Data Protection and Privacy Notice

Last Updated on September 22, 2021

Scope of this Notice

ThisData Protection and Privacy Notice ("Notice") covers information thatShenzhen ZuoMiTechnology Co., Ltd., and its subsidiaries and affiliates (collectively"ZuoMi", "we", "us", "our") collect,use, share, and store, including personal information (i.e. information thatcan be used to personally identify you by itself or when combined with otherinformation).

ThisNotice covers information collected and processed by ZuoMi when you use ourProducts and Services, including our smart home devices, cloud service, MobileApp, Sites, and Subscription Services, as defined in our Terms of Services(collectively "Services"). It describes how we collect, use, shareand secure the personal information you provide. It also describes your choicesregarding use, access and correction of your personal information.

Your Permission

Byusing ZuoMi products, including ZuoMi's web and Mobile Apps and cloud services,you give ZuoMi permission to collect, process, and store data as described inthis Data Protection and Privacy Notice. Your information, including personaldata, may be transferred to the United States and processed and stored there.Your information, including personal data, may also be transferred andprocessed in other countries where ZuoMi operates. These countries may not haveprivacy laws similar to or as comprehensive as the laws where you reside and/orare a citizen. By using ZuoMi’s Services, or by accessing its Site, youexplicitly consent to this transferring, processing, and storage of yourinformation, including personal data.

Aspart of delivering our service to you, your information, including personaldata, may be transferred and shared with third parties, including ouraffiliates. By using ZuoMi products, you give ZuoMi permission to share yourdata with these third parties.

Information that ZuoMi Collects

Whendoes ZuoMi collect and process information?
ZuoMi collects information when you use our Services and when you access ourSite. We also collect information when you provide it to us.


Whatinformation does ZuoMi collect and/or process from customers who use its Sites?
Theinformation we collect may include:

  • contact details, such as your name, title, company/organization name, email address, telephone and fax numbers, physical address, etc.;   
  • information about your company, and job function;   
  • your email marketing preferences;   
  • payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by our third-party payment processor on our behalf; we store only the last four digits of your payment card and the expiration date;   
  • financial information (including credit card or account information);   
  • information such as your nationality and country of residence that allows us to determine your eligibility under export control regulations to receive information about certain technologies;   
  • information used to customize and facilitate your use of our Sites, including login and technical information;   
  • inquiries about and orders for our products and services;   
  • information that assists us in identifying the products and services that best suit your requirements;   
  • information that assists us in improving our products and services;   
  • event registration information;   
  • feedback from you about our Sites and our products and services generally; and   
  • any information as collected pursuant to the description under "information collected automatically" below;   
  • Any personal information that you provide while applying for a job with ZuoMi.   


Whatpersonal information does ZuoMi collect and/or process from customers who useits products and services?
We may collect the following information, including personal information whileyou are using ZuoMi Products and Services:

  • Setup information and account information you provide, such as your date of birth, gender, email address and Wi-Fi network information;   
  • Data from the sensors built into the device, such as motion sensors, temperature sensors, light sensors, humidity sensors;   
  • Technical, usage and performance information from the device;   
  • Shared content;   
  • Information that assists us in identifying the products and services that best suit your requirements;   
  • Information that assists us in improving our products and services;   
  • Location data;   
  • Still images, video images, and audio recordings. Our security cameras and smart doorbell products capture still images, video images, and audio recordings. We collect, process, and store this information in order to provide our services to you. We may capture and email portions or videos to you as part of the notification system. We may also capture portions of videos to analyze for motion. The length that we store this information depends on your cloud subscription plan;   
  • Information that you post for publication on our Site or through our services;   
  • Information that you voluntarily share or post.   


Whatinformation does ZuoMi collect from its Mobile Apps?
When you download and use our Services, we automatically collect information onthe type of device you use, operating system version and system and performanceinformation.

Wesend you push notifications from time-to-time in order to update you about anyevents or promotions that we may be running. If you no longer wish to receivethese types of communications, you may turn them off at the device level. Toensure you receive proper notifications, we will need to collect certain informationabout your device such as operating system and user identification information.

Wemay collect your location-based information for the purpose of allowing you toshare your location while using the Moments function and to provide you withupdated weather. We will only share this information with our mapping providerfor the sole purpose of providing you this service. You may opt-out oflocation-based services at any time by editing the setting at the device level

Wemay use mobile analytics software to allow us to better understand thefunctionality of our Mobile Software on your phone. This software may recordinformation such as how often you use the application, the events that occurwithin the application, aggregated usage, performance data, and where theapplication was downloaded from. We do not link the information we store withinthe analytics software to any personally identifiable information you submitwithin the mobile application.

Use of Data

Howdoes ZuoMi use the information it collects?
ZuoMi uses your information in several ways:

  • To provide services to you;   
  • To develop and improve ZuoMi’s products and services;   
  • To ship products to you;   
  • To contact you regarding products or services or to direct offers and promotions to you;   
  • To establish and maintain customer accounts;   
  • To maintain billing records;   
  • To administer our Services and Site (including any searches or requests for information about our Services);   
  • To identify motion and other events in the information collected our Products;   
  • To manage risks, obtain or maintain insurance coverage, or to seek professional advice;   
  • To direct our targeting of Facebook Ads and Google Ads. For more information on Facebook Ads and your options, please see https://www.facebook.com/about/ads. For more information on Google Ads and your options, please see https://policies.google.com/technologies/ads.   
  • ZuoMi may also use de-identified data to assist us in making sales, marketing, and business decisions.   


Wheredoes ZuoMi store the information that it collects?
Your personal information may be collected, processed and stored by ZuoMi andits affiliates in the United States and other countries. ZuoMi's servers areall located in the United States, but your data may be transferred to othercountries. The privacy protections and legal requirements in some of thesecountries may not be the same as those in your country. If you are a customerlocated in countries other than the United States, including the European Unionor European Economic Area, by using ZuoMi products, applications, and/orservices you agree to the transfer of your personal data to the United Statesand other countries where ZuoMi and its affiliates operate.


CanI access the data that ZuoMi collects?
You have the right to access some information on your account page in order toview and where applicable, update your information (Please note that we maykeep a copy of the prior version for our records). You may have further rightsdepending on your location.


Arechildren allowed to use ZuoMi Products?
ZuoMi products are marketed to and intended to be used by adults. Childrenunder the age of 18 require consent from a parent or guardian to use ZuoMiproducts. Children under the age of 18 may only use ZuoMi's Services with thepermission and involvement of a parent or guardian. We do not knowingly collectinformation from children under the age of 18 without the express consent ofthe child's parent or guardian.


CanI limit the data that ZuoMi collects?
You have several options to limit the data that ZuoMi collects.

  • The use of ZuoMi products and services is voluntary and you always have the right not to provide any information by declining to purchase and/or use ZuoMi products and services.   
  • You can adjust your customer communication preferences to control what type of communications you receive from us.   
  • Most browsers will provide instructions on controlling which cookies can be used. If you choose to block or otherwise limit our cookies, it may affect the quality of services provided.   

Transmission and Sharing of Data

DoesZuoMi share the data it collects with any third parties?

Disclosuresto Third Parties
ZuoMi may also disclose your data to third parties, including affiliates andservice providers, as a part of delivering service to you. These third partiesare restricted from sharing your information without our permission.

Oneof the third-party services that we use is Google Analytics. You can find moreinformation on how Google uses data at https://policies.google.com/technologies/partner-sites.You may find more information about controlling the data the Google collects,including opt-out options at https://adssettings.google.com/.

Wemay also share data with third parties in the following situations:

  • Where disclosure is required by laws, regulations, legal processes, or government requests;   
  • If disclosure is necessary to protect the rights, property, or safety of ourselves, our users, or the public;   
  • To defend ourselves in a legal action;   
  • As part of a business transaction (If a transfer or sale of the company and/or all or part of its assets, your personal information may be sold or transferred. ZuoMi will take reasonable steps to request that the purchaser treat the data as stated in the ZuoMi Privacy Notice active at that time);   
  • To enforce our Terms of Sale or other policies;   
  • Whenever you consent to the sharing.   


DoesZuoMi transmit the data it collects to other countries?
As part of delivering service to you, ZuoMi and its affiliates may transferyour data between countries. The privacy protections and legal requirements insome of these countries may not be the same as those in your country. If youare a customer located in countries other than the United States, including theEuropean Union or European Economic Area, by using ZuoMi products,applications, and/or services you agree to the transfer of your personal datato the United States and other countries where ZuoMi and its affiliatesoperate.

Security

Howdoes ZuoMi protect my personal data?
Weare committed to ensuring that your Personal Data is kept and stored securely,and we maintain reasonable physical, technical and organizational measures andprocedures to safeguard and secure the information we collect through ourproducts, services and our Sites.

Thishas been done with a view to preventing unauthorized or unlawful processing ofyour Personal Data and accidental, unauthorized or unlawful access, use,processing, copying, alteration, transfer, loss or destruction of, or damage toyour Personal Data.

Weprotect the security of your Personal Data by:

  • using encryption where appropriate;   
  • using password protection where appropriate; and   
  • limiting access to your Personal Data (for example, only our staff or employees who need access to it for the purposes described in this Privacy Notice will have access to it);   

However,these measures do not release you from the responsibility of taking appropriatesteps to keep your Personal Data safe and secure, in particular by avoidingobvious user ID's or passwords, by changing your password regularly, and byensuring that you do not disclose your password(s) or grant any other personaccess to your user account and your Personal Data. We also cannot guaranteethat your Personal Data is secure when submitted or otherwise communicatedthrough insecure means.

Weendeavor to protect the privacy of your account and other Personal Informationwe hold in our records, but we cannot guarantee complete security. Unauthorizedentry or use, hardware or software failure, and other factors, may compromisethe security of user information at any time.

Wealso take reasonable efforts to obtain the agreement of our affiliates andthird-party service providers to take steps to protect the confidentiality,security, and integrity of personal data we share with them.

Cookie Notice

DoesZuoMi collect information on Site users automatically?
Yes. ZuoMi and our third-party partners may collect and analyze data collectedthrough automatic means, including cookies and other techniques, includingtracking pixels, when you use our Sites. Cookies save you time and allow us tounderstand how our Sites is used so that we can improve the sites and enhanceyour experience. Information on your browsing behavior, including browser type,domains, IP address, referring/exit pages, how you navigate and use our site,the timing, frequency and pattern of your service use, and how you interactwith links may be collected. ZuoMi also gathers demographic information aboutour user base as a whole. We also use persistent cookies which remain in yourbrowser and allow us to recognize you when you return to our Site, whichprovides convenience to you and helps us improve our Sites.

ZuoMialso collects information about your visit to our sites, including what pagesyou view, the number of bytes transferred, the links you click, the materialsyou access, and other actions taken within ZuoMi's sites. On sites that youenter with a user ID, we may connect this information with your identity todetermine your potential interests in our products and services. We alsocollect certain standard information that your browser sends to every websiteyou visit, such as your Internet Protocol (IP) address, your browser type andcapabilities and language, your operating system, the date and time you accessthe site, and the website from which you linked to our site to analyze trendsin the aggregate and administer the site. We do not link this information toyour identity.

Pleasebe aware that most browsers accept cookies automatically.


CanI control what information is collected?
Your browser may contain settings which allow you to control to some extentwhether cookies are accepted. ZuoMi has no control over the settings yourbrowser offers. If you choose to block cookies on ZuoMi's Sites, yourexperience may be affected, and some portions of the Sites may not work foryou.

Pleasenote that ZuoMi does not control the privacy or information collectingpractices of third party links (such as Facebook and Twitter buttons) on oursite. These parties may collect information on you if you click their links.Your interactions with these third parties will be controlled by their privacypolicies and settings.

Tomanage Flash cookies, please click here:
http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

Notice Governs Use: Changes to Privacy Notice

Theterms of this Privacy Notice will govern the use of any information collectedwhile it is in effect. ZuoMi reserves the right to change this Privacy Noticeat any time, without prior notice to you, and any changes will become effectiveimmediately upon posting. Your continued use of ZuoMi products, services, orSites after the posting of any of these changes will constitute acceptance of,and agreement to be bound by, those changes. Please review this Privacy Noticeperiodically for changes.


ReviewingYour Personal Information
Upon request ZuoMi Technology will provide you with information about whetherwe hold any of your personal information.

Insome cases, you can review, correct, request deletion of personal informationprovided through our Sites by going to the page on which you provided theinformation. In all cases, you can make a request to review and correct yourpersonal information collected via our Services by contacting us. We may takesteps to verify your identity before providing you access to your personalinformation. You can help us to maintain the accuracy of your information bynotifying us of any change to your mailing address, phone number, or emailaddress. We will respond to your request within a reasonable timeframe.

Notethat we need to retain certain records for legal or internal business reasonsand that some of your information may remain on backup systems, in compliancewith applicable law. We will retain your personal information for as long asnecessary to provide you with the Sites and applications you are eligible touse with your ZuoMi ID, or as needed to comply with our legal obligations, mayneed to retain your personal information in order to continue providing aservice or enforce our agreements.

Data processing, storage, and transfers wherethe GDPR applies

Thissection only applies to the personal data of those to whom the General DataProtection Regulation applies.


Whois the controller of your personal data?
A data controller is the entity that directs the processing of your data and ischiefly responsible for the data. Generally, ZuoMi will be the controller ofdata collected pursuant to this Notice.


Isyour data transferred to other countries?
Aspart of delivering service to you, ZuoMi and its affiliates may transfer yourdata between countries. The privacy protections and legal requirements in someof these countries may not be the same as those in your country. Thesetransfers occur between ZuoMi entities and our service providers.

YourPermission
By using our Site and/or Services, you are explicitly consenting to thistransfer of your information, including personal data. We may also useappropriate safeguards, namely contractual protections for the transfer ofPersonal Information to third parties, such as the European Commission’sStandard Contractual Clauses, where appropriate.

Pleasenote that any information you publish publicly on our Sites or services may beaccessed globally.


Wheredoes ZuoMi store the data it collects?
ZuoMi uses servers located in the United States of America. By using ZuoMi'sServices, you agree to having your data stored transferred to, processed andstored in the United States of America.


Whydoes ZuoMi collect and process data?
ZuoMi relies on the following legal bases to collect, process, transfer, andstore your personal data:

  • To allow us to enter into or fulfill the terms of a contract with you. We may need to collect and process your personal information in order to enter into or complete a contract that you are a party to, for example, we may need your name and address to deliver products to you after you order them.   
  • To allow us or our partners to fulfill our legitimate business interests, such as:   
    •    Preventing fraud;     
    •    Maintaining the security of our products and services;     
    •    Conducting daily business operations;     
    •    Conducting direct marketing;     
    •    Providing, maintaining, and improving our products and services;     
    •    Managing user account;     
    •    Managing our products and services;     
    •    Performing research that improves our products or services for the users or public;     
    •    Fulfilling obligations to our partners.     
  • To comply with legal obligations. ZuoMi may be required to process and/or disclose your personal data when legally required to do so as in when filing taxes or answering law enforcement subpoenas. ZuoMi may also disclose your information if required in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to comply with legal obligations, or when we believe in good faith that the law requires it. We may also disclose your personal information to verify or enforce our Terms & Conditions or other policies, or to otherwise protect the rights, property, safety, or security of third parties, visitors to our Sites or the public. ZuoMi has strict internal policies regarding when and how your information can be disclosed to legal authorities.   
  • To process your information after obtaining specific consent from you to do so. For example, to contact you with special offers after you grant ZuoMi consent to contact you with marketing material. Whenever consent is used to process your data you be provided with details on how that information will be used before you grant consent. You have the right to withdraw consent for this type of processing at any time. Withdrawal of consent will not affect the lawfulness of processing performed before consent is withdrawn. Information on how to withdraw consent will be provided before your information is processed based on your consent.   


Whatrights do I have?
The following rights are available under the General Data ProtectionRegulation. Please read the relevant laws and guidance from the applicableregulatory authorities for further information on these rights.

  • The right to be informed;   
  • The right of access;   
  • The right of rectification;   
  • The right to erasure;   
  • The right to restrict processing;   
  • The right to data portability;   
  • The right to object;   
  • Rights in relation to automated decision making and profiling.   

Inaddition to the above-mentioned rights, if we rely on consent for theprocessing of your Personal Information, you have the right to withdraw it atany time free of charge. When you do so, this will not affect the lawfulness ofthe processing before your consent withdrawal.

Youalso have the right to lodge a complaint with a competent supervisory authoritysubject to applicable law.

Questions

Ifyou have questions regarding this statement or our handling of your personalinformation, please contact us . We will promptly address your concern andstrive to reach a satisfactory resolution.


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