The Policy will help you understand the following content:
1. How do we collect and use your personal data
3. How do we protect your personal information
4. How do we share, transfer, and publicly disclose your personal data
5. Your rights
6. How do we deal with the personal information of minors
7. Revision and update of this policy
8. How to contact us
We understand the importance of personal information to you and will do our best to protect your personal data. We are committed to maintaining your trust in us and to abide by the following principles to protect your personal data: the principle of integration of rights and responsibilities, the principle of clearly defined objectives, the principle of choice and consent, the principle of minimum sufficient use, the principle of security, the principle of subject participation, the principle of openness and transparency etc. At the same time, we promise that we will take appropriate security protection measures to protect your personal data in accordance with the industry’s mature security standards.
Ⅰ. How Do We Collect and Use Your Personal Data
Personal data refers to various information recorded electronically or otherwise that can identify a specific natural person or reflect the activity of a particular natural person, either alone or in combination with other information.
ZOSI will only collect and use your personal data for the purposes listed below in the Policy.
1. When you register for an account, the information provided to us may include, but is not limited to, your phone number, email address, username and password.
2. If you purchase our products or services under our brand, your order data will also be collected.
3. When you use the ZOSI service, you need to bind your camera and other products. We collect the product serial number and product verification code that you bind, which is the basic information that must be collected to bind the product and further provide you with basic services such as previewing, video storing and value-added services.
4. When you turn on the message alert feature, we will collect a screenshot of the video taken by your camera to deliver the screenshot to you. You can turn it off with account settings.
5. You are fully aware that in the following situations, we do not need your authorization to collect and use your personal data:
(1) directly related to national security and national defense security;
(2) directly related to public safety, public health, and major public interests;
(3) directly related to criminal investigation, prosecution, trial and judgment execution;
(4) when it’s difficult to obtain the consent of the person for the protection of the personal rights and interests of the subject or other individuals, such as major legal rights of life and property;
(5) the personal data collected is disclosed to the public by the subject;
(6) your personal data collected from legally publicly disclosed information, such as from legal news reports, government information disclosure, etc.;
(7) It is requisite to sign a contract according to your requirements;
(8) It is necessary to maintain the safe and stable operation of the products and/or services provided, such as the detection and disposal of products and/or services;
(9) required for legitimate news reporting;
(10) when the academic research institution conducts statistical or academic research based on the public interest as well as provides academic research or describes research results to the public, the personal information contained in the research results will be de-identified;
(11) other circumstances as stipulated by laws and regulations.
2. Similar Technology as Cookies
In addition to cookies, we also use other similar technologies such as web siphons and pixel tags on our website. For example, the email we send to you may contain a URL that links to the content of our website. If you click on the link, we will track this click to help us understand your product or service preferences to improve customer service. A web siphon is usually a transparent image that is embedded in a website or email. With the pixel tags in the email, we can tell if the email is open. If you don’t want your event to be tracked in this way, you can unsubscribe from our mailing list at any time.
Ⅱ. How Do We Protect Your Personal Data
1. We will use all reasonable and practicable measures to protect your personal data, which is protected by a dedicated data security department.
2. Providing browsing services through https and other ways to ensure the security of user data during transmission.
3. Encryption protection of user personal data by adopting encryption technology and conducting data isolation by isolation technology.
4. Establish a personal data protection department as well as a strict data usage and access system. We only allow authorized personnel to access personal information and require them to fulfill their confidentiality obligations.
5. We will conduct security and privacy protection training courses to enhance employees’ awareness of the importance of personal data protection.
6. Although we have taken reasonable and effective measures, the network environment is not 100% safe. It is essential for you to take active measures to protect the security of your personal data, such as setting up complex passwords, periodically changing your account passwords, and not arbitrarily leaking passwords to others.
7. If the unfortunate incident of personal information security happens, you will be promptly informed according to the requirements of the law. And we will issue announcements in a reasonable and effective manner.
Ⅲ. How Do We Share, Transfer, and Publicly Disclose Your Personal Data?
We do not share your information with any company, organization or individual other than ZOSI, except for the circumstances as follows:
(1) in the case of obtaining your express authorization or consent;
(2) The mandatory requests of the competent authorities of government to share your personal data;
(3) According to the relative service agreement and regulation and so forth between you and ZOSI;
(4) When ZOSI is deemed to protect the legitimate rights and interests of its own and commence the action or resort to arbitration with the user;
We may share your data of order, account and device with third parties such as our partners to assure that the provided services is successfully carried out for you. However, we will only share your personal data for legitimate, valid, vital, specific, and unequivocal purposes, and will only share the personal data that is requisite for the service. Our partners do not have the right to use the shared personal data for any other purpose.
We will not transfer your personal data to any company, organization or individual except for the circumstances as follows:
(1) Transfer will be conducted under your explicit consent: We will ask for your affirmative consent before transferring your personal data to other parties;
3. Public Disclosure
We will only publicly disclose your personal data in the following circumstances:
(1) after obtaining your explicit consent;
(2) disclosure based on law: We may publicly disclose your personal data at the request of law, legal procedure, litigation or mandatory requirements of the competent government authorities.
Ⅳ. Your Rights
In compliance with China’s relevant laws, regulations, standards and universal practice of other countries and regions, we guarantee you to exercise the following rights about your personal data:
1. Access to or correct your personal data
You have the right to access to your personal data in line with the laws and regulations. You can access to or edit your personal data through the personal information and changing password page etc. on our website or in the app. However, for the sake of security and identification or as required by laws and regulations, you may not be able to modify the initial registration information provided.
2. Delete your personal data
In the following situations, you can ask us to delete your personal data:
(1) we deal with your personal data in violation of laws and regulations;
(2) we collect and use your personal data without your consent;
(3) we deal with your personal data against our agreement;
(4) you cancel your account;
(5) our service and operation is terminated.
If we decide to respond to your removal request, we will also notify the entity from which we obtained your personal information and request that it be removed promptly, unless otherwise required by laws and regulations, or if these entities have obtained your exclusive authorization.
When you delete data from our services, we may not immediately delete the corresponding data in the backup system, but will delete it when the backup is updated.
3. Change the scope of your authorization
You can reset your authorization for your personal data by visiting the authorization page of the ZOSI platform. When you withdraw your consent or authorization, we will stop providing you with the corresponding service to the withdrawal of consent or authorization and will neither process your corresponding personal data. However, your withdrawal of consent or authorization will not affect the processing of personal data previously based on your authorization.
4. Cancel the account
You can cancel your previously registered account at any time. After canceling the account, we will stop providing products or services, and delete your personal data according to your request, unless otherwise required by laws and regulations.
5. Respond to your above request
If you are unable to access, correct or delete your personal data, you can contact us through the contact information listed below this policy. On the account of safety, a written request may be required or other ways to prove your identity and then your request will be processed.
In principle, we do not charge you for a reasonable request, however, for the repeated requests that beyond reasonable level a certain amount of fee will be charged depending on the case. Furthermore, we may reject the requests that are irrationally repetitive, too much technical measures involved (e.g. new systems need to be developed or a thorough transformation from existing practices), pose risks to the legal rights of others, or are extremely impractical (e.g. concerning data stored on backup tapes).
In the following situations, we will not be able to respond to your request as required by law or regulation:
(1) related to national security and national defense security;
(2) related to public security, public health, and major public interests;
(3) related to criminal investigation, prosecution, trial and execution of judgments;
(4) with evidence sufficient to prove that you have subjective malice or abuse of rights;
(5) responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations;
(6) involving trade secrets.
Ⅴ. How Do We Deal with Underage Personal Data?
1. We attach great importance to the protection of information for minors. If you are a minor under the age of 18, you shall obtain prior written consent from your parents or legal guardian before using our services. We protect the data of minors in accordance with the relevant laws and regulations of the country.
2. For the collection of personal data of a minor based on the consent of the parent or legal guardian, only if it is permitted by law and expressly agreed by parents or legal guardian will the personal data of minors be used or publicly disclosed.
3. If we find that we have collected personal data about a minor without the prior consent of a verifiable parent or legal guardian, we will try to delete the data as soon as possible.
Ⅵ. Revision and Update of the Policy
1.We may modify the Policy in due course. Any modification to the Policy will be posted on this page. For major changes, we will notify you by push notification, pop-up, email, etc.
2. Significant changes in the Policy include but are not limited to:
(1) significant changes have taken place in our service mode. Such as the purpose of processing personal data, the type of personal data processed, the way in which personal data is used, etc.;
(2) we have undergone major changes in the ownership structure and organizational structure. e.g. changes in the owner caused by business adjustments, bankruptcy, mergers and acquisitions, etc.;
(3) the main object of personal information sharing, transfer or public disclosure have changed;
(4) crucial changes in your rights to participate in the processing of personal data and how it is exercised;
(5) It’s indicated that there is a high risk in your personal data safety impact evaluation report.
3. If you continue to use the ZOSI service after this policy update takes effect, it means the updated policy is fully read, understood and accepted and you are willing to accept the updated policy restrictions; if you do not accept this policy, please stop using our service immediately.
Ⅶ. How to Contact Us
If you have any questions, comments or advice about this policy, please contact us by phone at [400-660-8825] or by email [firstname.lastname@example.org].
If you are not satisfied with our response, especially if the ways we handle personal data impair your legal rights, you can also file complaints or report to the supervisory authorities e.g. Cyberspace Administration, Telecommunications Office, Public Security Bureau and Industry and Commercial Bureau.