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                      Privacy Policy

Last Updated: March 22, 2024


Overview

Welcome to use Holink Security App.


MS IDEA TECHNOLOGY CO LIMITED and its affiliates (collectively “HOLINK” “we” “our” or “us”) are committed to protecting the privacy confidentiality and security of your personal information by complying with applicable laws and we are equally committed to ensuring that all our employees and agents uphold these obligations.


This Privacy Policy describes how we collect use and handle your personal information when you use the services provided under HOLINK Websites (including but not limited to holink.us) or Holink Security Apps (hereinafter “HOLINK Services”). It also applies to any personal information we collect from the operation and use of Products while connected to our Holink Security App (the “Products”).


You may need to register an Account via Holink Security App or other Site to access HOLINK Services. For the purposes of seeking to provide you with a better experience to improve HOLINK Services or otherwise where you have consented with such Account without new registration you may access to other services provided by HOLINK over Internet and/or mobile applications. You may also from time to time ask us to migrate or export your personal information contained in one service to another services where such migration option is available. Any applicable privacy policy may apply to specific services provided by HOLINK you are advised to read this Privacy Policy and any specific policy for your interest before using the services.

HOLINK Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by us. This Privacy Policy does not apply to how third parties collect use disclose or retain information. We encourage you to review the privacy policies of these third-party websites or services.


We may modify this Privacy Policy at any time provided certain provisions of this Privacy Policy prove to be incomplete or outdated and further provided that these changes are reasonable for you taking into account your interests. We will post the most current version on the page of HOLINK App-Log in-More-About-Privacy Policy. By using HOLINK Services and Products or other acting permitted by the applicable laws you are deemed to have read acknowledged and accepted all the provisions stated here in this Privacy Policy including any changes we may make from time to time. In order to comply with applicable laws including local information protection legislation we will specifically seek prior express consent to the particular processing (e. g. providing marketing materials to you) of personal information.


1. Definitions

“Personal Information” has the same meaning as “Personal Data” and shall include any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified directly or indirectly in particular by reference to an identification number or to one or more factors specific to his physical physiological mental economic cultural or social identity. Examples of personal information include your name telephone number email address physical address and payment information.


Personal information also includes information that alone cannot directly identify you but with other information we have access to can identify you such as product serial numbers log data that automatically records information about your visit such as your browser type domains page views the URL of the page that referred you the URL of the page you next visit your IP address and page navigation unique device ID collected from Products and your mobile devices data from cookies pixel tags and web beacons the country and time zone of the connected Product geo-location mobile phone carrier identification and device software platform and firmware information.


2. The Type of Personal Information We Collect

In order to provide HOLINK Services to you as a controller we collect and process your Personal Information. We will ask you to provide Personal Information that is necessary to provide those services to you and we process the Personal Information which you voluntarily provide to us. If you do not provide your Personal Information we may not be able to provide you with our Products or HOLINK Services. We may also collect Personal Information from publicly or non-publicly accessible sources for example a third-party account where you use your a third-party account to register an HOLINK App Account.


Here are more details on the types of Personal Information we collect when you use HOLINK Services and Products:


2.1 Account Information

We collect and associate with your account the information you provide to us when you do things such as sign up for your account subscribe for premium services and set up two-factor authentication e.g. your user name your phone number email address payment information and physical address. When you sign up for your account we will also collect your location e.g. which country or district you resident. We use this location to decide the nearest data center to support your use of HOLINK Services.


2.2 Your Product Information

Our HOLINK Services are designed to make it simple for you to manage your Product like previewing your video captured or processed by your IP camera product in real time. To make that possible we need to associate your Product with your Account by collecting your Product information when you install and activate Products such as your Product name the Product’s verification code and serial number which are unique to the Product connected to HOLINK Services and associated with your Account. We also collect the parameter and configuration information of your Product when you configure your Product in your Account.


2.3 Your User Content

Our HOLINK Services enable you to view save and share content through HOLINK Services like video clips live video streams images captions and comments (“User Content”). To make that possible we may record process and transmit the video and/or audio content from the Product as well as the content you uploaded including the images texts sounds when you use the Product and/or the Service’s features. If you share your User Content with others we will further collect the phone number or email address of you and the person you elect to share your User Content with. We may also process data from your Product so that we can send you alerts when something happens. This may include capturing and sending you portions of your data as part of a notification or analyzing the data to identify motion or other events. To clarify: (i) for the streaming video you preview in real time we only transmit it rather than store it; (ii) When you use HOLINK Services to receive pictures or videos as alerts data we will only store this data for seven days to enable this function; and (iii) When you store video clips in your own SD card of your Product you may use our playback function to view the video in which case we only transmit your data rather than store it.


2.4 Customer Service Information

If you contact us with questions or concerns about HOLINK Services or Products we may use your personal information to verify your identity and respond. If you contact us via HOLINK Customer Services we may further require certain personal information. When there are reasonable doubts regarding your identity you might be asked to provide further information e.g. a copy of a document which help us to verify your identity. It can be any document such as a photo of your Product or your purchase invoice. Should you provide any other documents personal details such as your name and your address should be in clear in order to be able to identify you while any other information such as a photo or any personal characteristics may be blacked out. Our use of the information on your identification document is strictly limited: the information will only be used to verify your identity and will not be stored for longer than needed for this purpose.


2.5 Usage Information

When you access HOLINK Services we will collect information related to how you use HOLINK Services and manage your Product such as the types of content that you view or engage with the features you use the actions you take and the time frequency and duration of your activities. We use this information to provide you with a more friendly experience to prevent misuse and to ensure that HOLINK Services are working properly.


2.6 Device Information

We also collect information from and about the devices you use to access HOLINK Services. This includes things like the browser device name type of network and Operator you use and the UUID model system version language and time zone of your device. We may also receive information through device settings that you turn on such as access to your GPS location. If you have questions about the security and privacy settings of your mobile device please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.


2.7 Cookies and other technologies

We also use cookies web beacons pixel tags and other technologies to keep records store your preferences improve our advertising and collect information such as log data and device data.


2.8 For Individual Service Options

We may provide several individual services e.g. Cloud Storage Services. If you choose to use such individual services we may collect and process payment information including your name credit or debit card information billing address and details of your transaction history. When you use individual services we will capture process and retain video and audio data recordings from your Product for the duration of your subscription period of such services.


3. How We Use Your Personal Information

3.1 By Devices or Systems

We process your Personal Information as necessary for the provision of HOLINK Services and the performance of our contract with you. For example we need to process your personal information to enable the following:

  • Provide HOLINK Services such as registering you for a Service identifying and authenticating you setting up your device connecting your device to the network enabling device sharing function personalizing settings operating the device checking on the status of the device and sending usage notifications to you (including push notifications) Loyalty and incentive programs;
  • Provide customer support and communicate with you which includes functions enabling you to provide reviews of our products and feedback;
  • Crash reports are reports sent to our server when you report an error to us and with your consent. We need certain information in order to identify the cause of the issue to assist you. Information required includes device data usage history and logs device settings error reports abnormal activities reports and account information;
  • Operate evaluate and improve our business including developing software updates developing new products and services analyzing our Services aggregating and anonymizing data performing data analytics auditing and other internal functions;
  • Network security specifically for the prevention detection and protection against fraud abuse criminal activities and other abnormal activities;
  • Comply with regulation requirements enforcement and compliance with legal requirements for the execution of claims including relevant industry standards and our policies;
  • For administrative purposes including quality assurance purposes and internal training;
  • Marketing and advertising such as providing product and service recommendations which may include targeted ads. You may turn off targeted or interest-based advertising by communicating that request to us at info@holink.us.

We may combine information we obtain about you for the purposes described above. We may also use the information we obtain for other purposes for which we provide specific notice at the time of collection or otherwise with your consent.


3.2 Your Personal Information Used Across Connected Devices

Our products use information from your connected devices to give you a more personalized experience.


4. Personal Information Processed on Your Behalf as a Processor

Where Personal Information of third party individuals (“Third Party Information”) are collected and processed via the Products and/or the Services selected by you HOLINK will process such Third-Party Information as a processor on your behalf.


In particular we process Third Party Information from Your Content so that we can send you alerts when something you cared happens. Specifically when you use the Product’s recording or streaming features the video and/or audio content from your Product as part of Your Content that we transmit and/or process for you may include Third Party Information; when you use the comparative analysis features provided by us the basic information you upload for comparison may also include Third Party Information. This includes capturing and sending you portions of the Third Party Information as part of a notification or analyzing the Third Party Information to identify motion or other events you selected.


When you share the devices you have added in HOLINK App with other users they may gain access to your personal information such as account/user name/e-mail address/device information. Additionally we may collect and process the personal information of these users such as account/user name/e-mail address. Therefore please inform and obtain consent from others before sharing. When you accept the device sharing invitation from other users we may collect and process your personal information such as account/user name/e-mail address.


5. How We Share Your Personal Information

5.1 We do not sell any personal information to third parties and we never will.

5.2 We may share personal information with third parties on the basis of non-disclosure agreements. The following are the limited situations where we may share personal information:

  • Our Affiliates. We share your personal information with HOLINK affiliates who are required to use that information in accordance with the purposes described in this Privacy Policy for example to provide technical support as per your request.
  • Others working for and with HOLINK. HOLINK use service providers vendors technicians and other third-parties to help us process store and protect some of your Information and otherwise help us administer our Products and HOLINK Services effectively provide a better user experience process your purchases and increase the quality of our Products and HOLINK Services. These third-parties are forbidden from using your personal information for non-HOLINK purposes and are required to protect your information in accordance with this Privacy Policy and applicable laws. For a list of trusted third parties that we use to process your personal information please contact us.
  • New Owner. If HOLINK and/or all or part of our assets are ever sold or transferred your personal information may be among the items sold or transferred. Under such circumstance we will notify you by sending an email to the email address associated with your account or via an in-app or website notification of (i) the identity and contact information of the purchaser or transferee (ii) your right to revoke your consent to the provision of personal information and (iii) the means by which you may revoke such consent.
  • Law and Order; the Public Interest. We may provide information to third-parties if we believe in good faith that we are required by mandatory law to do so. For example to comply with legal orders and government requests; response to a subpoena or similar legal process including to law enforcement agencies regulators and courts; to protect the interests of our customers and users of HOLINK Service; to respond to claims that any content posted or displayed using HOLINK Service violates the rights of third parties; in an emergency protect the health and safety of users of HOLINK Service or the general public; or to enforce compliance with our Terms of Service.
  • Legitimate Business Interests of HOLINK. We share information to protect our own legitimate business interests when we believe in good faith that we are required or permitted by law to do so. For example we may share your personal information as needed to support auditing compliance and corporate governance functions; to combat fraud or criminal activity; to protect our rights or those of our affiliates and users; or as part of legal proceedings affecting HOLINK.

In addition to the above we may also disclose non-personal information (for example aggregated or anonymized Information) publicly or with third-parties provided those Information have been rendered anonymous in such a way that the Information subject is no longer identifiable.


6. Retention and Disposal of Your Information

We will retain your Personal Information for a period necessary to fulfill the purpose for which it was collected until you remove your information or for a period required by applicable regulations. When we no longer require your personal information we will either delete or anonymize it or if this is not possible (for example because your Personal Information has been stored in backup archives) then we will securely store your Personal Information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you) we may use this information indefinitely without further notice to you.


7. Your Privacy Rights

Subject to applicable law you may have the following rights regarding the Processing of your relevant Personal Information:


7.1 Right to Access

You have the right to obtain confirmation from us that we process your personal information and if so you may have the right to request access to your personal information.


7.2 Right to Rectification

You have the right to request that we rectify inaccurate personal information concerning you and depending on the purposes of the processing you may have the right to have incomplete personal information completed.


7.3 Right to Erasure

You have the right to request us to erase some or all of the personal information concerning you.


7.4 Right to Restrict Processing

You have the right to request us to restrict the further processing of your personal information. In such cases the respective information will be marked as restricted and may only be processed by us for certain purposes.


7.5 Right to Information Portability

You have the right to object on grounds relating to your particular situation to the processing of your personal information by us and we may be required to no longer process some or all of your personal information.


7.6 Right to Object to Directive Marketing

You have the right to object to the processing of Personal Information for direct marketing purposes.


7.7 Right to Object to Decision Based Solely on Automated Processing

You have the right not to be subject to a decision based solely on automated processing where the decision has a significant legal impact on you.


7.8 Right to Object to Processing

You have the right to object to the processing of your information if the information is processed based on necessity for the performance of a task carried out in public interest or necessity for our’s or third-party’s legitimate interests.


7.9 Right to Withdraw Consent

You have the right to withdraw consent you have provided to us where we rely solely on your consent to process your personal information. You can always provide your consent to us again at a later time. Please note that the withdrawal will not affect the processing of information based on prior consent.


8. Notice for Data Subjects Residing in California

The California Consumer Privacy Act (“CCPA”) provides consumers (California residents) with specific rights regarding their personal data. This section describes your CCPA rights. To exercise any of these rights please visit [info@holink.us].


8.1 Access to Specific Information and Data Portability Rights

You have the right to request that the Company disclose certain data to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or sharing that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we disclose your personal information for a business purpose we will identify the personal information categories that each category of recipient obtained.

8.2 Right to Delete

You have the right to request that the Company delete any of your personal information that we collected from you and retained subject to certain exceptions. Once we receive and confirm your verifiable consumer request we will delete (and direct our service providers to delete) your personal information from our records unless an exception applies.


8.3 Right to Opt-Out Of Sales or Sharing

You have the right to opt-out of the sale or sharing of your personal data. You may exercise the right at any time by clicking “Do Not Sell My Personal Information” <https://us.eufy.com/pages/privacy-request?ref=footer>. You can also send the request through the access path located at the bottom of the webpage.


8.4 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for like-goods or services including through granting discounts or other benefits or imposing penalties.
  • Provide you with a different level or quality of like-goods or services.
  • Suggest that you may receive a different price or rate for like-goods or services or a different level or quality of like-goods or services.

8.5 “Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websites other products services and platforms that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.


9. Children’s Data Protection

We place great importance on the security of children’s information. Our Services are not intended to be operated by children nor do we knowingly collect children’s personal information for the provision of our Services or the operation of our devices. If you become aware that your child has provided us with personal information without your consent please contact us here <info@holink.us>. If we become aware that a child has provided us with personal data we will delete the data from our system.


We do not intend that any portion of its HOLINK Services will be accessed or used by children under the age of 18 or equivalent minimum age in the relevant jurisdiction and such use is prohibited. Our HOLINK Services are designed and intended for adults. By using HOLINK Services you represent that you are at least 18 years old or above the equivalent minimum age in the relevant jurisdiction and understand that you must be at least 18 years old or above the equivalent minimum age in the relevant jurisdiction in order to create an account and purchase the goods or services advertised through our HOLINK Services. If we obtain actual knowledge that an account is associated with a registered user who is under the age of 18 years old or equivalent minimum age in the relevant jurisdiction we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 18 or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us please contact us by email at info@holink.us. A parent or guardian of a child under the age of 18 or equivalent minimum age in the relevant jurisdiction may review and request deletion of such child’s personal information as well as prohibit the use thereof.


10. Global Operations and Data Transfers

We transfer and process your information globally both in our own facilities and with service providers or partners regardless of where you use our Services. As HOLINK operates globally we may transfer your personal information to our affiliates worldwide when processing that information for the purposes described in this Privacy Policy e.g. if you request for customer services from HOLINK our colleagues in China may access certain of your information (wherever you are located) in order to provide the requested services to you. We shall do so in accordance with the applicable laws. In particular we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You hereby agree to the data transfer and you have the right to be informed of the appropriate safeguards taken by HOLINK for this transfer of your Personal Information.


Currently we have data centers in the U.S. and China. The laws regulations and standards of the country in which your information is stored or processed may be different from those of your own country. You have understood that the risks under applicable data protection laws are different and we may transfer to and store your personal information at our overseas facilities. However this does not change any of our commitments to safeguard your personal information in accordance with this Privacy Policy.


11. Updates to the Privacy Policy

This Privacy Policy went into effect on the “Last Updated” date noted near the top of this page. We may update our Privacy Policy from time to time. We encourage you to look for updates and changes to this Statement by checking the “Last Updated” date when you access our websites or mobile applications. If we make material changes to how we treat our users’ personal information we will notify you by notice in the App.


12. Contact Us

If you have any questions or comments about this Privacy Policy or our privacy practice please contact: info@holink.us. We answer all inquiries and concerns within 30 days.