Privacy statement

Effective Date:2021-08-11

Updated Date:2021-08-11

Dongguan Anhong Electronic Technology Co., Ltd. and its affiliated companies and subsidiaries (hereinafter referred to as "we", "us", "Anhong Electronics") are committed to protecting your privacy. This Privacy Statement (hereinafter referred to as "Statement") explains how we process personal data and ensure information privacy during your use of the following services, products, and related mobile applications (collectively referred to as "Products").

• BabyCam App

In this privacy statement, "personal data" refers to information that, used alone or in combination with other information, can identify an individual. "Smart device" refers to non-standard computing devices with a human-machine interface produced or manufactured by hardware manufacturers and capable of transmitting data via wireless networks. "App" refers to the mobile application developed by Anhong Electronics Company that helps end-users remotely control smart devices and connect to the Anhong Electronics IoT platform.

For other brand apps supported by Anhong Electronics, it will be up to our customers to decide what personal data to collect through our products. We collect information based on customer requests, and the processing of such information is limited to providing the services agreed upon with our customers. If you are a user of our customer and do not wish to be contacted by customers using our services, please contact the customer directly and inform them of your request.

What personal data do we collect?

In order to provide the Services to you, we will ask you to provide necessary Personal Data that is required to provide those Services. If you do not provide your Personal Data, we may not be able to provide you with the Services.

While you are still in the process of learning about our products, you can try using them without registering/logging in. When you log out or do not create an account (i.e., in "login-free" mode), you can still use many of BabyCam's products or services with a guest identity ID, such as searching or browsing the features available on the BabyCam application. When you use the login-free mode, we will not collect your account and related information; the information we collect is limited to the permissions information for additional features you have authorized, as well as information about your device and its usage, such as the operating system of your phone. When you use features in our products and/or services that require location services, we will obtain location information based on your authorization. When you choose to exit the login-free mode, we will immediately and permanently delete your information.

However, if you are using or purchasing products and/or services based on your account information, please go to the registration/login page to register or log in.

1. The information you voluntarily provide to us

Account Information: When you register for our account, we collect your account name and contact information such as your email address, phone number, username, and login credentials. During your interaction with our products, we further collect information from your account such as nickname, avatar, country code, language preferences, or timezone information.

If you choose to authorize the use of third-party accounts for login, we will obtain the account information you share from the third party (such as profile picture, nickname, regional information) and bind it to your BabyCam account for quick login. We will use your personal information in accordance with the agreements with third parties and the terms regarding the sharing of personal information in the privacy policies published by third parties, provided that this is in compliance with relevant laws and regulations.

Feedback: When you use the feedback and suggestion feature in our product, we collect your email address, phone number, and feedback content to address your issues and device malfunctions in a timely manner.

At the same time, BabyCam will collect corresponding and necessary personal information according to different application products and services in order to provide you with products and services.

Information based on additional functions:

Based on the information collected from the provided additional features

To provide you with more convenient and better products and/or services, and to enhance your experience, we will collect and use your personal information in the following additional services we offer to you. If you do not provide this information, it will not affect your use of the BabyCam application, but you will not be able to enjoy the user experience that these additional services bring. These additional services include:

(1)Location-based additional services:

When you enable the location function on your mobile device through system authorization and use location-based services, we collect and use your location information to allow you to pair your BabyCam application with smart devices. Additionally, when you use our specific products or services (such as weather services), based on your consent, we collect real-time precise or non-precise geolocation information about you. You can turn off the location services on your mobile device to stop our collection of your location information.

Based on your consent, when you enable the geo-fence feature, your location information will be generated and shared with Google Maps services. Please note that Google has corresponding data protection measures, which you may refer to Google Data Protection Terms for more details. You may disable the collection and use of your location information by managing the device level settings, upon which we will cease to collect and use your location information.

(2)Camera-based additional services:

You can use this feature to scan a QR code to add your purchased device, take videos, etc., after enabling camera/camera permissions. Please be aware that even if you have agreed to enable camera/camera permissions, we will only access information when you actively scan a QR code or take a video, etc. using the camera/camera.

(3)Additional services for accessing and uploading images/videos based on the photo/video library:

You can use this feature to upload your photos/pictures/videos after enabling album permissions, to change your avatar, report device usage issues as proof, and other functions. When you use functions like changing your avatar, we do not identify this information; however, when you report device usage issues, we will locate your problem through the photos/pictures you upload.

(4)Microphone-based voice technology related additional services:

You can use the microphone to enable voice features, such as recording videos or waking up voice assistants, after granting microphone permissions. We will collect your voice information in these features to recognize your command needs. Please be aware that even if you have agreed to enable microphone permissions, we will only access voice information through the microphone when you actively click on the microphone icon within the App or record a video.

(5)Additional services based on storage permissions:

We apply for this permission to ensure the stable operation of the client. After you enable our permission to read/write to your device storage, we will read or write necessary information such as images, files, crash logs, etc., from or to your device storage space. This is used to provide features like information publishing or recording crash logs locally.

(6)Additional features based on message notification permissions:

We request this permission from you in order to send you notifications about our products or services, especially if you have purchased related services, so that we can send alerts to you to catch real-time conditions.

You understand and agree that the above additional services require you to enable location information (location), camera (camera), photo album (photo library), microphone (voice), and access to internal and external storage on your device to collect and use the information involved. You can check the status of these permissions individually in your device settings and decide whether to turn these permissions on or off. The permission requests for location information (location), camera (camera), photo album (photo library), microphone (voice), and internal and external storage are mainly used for device addition, device usage, and other functional implementations.

Please note that by enabling any permission, you grant us authorization to collect and use your personal information to provide you with the corresponding services. Once you disable any permission, it means you have revoked your authorization, and we will no longer collect and use your personal information based on that permission, nor will we be able to provide you with the services corresponding to that permission. However, your decision to disable a permission will not affect the collection and use of information that has been carried out based on your previous authorization.

2.Information we collect automatically

Mobile Device Information: When you interact with our products, to ensure the 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 mobile device information, such as device model, IMEI, operating system, login IP address, wireless connection information, operating system type and version, application version number, push notification identifier, log files, and mobile network information. At the same time, we will collect your software version number. To ensure the security of the operating environment or as required to provide services, we will collect information about the mobile applications and other software you use.

Use of Information: During your interaction with our website and services, we automatically collect usage information related to visits, clicks, downloads, sending/receiving messages, and other uses of our website and services.

Log Information: When you use our application, system and exception logs are uploaded, which include your IP address, the language used, the version of your operating system, and the date or time of access.

MAC address:When you interact with our smart devices, to ensure stable device connection and high-speed response from the server, we collect the MAC address of your mobile phone.

IMEI:When you are adding our smart device, to ensure identification and addition, we will obtain the device's IMEI information.

SSID:When you are adding our smart devices, to ensure the device connects to the network successfully, we will obtain the SSID information you input. This information is only used for network setup purposes.

Please note that individual device information and service log information are types of data that cannot identify specific individuals on their own. If we combine this non-personal information with other information to identify specific individuals, or if we use it in conjunction with personal information, during the period of such combined use, this non-personal information will be treated as personal information. Unless we have obtained your authorization or there are other provisions in laws and regulations, we will anonymize and de-identify this information.

3.Information about smart devices:

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

Information Reported by Smart Devices: Based on the different smart devices you choose to connect with our products or services, we collect information reported by your smart devices. For example, smart scales or fitness trackers report your height, weight, body fat mass (BFM), body mass index (BMI), and skeletal muscle mass (SMM); smart cameras collect images or videos they capture. Please note that when you actively agree to connect the BabyCam application with health apps, we will share your measurement data with the third-party health platforms you choose (such as Apple Health, Google Fit, Fitbit, etc.), which includes only your BMI, height, weight, and body fat percentage data. The purpose of sharing data is solely for measuring and analyzing health-related indicators related to you, and it will never be disclosed to any other third parties. You can always turn off the authorized connection between the BabyCam application and third-party health platforms through the HealthKit settings page.

Bugly collects information:When you use our products, we also collect: log information (including: third-party developer custom logs, Logcat logs, and APP crash stack information), device IDs (including: androidid and idfv), network information, system name, system version, and country code.

Regarding children's use of this application

Our services are primarily aimed at adults aged 18 and over. If you are under 18 but need to use this application, you will need your legal guardian to read this statement with you and obtain their consent. Additionally, we recommend that your legal guardian supervise and guide your use of this application.

Purpose and legal basis for processing personal data.

The purpose of our processing of your information is as follows:

We provide services:We process your account and user profile data, device information, usage data, location information, and information related to your smart devices, aiming to provide the products and services you request or purchase. The legal basis for such processing is our performance of the service terms in the contract we have with you.

Improve our services:We process your device information, usage data, location information, and information related to your smart devices, aiming to ensure the functionality and security of our products, develop and improve our products and services, analyze our operational efficiency, and prevent fraud or misuse. The legal basis for such processing is our performance of the relevant service terms in the contract we have with you.

Non-marketing communication:We process your personal data in order to send you important information regarding services; changes to terms, conditions, and policies; and/or other administrative information. Due to the importance of such information, you may not be able to opt out of receiving such emails. The legal basis for such processing is our performance of the contract with you, including the terms of use of the service.

Marketing communications:We process your personal data in order to provide you with marketing and promotional information related to our products and services. In such cases, each email we send you contains instructions that allow you to choose not to receive such emails anymore. Additionally, if you agree to participate in our giveaways, contests, or other promotional activities, we may use your personal data to manage these activities. The legal basis for such processing is based on your consent.

After-sales maintenance service:To achieve specific business functions of various Bugly SDKs, such as: reviewing Logcat logs and analyzing the APP crash stack information to address the abnormal crashes encountered by the APP.

Compliance: We will process your personal data where we consider it necessary or appropriate to do so: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of yours or other users; and (g) to seek available remedies or limit our damages.

With whom do we share your information and personal data?

In BabyCam, we share your personal data only in ways that you are already aware of.

We may share your personal data with the following participants:

We may disclose your personal data to third-party service providers who provide certain business-related services to us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support services, email delivery services, and other similar services, so that they can provide services to us.

Disclose your personal data to customers and other business partners who directly or indirectly provide you with smart devices and/or the network and systems you use to access and use our websites and services.

In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including but not limited to any bankruptcy or similar proceedings), we may disclose your personal data to an affiliated company or other third party. In such cases, you will receive a notification via email and/or our website regarding the change of ownership, incompatible new uses of your personal information, and clear information about your options regarding personal information.

In cases where we deem it necessary or appropriate: (a) comply with applicable laws and regulations; (b) comply with legal process; (c) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) enforce our terms and conditions; (e) protect our operations, business, and systems; (f) protect our and/or your rights, privacy, safety, or property; and (g) seek available remedies or limit our damages.

Disclose your personal data to subsidiaries or affiliated companies within the group for regular business activities.

We will only disclose your personal data to other third parties with your consent, except for the aforementioned third parties.

International transfer of collected information

For the convenience of our operations, we may transfer, store, and process your personal information and device basic information outside the jurisdiction of your residence. These countries may have different information protection laws. In such cases, we ensure that your information is fully protected through the following means:

Agreement reached under the "EU Standard Contractual Clauses" approved under Article 46 of the GDPR.

If you wish to learn more about our security measures, you can contact us directly through this policy.

Rights related to personal data

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

You do not need to pay any fees, and we will respond within 30 days. If you plan to send us an email, please clearly state in your request which information you wish to change, whether you want your personal information removed from our database, or what restrictions you would like us to impose when using your personal information. Please note that for security reasons, we may require you to verify your identity before further processing your request.

You can:

Request access to personal data related to you that we process;

Request us to correct inaccurate or incomplete personal information related to you;

Request to delete your personal data;

Request to temporarily or permanently restrict our processing of some or all of your personal data;

We require your consent or a contract with you to process your data, as well as to transfer personal information to you or a third party when we process your data automatically; and When we use your data based on your consent or our legitimate interests, choose to object or refuse our use of your personal data.

About account deactivation

You can log out of your account by following these steps: "My - Personal Information - Account & Security - Log Out Account" Information security measures

We adopt commercially reasonable physical, managerial, and technical safeguards to maintain the integrity and security of your personal information. BabCam provides a variety of security strategies to effectively ensure the safety of user and device data. In terms of device access, we employ proprietary BabyCam algorithms to ensure data isolation, access authentication, and authorization requests. In terms of data communication, we support the use of secure algorithms and transmission encryption protocols, as well as business-level encrypted information transmission based on dynamic keys for communication. In terms of data processing, we use strict data filtering and verification, as well as a complete data audit process. In terms of data storage, all of your confidential information will be encrypted for secure storage. If for any reason you believe that your interaction with us is no longer secure (for example, you believe that the security of your BabyCam account has been compromised), please send an email to services@anhongcam.com to inform us immediately.

Information retention period

We will process your personal data for the shortest period necessary to achieve the purposes set out in this privacy statement (7 working days), unless a longer retention period is required by specific legal requirements. We will determine the appropriate retention period based on the quantity, nature, and sensitivity of the personal data, and upon the expiration of this period, we will destroy your personal data. If we are technically unable to perform the above actions, we will take appropriate measures to prevent any further use of your personal data. Dispute resolution

If you have unresolved privacy or data use concerns and we have not provided a satisfactory solution, please contact our supervisory authority in the EU at https://edpb.europa.eu/about-edpb/board/members_en.

Third-party SDK

This "APP" integrates the following SDKs: "com.huawei.hms (Huawei; Huawei Push), com.huawei.agconnect (Huawei; Huawei Coordinated Operations), com.tencent.bugly (Bugly; Tencent Bugly), com.alipay (Alipay Payment), MiPush_SDK_Client_4_8_2 (Xiaomi Push), com.vivo.push (Vivo Push), com.heytap.msp.push (OPPO Push), com.xiaomi.mipush.sdk (Xiaomi Push), com.amap.api (AutoNavi Map SDK), com.baidu.location (Baidu Maps; Baidu Location; Baidu LBS; BaiduLBS), com.aliyun (Alibaba Cloud | Alibaba Push | mPaaS)."

com.mobile.auth (Alibaba Cloud One-Click Login SDK for phone number) com.cmic.sso (China Mobile)For specific uses of third-party SDKs, please refer to the corresponding privacy service agreements.

com.huawei.hms (Huawei; Huawei Push) com.huawei.agconnect (Huawei; Huawei Coordinated Operation Application) Privacy Service Agreement:https://developer.huawei.com/consumer/cn/doc/distribution/app/20213

com.tencent.bugly (Bugly; Tencent Bugly) Privacy Protection Statement:

https://static.bugly.qq.com/bugly-sdk-privacy-statement.pdf

Regarding changes to the policy statement

We may update this privacy statement based on changes to the information practices. If we make any significant changes, we will notify you by email (sent to the email address specified in your account) or by posting a notice on the mobile application before the changes take effect. We suggest that you regularly visit this page to obtain the latest information on privacy practices.

If you have not agreed to our privacy services, it will result in the inability to log into the APP, as during the login process we will collect your login logs, account information, and other related data.

Applicability of law and jurisdiction

The policy is formulated in accordance with the laws of the People's Republic of China and is subject to the jurisdiction of the laws of the People's Republic of China.

If you have any questions about our practices or this privacy statement, please contact us in the following ways:

Company Name: Dongguan Anhong Electronic Technology Co., Ltd.

Mailing address: Room 9001, Building 8, Jindi Smart Port, Tangxia Town, Dongguan City, Guangdong Province, China.

Email: services@anhongcam.com