Wisualarm
Privacy Policy
Last modified:
2022-10-18
Introduction
This Wisualarm
Privacy Policy describes the types of information, including but not limited to
personal data, we may collect from you or that you may provide when you
interact with us, use our application, and/or products or services in relation
to Wisualarm mobile client or when you visit our website
https://www.wisualarm.com/ (“website”), including any subdomains and any
content, functionality and services offered on, by or through it or them, or
any other websites, e-mails, applications that link to this Privacy Policy
(collectively referred to as “Services”), all of them provided by Zhejiang Huaxiao Technology Co., Ltd
(“Huaxiao”, “Wisualarm”, “we”, “us”, or “our”), acting as a data controller.
This Privacy Policy also describes how we collect, use, maintain, share,
protect, disclose or otherwise process that information. Please read this
policy carefully to understand our policies and practices regarding your
information and how we will treat it.
“Personal Data” as
in this Wisualarm Privacy Policy shall mean any information that identifies you
or can, identify you directly or indirectly, in particular if in combination
with another identifier of you.
This Privacy
Policy includes the following contents:
1. Information We Collect About You, Purposes of Processing
and Legal Grounds
2. Children under the Age of 16
3. How we store your personal data
4.Information Sharing
5.Data Security Measures
6. Third Party Suppliers and Their Services
7.Your Rights
8. Changes to Our Privacy Policy
9.Contact Information
1.
Information
We Collect About You, Purposes of Processing and Legal Grounds
We collect several
types of information from and about users of our Services, including
information that you directly provide to us and it identifies you personally, such as, without limitation, name, postal
address, e-mail address and telephone number.
We may also
automatically collect certain information as you navigate through the website
or use our Services, such as usage
details, equipment profiles and IP addresses, by means of cookies, web beacons
and other tracking technologies.
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.
|
Activity |
Type
of data |
Processing
purposes |
|
|
A. Use of Wisualarm
App, Devices |
|||
|
1.1
When you sign up with Wisualarm App for the first time |
Email
address; telephone number (only of customers who sign up with Wisualarm App
via their telephone number); 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 can be uploaded on a voluntary basis if you desire to
have a more personalized account, omission to do so, does not affect the
running of Wisualarm App |
Performance
of contract for Wisualarm Registration Agreement and legitimate interests to
maintain our contractual relationship with you, we only provide services to
users within the European Economic Area (the "EEA"), 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. We process this
personal data in accordance with the applicable EU and Member State
regulations on data protection in particular, the General Data Protection
Regulation No.2016/679 (the “GDPR”). |
|
1.2
When you change the details you used for registration |
If
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 Wisualarm App’s other functions |
|
|
2.
When you log in and use our services |
To
offer our services to you, maintain our services’ normal operations, optimize
our services and secure the safety of your account |
||
|
3.
When you add device (on the Device interface, you can view and add devices
like Gate, Alarm devices, IP cameras, storage devices, and doorbells, to
Wisualarm App) |
Device
SN; Device model; wifi info; Device Name; Device password (encrypted); device
time zone and DST status on/off |
To
process your request to add a device to your account and allow configuration
of your device. Refusing to provide such information may only result in your
being unable to use this function, but does not affect your normal use of
Wisualarm’s other functions. |
|
|
4.
When you use Live View function which provides you a real-time video display |
Device
SN; Device IP; Device Port Information; Video Stream |
To
provide you with the basic services of video display through Wisualarm App |
|
|
5.
When you use Playback and Video Recording functions |
Device
SN, Device’s Channel ID, Record Files Path |
To
store your history record and allow you view it |
|
|
6.
When you activate and configure the settings of the added device such as IP
camera, doorbell and storage device |
Mac
address; IP address; Device SN; Device model; Device firmware version;
Country information (via IP address); Device location (via IP); Date of
device register; Device channel information; Device offline/online status;
Device configuration information |
To
allow activation of your Wisualarm device and its registration with our
server |
|
|
7.
When you set device name and cover image |
Cover
image; Device name; Channel information; Device model; Device SN |
You
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
device added on your Wisualarm 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 Wisualarm App’s other functions. |
|
|
8.
When you enter device password or use the reset function |
Device
SN; password (encrypted) |
To
allow you enhance the security of your device 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
Wisualarm’s other functions. |
|
|
9.
When you use Device Share function |
Device
SN; Email and (or) telephone number of the other user you share your device
with |
To
allow you the sharing of your device with another user of Wisualarm 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 Wisualarm’s other functions. |
|
|
10.
When you use Delete Device function |
Device
SN; Email and (or) telephone number (only of customers who sign up with
Wisualarm App via their telephone number). |
To
allow the removal of the device from your account on Wisualarm 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 Wisualarm’s other functions. |
|
|
11.
When you receive notification |
Device
SN; Push notice ID/alarm snapshot |
To
send you alarm notifications and provide you the services you have requested
us for |
|
|
12.
When you use Wisualarm App’s cloud services to extend your storage capability |
Device
SN; messages and video record; Device channel information |
To
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
Wisualarm’s other functions. |
|
|
13.
When you buy cloud storage plan or redeem gift card |
Details
of the purchased cloud storage plan; payment method; order date; email |
To
process your order and invoice you for the purposes of cloud storage plan |
|
|
14.
When you transfer your cloud storage plan |
Device
name the plan is transferred from; device name the plan is transferred to;
plan information |
To
transfer the activated cloud service to a specific device added to your
account. 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 Wisualarm’s other functions. |
|
|
15.
When you de-register from Wisualarm App and cease to use Wisualarm device and
our service |
Your
telephone number (only of customers who sign up with Wisualarm 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 Wisualarm App. |
Consent |
|
16.
When you use Device AI function |
Device
SN, and personal data captured by the camera, i.e. car license number |
To
allow you to receive alarm when detecting particular targets, i.e. human
shape, motor vehicles, and pets, and intelligent summary push |
Consent |
|
17.
When you use User Experience Plan function |
Browsing
history & clicking behavior |
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 Wisualarm
App’s other functions. |
Consent |
|
18.
When you communicate with us through email or Feedback function |
Content
of your communication with us |
To
communicate with you, provide you with information you request about us,
answer your questions or handle your complaints |
Our
legitimate interests to communicate with you and reply your inquiries/comments |
|
19.
When you de-register from Wisualarm App and cease to use Wisualarm device and
our service |
Your
telephone number (only of customers who sign up with Wisualarm App via their telephone number), and
(or) Email address. |
To
allow us to complete your deregistration, and to delete all your personal
data collected by us during the period of your use of Wisualarm App. |
Consent |
|
20.
device log |
Your
user name, telephone number, Email address, Device SN, and permission that
provide access to the storage on the Device |
To
allow us to improve our Wisualarm App and device service and provide you with
better user experience |
Consent |
|
21.
Device Label Figure and name |
Your
user name, telephone number, Email address, Device SN, and permission that
provide access to the storage on the Device |
To
allow you to save QR code with Device detail at your terminal |
Consent |
|
B. Other uses of your
information |
|||
|
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
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 information |
Performance
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 |
||
2.
Children
under the Age of 16
Our websites are
not generally targeted at children under 16 years of age. No one under age 16
should provide any personal data to or on our Services. We do not knowingly
collect personal data from children under 16.
Huaxiao strongly recommends
that parents take an active role in supervising the online activities of their
children. If you believe we might have any information from or about a child
under 16, please contact us at cloud.huaxiao@wisualarm.com
.
3.
How
we store your personal data
Your personal data
will be retained in the European Economic Area (“EEA”) for as long as required
for the purposes described in this Privacy Policy or in so far 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. In the event where we cease
our products or part or all of our services, we will notify you and delete your
personal data in concern or anonymize such information within a reasonable
period of time.
4.
Information
Sharing
We might disclose
your personal data with certain trusted third parties for the following
reasons:
To our
subsidiaries and affiliates to provide you the services you have requested us
for and for the purposes of our legitimate interests of customer relation
management
To
forwarders/carriers and other business partners to the extent that we need to
deliver your orders
To IT services
providers who offer support during our daily operations, such as the
maintenance of digital databases
To third party
hotline service provided for receiving and following up on your request for
after-sales
To marketing
services providers in order to provide you the services you have requested us
for, such as receiving the news you have opted-in
To a buyer or
potential possible buyer of our business for evaluation and completion of
transactional corporate matter.
All such third
parties will be required to adequately safeguard your personal data, subject to
agreements that correspond to the requirements of applicable laws.
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 or for investigations (e.g. disclosure to prevent crime or
fraud, or to comply with a court order or legislation).
To enforce or
apply our Terms of Use and other agreements, including for billing and
collection purposes.
If we believe
disclosure is necessary or appropriate to protect the legitimate rights,
property or our safety, our customers or others.
As regards the
personal data collected during your use of the Wisualarm App and Cloud, we use
the services of cloud service providers, Alibaba Cloud Computing Co., Ltd.
5.
Data
Security Measures
We have
implemented appropriate technical and organizational measures designed to
secure your personal data from accidental loss and from unauthorized access,
use, alteration and disclosure. All information you provide to us is stored on
our secure servers behind firewalls. Any payment transactions will be encrypted
using SSL technology. In the case of information leakage or other incidents involving
information security, we will initiate contingency plans to prevent the wide
spread of security incidents and inform you in the form of push notifications
and announcements.
6.
Third
Party Suppliers and Their Services
To ensure you have
a smooth browsing experience, you may receive content or network links from
third party suppliers (hereinafter referred to as the third party) beside us
and our partners. Except as otherwise expressly stated in this Wisualarm
Privacy Policy, this Wisualarm Privacy Policy does not apply to situations
where a third party independently provides services to you through our
services, such as websites that may include the services we offer or other
third parties’ sites that have a link to our services. Please note that if you use
such third parties’ products and/or services (including but not limited to
PayPal or other credit card payment services) and provide your personal
information, your information will be handled in compliance with that third
party's privacy statement or similar policies. We cannot control the privacy
and data protection policies of the third parties, and the third parties are
not bound by this policy. Before submitting personal information to third
parties, please see the privacy policy of these third parties. You can choose
whether to access links, contents, and services provided by third parties. We
take no responsibility when your information was misused or improperly
disclosed in such occasions.
7.
Your
Rights
You can review and
change your personal data by logging into your account on our website and
visiting your account profile page.
You may also send us an e-mail at cloud.huaxiao@wisualarm.com
to request access to, or require us to correct or delete any personal data that
you have provided to us. You may also object to or request us to restrict your
processing. 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. If you want to access your head
portrait, user name, email address and other basic information, or video,
image, order, device and other service information on your Wisualarm account,
you can enter Wisualarm and tap on corresponding function button to access
relevant information.
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, though we may need to verify the accuracy of
the new data you provide to us. If you want to change your nickname, email
address, etc. on your Wisualarm account, enter Wisualarm, tap on related
function button.
Request erasure of your personal data.
This enables you to ask us to delete or remove personal data where 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. If you want to
delete the basic information such as email address, and password, or service
information such as video, image and alarm on your Wisualarm account, you can
delete your information by tapping on related data clear function button.
Request restriction of processing
of 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. If you want to disable user
experience program and alarm information on your Wisualarm account, you can
enter Wisualarm and tap on corresponding close button to turn it off
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.
8.
Changes
to Our Privacy Policy
We keep this
Privacy Policy under review and modify this Privacy Policy from time to time.
We will inform you for any modifications on the Privacy Policy. We will also
provide a notice of the modifications on the homepage for a short period. The
date the Privacy Policy was last revised is identified at the top of the page.
9.
Contact
Information
To ask questions
or comment about this Privacy Policy and our privacy practices, please contact
our Data Protection Officer via phone at 400-672-8166, through email at cloud.huaxiao@wisualarm.com
, or by mail at:
Zhejiang Huaxiao
Technology Co., Ltd
E19, BingXin Road
1399, Binjiang District,
Hangzhou, Zhejiang
Province, P.R. China
310053
C/O: Data
Protection Officer