PRIVACY POLICY

Update!

Our Privacy Policy was updated on 14 July 2021. We have revamped the Privacy Policy front and back so that from this date onwards, this Privacy Policy can provide privacy details on how we manage your personal information for Mi 360° Home Security Camera 2K Pro software and services provided by Imilab.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

OUR COMMITMENT TO YOU

This Privacy Policy sets out how Imilab Inc. and its affiliated companies within the Imilab Inc. (“Imilab”, “we”, “our” or “us”) collect, use, disclose, process and protect any information that you give us when you use Mi 360° Home Security Camera 2K Pro software and services. Should we ask you to provide certain information by which you can be identified when using Mi 360° Home Security Camera 2K Pro software and services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

The Privacy Policy is designed with you in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, as well as full confidence that ultimately, you have control of any personal information provided to Imilab.

In this Privacy Policy, “personal information” means information that can be used to identify an individual, either from that information alone or from that information combined with other information Imilab has access about that individual. Such personal information may include but not limit to the information you provide to us or upload, device information, etc.

By using Mi 360° Home Security Camera 2K Pro software and services, you are deemed to have read, acknowledged and accepted all the provisions stated here in the Privacy Policy, including any changes we may make from time to time. In order to comply with applicable laws, including local data protection legislation, we will specifically seek prior explicit consent to the particular processing (e.g., automated individual decision-making) of special categories of personal data. We are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, including your local data protection legislation. We are equally committed to ensuring that all our employees and agents uphold these obligations.

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact our Data Protection Officer at https://privacy.mi.com/support to address your specific concerns. We will be happy to address them directly.

WHAT INFORMATION IS COLLECTED AND HOW WE CAN USE IT

TYPES OF INFORMATION COLLECTED

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. If you do not provide your personal information, we may not be able to provide you with our products or services.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of information (which may or may not be personal information):

• Account information: We will collect information about your Mi account and the Mi accounts you share the device with.
• Device related information: We may collect information about the hardware, performance, status, etc. of your device, including device name, DID, firmware version, installation location (such as in the living room), time zone, security code (if any) for viewing the device, screen information (such as sharpness, scaling), as well as memory card information (errors, remaining storage, recording mode).
• Information about device settings: We may collect information about device settings, including status indicator on/off, flow protection switches，physical obstruction settings, image settings, night vision settings, human tracking switch , Home Surveillance Assistant settings (sensitivity, home surveillance period, alarm interval, push setting), baby crying sound detection.
• Network Information: We may collect network-related information when your device is connected to a network, including current Wi-Fi connection mode (LAN or remote), assigned IP address, Wi-Fi signal intensity, RSSI, MAC address, and the Wi-Fi network name (SSID) and password you provide. Such information will be encrypted and stored in a secure server and will be used for purposes you authorize.
• Video recording information: When Home Surveillance Assistant is enabled, we may collect information about videos triggered when someone lingers or passes within the detection range of the camera (i.e., Home Surveillance Assistant video recording ) and videos triggered by the crying sound of your baby when baby crying sound detection is enabled (i.e., baby crying video recording ). Therefore, we may collect information related to recording, including recording date and duration, trigger event, play speed. If you use a storage card, you can also choose to store the video on the storage card in the recording mode you set. We will also collect information about events that trigger video recording, including area change, someone passing by, baby crying sound, and smart scenarios trigger.
• Feedback: We will collect feedback, contact information and error log you provide.
• BLE sub-device’s information: Mi 360° Home security Camera 2K Pro will also work as BLE gateway to support other BLE sub-devices to connect to internet. We will collection information about BLE-sub devices which connect to Mi 360° Home security Camera 2K Pro, including BLE sub-device device ID, model name, device name, device status, MAC address, signal strength.
• Device access record: In order to facilitate you to view the access records before and after device sharing at any time, we will collect the information related to the device visitor, including the Imilab Account name, Imilab Account, access time and date, accessed device information, and the location of the visitor. Meanwhile, we will mark the access account of the device shared person as the shared account. The access records will be retained for up to 7 days and will be automatically deleted after then. If you need to use this function, you can update the plug-in version of this product to V182 and later.

We may also collect other types of information which are not directly or indirectly linked to an individual and which is aggregated, anonymized or de- identified. For example, the device model and system version number of the user’s Imilab device may be collected when using a particular service. Such information is collected in order to improve the services we provide to you.

HOW THE PERSONAL INFORMATION IS USED

Personal information is collected for providing services and / or products to you, and legal compliance on our part under applicable laws. You hereby consent that we may process and disclose personal information to our affiliated companies, Third Party Service Providers (defined below) for the purposes stated in this Privacy Policy.

We may use your personal information for the following purposes:

• Providing, processing, maintaining, improving and developing our goods and/or services to you, including after-sales and customer support and for services on your device or through our websites.
• Communicating with you about your device, service or any general queries, such as updates, customer inquiry support, information about our events, notices.
• Analyzing and developing statistical information on use of our products and services to better improve our products and services.
• Optimizing the performance and security of your device.
• Storing and maintaining information about you for our business operations or legal obligations.
• Providing local services without communicating with our servers.

Here are more details on how we use your information (which may include personal information):

• Pairing with device and synchronize data: We will collect information about accounts, device and network to synchronize data, enable the device to accept plug-in instruction, and upload data to server (applicable to specific functions/services only).
• Viewing live image: You can view the live image from time to time on your phone. For this reason, we will collect information about current image time, playback speed, image quality option and volume. In addition, you can snap a screenshot or record the current live image. Live image screenshot/video recording will be saved on your phone instead of being uploaded to any server. You can also control the angle with the arrow keys. To do this, we will send your control instructions to the device.
• Home Surveillance Assistant: You can enable or disable the Home Surveillance Assistant function. If enabled, video recording will be triggered when image changes within the detection range of the camera. You can set the distance (in meters) away from the door to trigger video recording, the start and end time of home surveillance, and the shooting interval to avoid interruption from one same event. You can view the videos online on your phone. To do this, we will collect information about your settings on sensitivity, home surveillance periods, shooting interval, and image change push notification on/off.
• Video playback: You can view videos of various types in the plug-in. To do this, we will collect and encrypt the videos triggered by Home Surveillance Assistant and baby cry, as well as the triggering events, and save these encrypted data in a secure server. The videos will be stored on the server. To do this, we will collect information related to your network, information related to recording, including recording date, recording time, trigger event, recording video duration, sound settings, and play speed.
• Baby crying sound detection: When baby crying sound detection is enabled, you will receive a push notification if baby crying sound is detected. We process it locally and do not upload it to the cloud. To do this, we will collect information about the on/off status of baby crying sound push notification.
• Two-way talkback: You can view information about the live image in the plug-in and talk with the visitor with two-way talkback function. We will not collect information about your conversation, unless you select to record current live image before using the two-way talkback. But under no circumstances will we try to read or identify your conversation.
• To collect user feedback: The feedback you provide is extremely valuable in helping us improve our services. In order to track your feedback, Imilab may use the personal information you provide to contact you and to keep records.
• Sending notification: The device will send you corresponding notification according to triggering events. For example, you can set the device to send notification to your phone when monitored image changes. To do this, we will collect information about your push settings. You can disable push notification in Settings.

WITH WHOM WE SHARE YOUR INFORMATION

We do not sell any personal information to third parties.

We may disclose your personal information on occasion to third parties (as described below) in order to provide the products or services that you have requested.

Disclosure may be made to Third Party Service Providers and affiliated companies listed in this section below. In each case described in this section, you can be assured that Imilab will only share your personal information in accordance with your consent. Your consent to Imilab will engage sub-processors for the processing of your personal information. You should know that when Imilab shares your personal information with a Third Party Service Provider under any circumstance described in this section, Imilab will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. Imilab will contractually ensure compliance by any Third Party Service Providers with the privacy standards that apply to them in your home jurisdiction.

SHARING WITH OUR GROUP AND THIRD PARTY SERVICE PROVIDERS

In order to conduct business operations smoothly in providing you with the full capabilities of our products and services, we may disclose your personal information from time to time to other Imilab affiliated companies, or our third party service providers which are our mailing houses, delivery service providers, telecommunications companies, data centers, data storage facilities, customer service providers, advertising and marketing service providers, and Imilab’s representatives. Such Third Party Service Providers would be processing your personal information on Imilab’s behalf or for one or more of the purposes listed above. If you no longer wish to allow us to share this information, please contact us at https://privacy.mi.com/support.

After-sales, push, troubleshooting and other service provider: After-sales, push, troubleshooting and other services for the product are provided by third party Shanghai Imilab Technology Co., Ltd., and we may provide your firmware log information to such service provider for the purpose of providing the above services to you.

SHARING WITH OTHERS

Imilab may disclose your personal information without further consent when required under applicable law.

INFORMATION NOT REQUIRING CONSENT

We may share anonymized information and statistics in aggregate form with third parties for business purposes, for example with advertisers on our website, we may share them trends about the general use of our services, such as the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

For the avoidance of doubt, Imilab may collect, use or disclose your personal information without your consent if it is and only to the extent it is allowed explicitly under local data protection laws. Such disclosure may be brought about by the necessity to protect our rights, ensure the safety of you and other people, and comply with the requirements of the local government to facilitate the investigations of illegal activities.

SECURITY SAFEGUARDS

IMILAB’S SECURITY MEASURES

We are committed to ensuring that your personal information is secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure the information we collect from your using of Imilab products and services and on Imilab websites. We will use all reasonable efforts to safeguard your personal information.

For example, when you access your Mi Account, you can choose to use our two- step verification process for better security. When you send or receive data from your Imilab device to our servers, we make sure they are encrypted using Secure Sockets Layer (“SSL”) and other algorithms.

All your personal information is stored on secure servers that are protected in controlled facilities. We classify your data based on importance and sensitivity, and ensure that your personal information has the highest security level. We make sure that our employees and Third Party Service Providers who access the information to help provide you with our products and services are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. We have special access controls for cloud based data storage as well. All in all, we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We will take all practicable steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

WHAT YOU CAN DO

• You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you. Whenever you log in as a Mi Account user on Imilab websites, particularly on somebody else’s computer or on public Internet terminals, you should always log out at the end of your session.
• Imilab cannot be held responsible for lapses in security caused by third party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must notify us immediately if there is any unauthorized use of your account by any other Internet user or any other breach of security.
• Your assistance will help us protect the privacy of your personal information.

RETENTION POLICY

Personal information will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by Imilab even if the further processing is incompatible with original purposes.

All the personal information on the device will be erased when you reset your device to factory default settings. To implement a hard-reset function, you can insert the needle into the resetting hole of camera, and hold it for about 3 seconds. When the sensor indicator light turns yellow, the device implements factory default settings successfully. Beware that hard-reset can’t be undo, so you have to make sure that you don’t need the information any more.

ACCESSING OTHER FEATURES ON YOUR DEVICE

Our applications may need access to certain features on your device such as Wi-Fi network status. This information is used to allow the applications to run on your device and allow you to interact with the applications. At any time you may revoke your permissions by turning these off at the device level or contacting us at https://privacy.mi.com/support.

YOU HAVE CONTROL OVER YOUR INFORMATION!

CONTROLLING SETTINGS

Imilab recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways Imilab makes available for you to choose to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings:

• Add/delete the device;
• Log in and out of the Mi Account;
• Go to “Settings > Home Surveillance Assistant setting” to enable or disable Home Surveillance Assistant;
• Go to “Settings > Push settings” to manage push notifications;
• Toggle on/off for other services and functionalities which deal with sensitive or personal information.

If you have previously agreed to us using your personal information for the abovementioned purposes, you may change your mind at any time by writing or submitting a request to https://privacy.mi.com/support.

ACCESSING, UPDATING, CORRECTING OR ERASING YOUR PERSONAL INFORMATION

• You have the right to request access to and/or correction of any other personal information that we hold about you. When you update your personal information, you will be asked to verify your identity before we proceed with your request. Once we obtain sufficient information to accommodate your request for access to or correction of your personal information, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.
• A copy of your personal data collected and processed by us will be provided to you upon your request free of charge. For any extra request of the same information, we may charge a reasonable fee based on actual administrative costs according to the applicable laws.
• If you would like to request access to your personal data held by us or if you believe any information we are holding on you is incorrect or incomplete, please submit a request to https://privacy.mi.com/support.
• For details relating to the personal information in your Mi Account, you may also access and change them at http://account.mi.com or by logging into your account on your device.
• You may also log in to Mi Account (https://www.mi.com/global/) and enter “privacy” module, where you could delete the data generated by web apps and services as well as permanently delete your account along with the data associated with it. If you would like to delete the data generated by smart device, please submit a request to https://privacy.mi.com/support.

WITHDRAWAL OF CONSENT

You may withdraw your consent for the collection, use and/or disclosure of your personal information in our possession or control by submitting a request to https://privacy.mi.com/support. This can be performed by going to the "Settings > Additional settings > Legal information > Revoke authorization ", clicking the button “OK” to withdraw authorization. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request.

Please recognize that your withdrawal of consent could result in certain legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy Mi 360° Home Security Camera 2K Pro software and services.

TRANSFER OF PERSONAL INFORMATION OUTSIDE OF YOUR JURISDICTION

To the extent that we may need to transfer personal information outside of your jurisdiction, whether to our affiliated companies (which are in the communications, social media, information technology, and cloud businesses) or Third Party Service Providers, 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 will have the right to be informed of the appropriate safeguards taken by Imilab for this transfer of your personal information

Imilab may use overseas facilities operated and controlled by Imilab to process or back up your personal information. Currently, Imilab has data centers in Beijing, United States, Singapore, Russia, India and Germany. These overseas jurisdictions may or may not have in place data protection laws which are substantially similar to that in your home jurisdiction. 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.

MISCELLANEOUS

MINORS

We consider it the responsibility of parents to monitor their children’s use of our products and services. Nevertheless, it is our policy not to require personal information from minors or offer to send any promotional materials to persons in that category.

Imilab does not seek or intend to seek to receive any personal information from minors. Should a parent or guardian have reasons to believe that a minor has provided Imilab with personal information without their prior consent, please contact us to ensure that the personal information is removed and the minor unsubscribes from any of the applicable Imilab services.

ORDER OF PRECEDENCE

If you have agreed to our applicable User Agreements, in the event of inconsistency between such User Agreements and this Privacy Policy, such User Agreements shall prevail.

UPDATES TO THE PRIVACY POLICY

We keep our Privacy Policy under regular review and may update this privacy policy to reflect changes to our information practices. If we make material changes to our Privacy Policy, we will notify you by email (sent to the e-mail address specified in your account) or post the changes on all the Imilab websites or through our software, so that you may be aware of the information we collect and how we use it. Such changes to our Privacy Policy shall apply from the effective date as set out in the notice or on the website. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of products and services on the websites, mobile phones and/or any other device will be taken as acceptance of the updated Privacy Policy. We will seek your fresh consent before we collect more personal information from you or when we wish to use or disclose your personal information for new purposes.

DO I HAVE TO AGREE TO ANY THIRD PARTY TERMS AND CONDITIONS?

Our Privacy Policy does not apply to products and services offered by a third party. Imilab products and services may include third parties’ products, services and links to third parties’ websites. When you use such products or services, they may collect your information too. For this reason, we strongly suggest that you read the third party’s privacy policy as you have taken time to read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating to Imilab’s collection, use, or disclosure of your personal information, please contact us via https://privacy.mi.com/support or at the address below. When we receive privacy or personal information requests about accessing or downloading personal information, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information.

If you are not satisfied with the response you received from us in relation to your personal information, you can hand over the complaint to the relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.

Imilab Communications Co., Ltd. #019, 9th Floor, Building 6, 33 Xi’erqi Middle Road, Haidian District, Beijing, China 100085

Imilab Singapore Pte. Ltd. 20 Cross Street, China Court #02-12 Singapore 048422

For users in India:

Imilab Technology India Private Limited Building Orchid, Block E, Embassy Tech Village, Outer Ring Road, Devarabisanahalli, Bengaluru, Karnataka - 560103, India

Any discrepancies and grievances with respect to processing of sensitive personal data or information shall be informed to the designated Grievance Officer as mentioned below:

Name: Vishwanath C

Telephone: 080 6885 6286, Mon-Sat: 9 AM to 6 PM

Email: grievance.officer@Imilab.com

For users in the European Economic Area (EEA):

Imilab Technology Netherlands B.V. Prinses Beatrixlaan 582, The Hague 2595BM Netherlands

Thank you for taking the time to read our Privacy Policy!