ensure that the transfer is governed by the European Commission’s standard contractual clauses. You can review the agreement on the basis of approved EU standard contractual clauses per GDPR Art. 46. For more information, see here.

If you would like further details on the safeguards we have in place under the data transfer, you can contact us directly as described in this Policy.

Rights related to personal data

We respect your rights and will also have access to your personal data. You may exercise any of the following rights:

Customer confirmation:
Email address dealing with privacy rights; Or provide other contact information, such as phone number, such as a separate privacy response page, so that users can submit privacy requests. At least 2 ways are provided.
You don't need to pay any fees. We will complete the inspection and processing within 15 working days or 30 natural days. If you decide to send us a request by email, please state what information you want to change, whether you want to delete your personal data from our database, or what restrictions you want us to be subject to when using your personal data. Please note that for security reasons, we will ask you to verify your identity before further processing your request.

You can:

Request access to personal data related to you processed by us;
Ask us to correct inaccurate or incomplete personal data related to you;
Ask to delete your personal data;
Require us to temporarily or permanently restrict the processing of some or all of your personal data;
Require us to process your data based on your consent or the contract signed with you, and transfer personal data to yourself or a third party when we automatically process your data;
When we use your personal data based on your consent or our legitimate interests, we choose to oppose or refuse us to use your personal data.

About withdrawal of consent:

We will guarantee your right to withdraw your consent in the following ways:

The privacy rights obtained through the device system settings can revoke your consent by changing the device permissions, including location, camera / camera, photo album (picture library / Video Library), microphone, Bluetooth settings, notification and other related functions;
In the non marketing communication you agree, turn off your selection through [me] - [message center] - [app message notification];
When you agree to the data analysis function, close your selection through [me] - [settings] - [privacy settings] - [data analysis];
In the personalized push service you agree to, click [me] - [settings] - [privacy settings] - [personalized push service] to turn off your selection;
Unbind the smart device through the application, and the information you use the smart device will not be collected;

When you withdraw your consent or authorization, we cannot continue to provide you with the services corresponding to the withdrawal of authorization. However, your withdrawal of consent or authorization will not affect the personal information processing based on your consent before withdrawal.

Safety assurance measures

We take commercially reasonable physical, management and technical guarantee measures to maintain the integrity and security of your personal data. We provides a variety of security strategies to effectively ensure the data security of users and devices. In terms of device access, we guarantee data security, access authentication and authorization application. In terms of data communication, it supports the use of security algorithms and transmission encryption protocols, as well as business level information encryption transmission based on dynamic keys. In terms of data processing, strict data filtering and verification and a complete data review process are adopted. In terms of data storage, all confidential information of users will be securely encrypted for storage. If you think that your interaction with us is no longer safe for any reason (for example, you think the security of your account has been compromised), please send an email to support@guoanvision.net Let us know immediately.

Data retention period

We will confirm within the shortest time limit to achieve the purpose stated in the cost policy: if there is a specific period, please describe the processing of your personal data within the shortest time limit, unless it needs to be retained for a long time according to specific legal requirements. We will decide the appropriate retention period according to the quantity, nature and sensitivity of personal data. After the retention period, we will destroy your personal data. If we are unable to destroy the data for technical reasons, we will take appropriate measures to prevent further use of your personal data.

Personal information protection of children

Protecting the privacy of young children is especially important to us. The Services are not directed to individuals under the age of sixteen (16) (or such other age provided by applicable law in your country/region of residence), and we request that these individuals do not provide any Personal Data to us. We do not knowingly collect Personal Data from any child unless we first obtain permission from that child’s parent or legal guardian. If we become aware that we have collected Personal Data from any child without permission from that child’s parent or legal guardian, we will take steps to remove that information.

California Privacy Rights

California Civil Code Section 1798.83 permits users of the Software that are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please contact us in accordance with the "Contact Us" section below. We do not disclose Personal Data to third parties for their direct marketing purposes without your consent. Visit our Statement on California Privacy Notice page for more information.

Statement on policy changes

We will update this policy according to changes in information practice. If we make any significant changes, we will notify you by email (sent to the email address specified in your account), or publish the notice on the mobile app before the change takes effect. We recommend that you browse this page regularly to get the latest information about privacy practices.

Contact us

If you have any questions about our practices or this policy, please contact us through the following ways:

Shenzhen Guoan Vision Technology Co., Ltd.

Mailing address: 309, Building 5, Phase 2, Tian’an Cloud Valley, Bantian Street, Longgang District, Shenzhen, Guangdong, China

Mail box: support@guoanvision.net