Release/Update Date: October 15, 2021

Effective date: October 18, 2021

【Overview】

Thank you for trusting and using AView. AView (hereinafter also referred to as ‘we’) takes user privacy very seriously. We understand the importance of your personal information, and we are committed to protecting your personal information in strict compliance with the requirements of laws and regulations and in accordance with the developed safety standards in the industry. To this end, we have created AView Privacy Policy (hereinafter also referred to as this Policy) so that you can learn more about how AView collects, uses, transfers, stores and discloses your personal information and what your rights are under our products or services. Special Note: Explanations of specific terms and their sources are set forth in an appendix, with those closely related to your rights highlighted in bold or underlined; you are encouraged to read carefully and understand this Privacy Policy before using our products and services in order to make appropriate choices.

The main points of this policy are as follows：

We will collect and use your personal information in accordance with the Privacy Policy, but we will not collect all your information at one time through mandatory bundling since you agree to this policy.

When you use or activate the relevant functions or use the services, we will collect and use the relevant information from you for the reason of the realization of functions and services. You may refuse to provide such information unless it is essential for the realization of basic business function or as required by law or regulation which will not affect the use of other functions or services; however, you should be aware that if you refuse to provide the necessary information, AView will not be able to provide you with complete products or services and may not be able to respond to or resolve problems you encounter in certain specific scenarios.

Location, camera, microphone, photo album (storage) are not turned on by default and will only be used for the realization of specific functions or services with your explicit authorization, which you can also withdraw. In particular, even if we obtain these sensitive permissions with your authorization, we will not collect your information when it is not needed for the function or service concerned, as explained in detail in hyperlinks to each mobile application’s permission acquisition instructions and the scenario of third-party SDK integration.

AView mobile application privacy statement（AViewAPP）

This Policy applies to all AView services, including services provided by AView through its own branded intelligent hardware or eachAView Software, as well as parts of AView’s features/services that are integrated into third-party products or software (such as AView services under applets and official accounts) (collectively, our products or services), the personal information used by specific products or services may vary or may be adjusted after the release of this Policy.

Since this Policy is relevant to the products or services you use, we hope that you read carefully and understand this Policy, specifically the terms identified in bold/underlined/italicized, before use our products or services and, if necessary, follow the guidelines in this Policy to make the choices you deem appropriate. By clicking on the consent option or using AView services, you consent to our collection, use, storage, disclosure and processing of your relevant personal information in accordance with this Policy.

If you have any questions, comments or suggestions, you may contact us via the means agreed to in Chapter 9 of this policy.

【Main body of the policy】

You can further understand the details of this policy by reading the corresponding chapters according to the following index：

Chapter 1: How we collect and use your personal information

Chapter 2: How we entrust the processing, sharing, transfer and public disclosure of your personal information

Chapter 3: How we protect and store your personal information

Chapter 4: Your rights

Chapter 5: Third party services

Chapter 6: How we handle personal information of minors

Chapter 7: Revisions and updates of this Policy

Chapter 8: How to contact us

Chapter 1: How we collect and use your personal information

I. The personal information we collect and use

When using our products or services, you may need to actively submit to us or authorize us to collect and use personal information, including the following two：

• Information necessary to perform the essential business functions of providing our products or services to you. If you refuse to provide the corresponding information, you will be unable to use our products and or services properly.
• Information necessary to enable additional business functions of our products or services to be provided to you. Refusing to provides such information will result in your inability to use the relevant additional business functions or achieve the functional effect we intend to achieve and will not affect your use of the basic business functions of our products and services as usual.

Please be reminded that：

• Our products or services are provided through different carriers, and the specific products/services selected by different users differ; accordingly, the basic additional functions and the type and scope of personal information collected and used may differ, please refer to the specific product service functions.

2）Some services may require you to open the corresponding permissions on your terminal device, you can check the specific permissions involved in AView APP through AView Mobile Application Privacy Statement and turn them on or off at any time through your phone’s Settings – Application Permissions to manage your corresponding information authorization. It is important to note that even if we have obtained these permissions with your authorization, we will not collect your information when it is not needed for service or function concerned.

3）In order to bring you a better experience of our products and services, we are continuously working to improve our technology, and we may introduce new or optimized features from time to time, which may require the collection and use of new personal information or change the purpose or manner of use of personal information. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this Policy, pop-up windows, page prompts, etc., and provide you with autonomy in the option of consent, and collect and use it after obtaining your explicit consent. In this process, if you have any questions, comments or suggestions, you can contact us through the various contact information listed in this Policy, and we will provide you with answers as soon as possible.

We collect and use your personal information for the following functions and purposes under this policy：

1. Registration, Account Login and Verification：

When you visit our application, although you can browse and search relevant web pages, you need to register as an AView user to access the posting, commenting and other user services. When you register and login to AView and related services, you need to provide your cell phone number, email address, password and verification code; such information is required by the real-name system registration of applicable laws and regulations and if you refuse to provide it, you will not be able to register successfully. Additionally:

1. You may choose to fill in your nickname, avatar or email address according to your own needs in order to use our other personalized services (specific services and corresponding information will be notified to you through system prompts or in other manners), unless otherwise stated, refusing to submit such additional information will not affect your access to basic functions of your AView account.
2. 2.For services that require an AView account to access, we may verify your user identity based on the information you provided above to ensure that we provide the service to you personally.
3. AView Cloud Services：

With an AView account login, you can bind your product to AView APP and control or manage it remotely (i.e., AView cloud services). We will collect and use personal information according to the specific features you select.

1. When you bind your device to use AView cloud services, we will collect your ID and QR code of the product bound. Such information is unique basic information of product that must be collected to bind the products and further provide you with AView cloud services.
2. In order to provide a more humanized service, we will store a screenshot of your current video screen to facilitate your identification of the surveillance location when you use the preview function of the video surveillance equipment; The screenshot will only be stored in your phone’s memory and will only be used, but not collected by AView; and you can refuse us to store the screenshot by turning off file storage permissions. It is important to note that the screenshot and video features require you to grant file storage permission, the screenshot and video are stored in your phone’s memory, and we will not collect or view your screenshot or video content.
3. 3.When you use features such as remote intercom, we accordingly collect the audio content you submit in order to enable you to use that feature. You can refuse us to do so by turning off microphone permission through the system settings, but this will prevent you from using the feature.
4. 4.When you use the analysis or comparison function based on the user’s baseline information (including face/personal recognition, license plate/vehicle recognition, voice recognition, text recognition, fingerprint unlocking), you need to enter the license plate number, face picture, voice, and text information in advance so that we can extract and process the characteristic value of your baseline information and implement the related service on the hardware; if you refuse to provide it, you will not be able to use the related function.
5. 5.When you turn on the message alert feature, we will push relevant system messages and you will have a video screenshot of the cloud service displayed when you view the message. You can turn off this feature via the message alert setting button.
6. 6.When you use AView devices, videos or recordings sharing related features, you need to submit the account information of the relevant person(s), as prompted by the sharing feature interface. If you refuse to provide it, you will be unable to use the relevant features. It is important to note that sharing or similar features will make your personal information public within the range you specify, and you must decide carefully whether to use them and be responsible for the consequences.
7. 7.When you use the value-added services based on AView cloud, we will collect your personal information directly related to the purpose of the service. Specific service purposes and information content will be indicated to you in the form of service descriptions or rules of use. Such information is necessary for us to provide you with various value-added services, refusing to provide it may result in your inability to use the relevant services normally.

iii.Suggestions and Questionnaires：

We will record the contact information, feedback questions or suggestions you submit when using the above features in order to improve our products or services and enhance your experience.

1. Security Assurance, Operation and Maintenance Services:

To meet Network Security Law and other laws and regulations and the basic requirements for the provision of services to protect your account security and system operation security, we will collect relevant information generated during your use of our products or services, including:

1. 1.When you useAView Softwareand related services, we receive and record information about the devices and logs you use to install and use AView Software, according to the specific permissions you grant during the installation and use of the software, which includes your cell phone or computer hardware model, operating system version number, browser type, International Mobile Equipment Identity (IMEI), International Mobile Equipment Identity (IMSI), Network Hardware Address (MAC), IP address, software version number, network access method and type, and operation log information. Please understand that such information is essential to the provision of our services and the assurance of proper function of our products, as well as to the prompts of updates onAView Software.
2. 2.When you use AView cloud servicesto manage your bundled smart electronic hardware devices, we automatically receive and record information about the devices, including type, model, firmware number, MAC address, system version number, and system settings. We use such information to provide services to you and keep your devices function safely; for example, if your system is set to allow automatic device upgrades (which is enabled by default on some devices), we will automatically install and run the upgrade package for you when it becomes available to ensure that your device is always effectively adapted toAView Softwareyou are using.
3. 3.To help us better understand the operation of AView service and ensure the security of the operation and provision of the service, we may record network log or device log information, as well as information on the frequency of use of software, devices and related services, crash data, error reporting or abnormal service data, system operation status, overall installation and usage, performance data of abnormal devices, etc. Please note that information such as device information and log information alone is information that cannot be taken to identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person or use it in combination with personal information, such non-personal information may be treated as personal information during the period of combined use. We will anonymize and de-identify such personal information unless we obtain your authorization or it is required by laws and regulations.
4. Changes in the Purpose of Collecting and Using Personal Information：

Please be aware that we may make adjustments to AView services as our business develops. In principle, when a new function or service is related to the function or service we currently provide, the personal information collected and used will be directly related or reasonably related to the original purpose of processing. In scenarios where there is no direct or reasonable connection to the original processing purpose, we will collect and use your personal information in accordance with the requirements of laws, regulations, and national standards by separately informing you with page prompts, interaction processes, and agreement confirmation, and obtaining your consent.

II. Rules for the use of your personal information

1. We will use your personal information in accordance with the following rules.

（1）We will use it as agreed in this Policy and for the purpose of achieving the function of appropriate product or service.

（2）We may use your personal information and other information that we obtain in a lawful manner in connection with your use of the services or products (hereinafter being referred to as Other Information) in combination to prevent, detect, and investigate fraud, infringement, threatening security , illegality, or violation of agreements with us or our affiliates.

（3）We may process your personal information or use it in combination with other information for the purposes of maintaining, improving, optimizing our products or services, and enhancing the user experience, including recommending content that maybe you are interested in, sending you commercial electronic messages (‘advertisements’), or sharing information with partners so that they can send you information about other auxiliary products and services in accordance with this Policy.

（4）When you access third party services through our products or services, we may share personal information within the scope of your authorization with the third party service provider in accordance with your authorization.

（5）Other uses as permitted by you.

2. 2.Please note that all personal information that you provide or authorize us to collect when you use our products or services will be retained and used for the duration of your use of our products or services. If you refuse our collection through your account settings or system settings, we will stop collecting it accordingly (and may not be able to provide you with the corresponding services as a result); however, unless you delete your personal information in accordance with the law, your refusal will not affect our processing and storage of personal information based on your previous authorization.
3. 3.We may compile statistics on the use of our products or services and may share such statistics with the public or third parties to demonstrate overall usage trends of our products or services or to generate research results such as market satisfaction studies and service improvement plans in connection therewith. However, these statistics will not contain any personally identifiable information of yours.
4. 4.When we display your personal information, we will use methods including content replacement and preserving anonymity to desensitize your information for your information safety.
5. 5.When we want to use your personal information for purposes other than those maintained in this Policy, or when information collected for a specific purpose has been used for other purposes, your consent will be sought in advance via a checkbox that you have actively selected.

III.Exceptions to the collection and use of personal information with prior authorized consent

You are fully aware that, according to the Information security technology – Personal information security specification and its legal basis, your authorized consent is not required for the collection and use of your personal information in the following cases:

1. In connection with AView’s fulfillment of its obligations imposed by laws and regulations.
2. Those directly related to national security or national defense.
3. Those directly related to public safety, public health, and major public interests.
4. Those directly related to criminal investigation, prosecution, trial and execution of judicial decisions, etc.
5. For the purpose of protecting your or other individual’s legitimate rights and interests, life safety, and property safety and your authorization for collecting such information cannot be obtained for some reason.
6. Where the personal information involved has been made public by yourself.
7. According to the circumstances necessary for you to enter into and fulfill a contract or other written document with us.
8. Where your personal information has been made publicly available in legitimate news coverage, governmental announcements, and other channels.
9. For ensuring the safe and stable operation of the provided products or services, such as identifying and/or fixing failures of such products or services.
10. Other circumstances specified in laws and regulations.

Chapter 2: How we entrust the processing, sharing and public disclosure of your personal information

I. Entrusted processing

Entrusted processing refers to the process by which AView, as the controller of personal information, entrusts other companies or organizations (including our affiliates) with specialized analytical skills or capabilities to process user information on our behalf within the scope of legal authorization. We usually adopt entrusted processing with operations such as SMS and email delivery, intelligent comparative analysis, etc in order to improve the efficiency and reduce the cost of information processing. We will require the entrusted company to comply with strict confidentiality obligations and take effective confidentiality measures through written agreements, on-site audits, etc., and prohibit them from using such information for purposes not authorized by you; at the same time, we will require them to delete your personal information as soon as the entrusted relationship is terminated.

1. Sharing

Sharing is the process by which AView makes personal information available to other controllers of personal information and each party has separate control over the personal information. We are committed to sharing your personal information with third parties only when it is legal, legitimate, necessary, specific and for a definite purpose, and only as much personal information as is necessary to achieve the relevant purpose. We will also perform third party  management through strict access, confidentiality agreements, auditing and monitoring, and require them to handle relevant information with no less confidentiality and security measures than those required by this Policy.

1. We will not share your personal information with outside parties, except in the following circumstances：

1）AView has obtained the express authorization or consent from you or your guardian.

2）Where we are required by competent  authorities, such as a judicial or administrative body, to disclose it based on legal procedures.

3）To the extent required or permitted by law or regulation, to deal with disputes or controversies between you and others, or to protect you or AView and its affiliates, AView users, and the public interests from harm.

4）When shared with our affiliates without violating this Policy.

5）Sharing with our partners as agreed in the relevant service agreements, rules of use, etc. between you and AView and for the purpose of providing you with services.

6）Other cases required or permitted by the applicable laws and regulations such as Network Security Law.

2. 2.Sharing with affiliates: Personal information collected by us may be shared with or actually processed by our affiliates based on considerations such as a unified account system and a consistent brand experience. We promise that we will share only the necessary personal information and that such sharing will be subject to the purposes of this Policy; at the same time, we will ensure security through legal documentation between affiliates, internal systems and segregation of employee permissions.
3. 3.Sharing with partners: In order to provide you with improved, optimized products or services, we may share your personal information with third-party partners who support the function of our products or services. These third parties assist us or provide services to you on their own behalf; we share your personal information with them for the purpose of enabling the products or services you have selected; and we share your personal information with them only to the extent necessary for them to provide the appropriate support.

At present, the third party partners aforementioned include the following types：

1）Suppliers that provide operation support for AView’s own products or services, including warehousing and logistics providers, outsourced customer service, installers, authorized repairers, etc. We need to share your order information or product information with these suppliers in order to provide you with logistics and distribution, customer support and other related services.

2）Partners who work with us to provide a particular service, including third parties such as watching service providers, Key Management Service providers, etc. We will share with them the information necessary to complete the service, based on the specific service you have selected.

3）Third party merchants that provide their own products or services through our user operation system, including third party SDK operators, third party developers that support authorized login for AView accounts, and partners that entrust us with information promotion. We may share your necessary account information, usage information, etc. with them so that they can provide you with relevant products or services.

4. 4.The shared parties may have their own privacy policies or related statements, and we recommend that you review them carefully before making any authorization and make any choices you deem appropriate.

You should be aware that when you use certain features of the Service, we may access software development kits (SDKs) provided by third parties to implement the relevant features. This includes, in particular, the following.

III. Public disclosure

Your personal information will only be disclosed publicly under the following circumstances:

1. Upon your express consent;
2. Disclosure based on law: We may publicly disclose personal information relating to your violation of law or contract if compulsively required by law, legal process, litigation or governmental authority, or to ensure AView users or the public’s life safety and property safety.

IV. Exceptions to prior authorized consent for sharing and public disclosure of personal information

Please understand that, in accordance with the applicable laws, regulations and national standards, such as Network Security Law and the Information security technology – Personal information security specification, your authorized consent is not required for sharing and public disclosure of your personal information in the following circumstances.

1. In connection with AView’s fulfillment of its obligations imposed by laws and regulations.
2. Those directly related to national security or national defense.
3. Those directly related to public safety, public health, or major public interests.
4. Those directly related to crime investigation, prosecution, trial and execution of judicial decisions, etc.
5. For the purpose of protecting your or other individuals’ legitimate rights and interests, life safety and property safety and your authorization for collecting such information cannot be obtained for some reason.
6. Where the personal information involved has been made public by yourself.
7. Where your personal information has been made publicly available in legitimate news coverage, governmental announcements disclosure, and other channels. In addition, in accordance with the aforementioned laws and regulations, if personal information that has been de-identified is provided to the public and it is ensured that the recipient of the data cannot recover and re-identify the subject of the personal information, it will be unnecessary to specially notify you or obtain your consent.

Chapter 3: How we protect and store your personal information

I. Protection and safety measures of your personal information

1. 1.We will make every reasonable effort to protect the personal information obtained from you and have a special data safety department to protect the safety of personal information. In order to prevent unauthorized access, copying, modification, transmission, loss, destruction, handling or use of your personal information under an accidental and unauthorized circumstances, we have taken and will continue to take the following measures to protect your personal information.

1）Our web service adopts encryption technologies such as transmission security protocols and provides browsing services through https and other means to ensure the safety of user data during transmission.

2）By adopting encryption technology to encrypt and store users’ personal information and segregate it through segregation technology.

3）When personal information is used, such as personal information display and personal information association calculation, we will adopt various data encryption technologies including content replacement and encryption to enhance the security of personal information during use.

4）We have set up a strict data use and access system, and use strict data access rights control and multiple identity authentication technology to protect personal information and avoid unauthorized use of data. We only allow authorized personnel to access personal information and require them to fulfill the corresponding confidentiality obligations.

5）We adopt special data and technical security auditing and set up several measures for log auditing and behavior auditing.

2. 2.Other security measures taken to protect personal information.

1）Manage and regulate the storage and use of personal information by establishing a data classification and rating system, data security management norms, and norms of secure development of data.

2）Establishing a specialized department of information protection, an information security emergency response organization, and a personal information protection commissioner to promote and ensure personal information safety.

3）Enhance safety awareness. We also hold safety and privacy training sessions to enhance employees’ awareness of the importance of personal information protection.

3. 3.Although aforementioned reasonable and effective measures have been taken and the standards required by applicable laws and regulations have been complied with, given the open nature of the online environment, we cannot guarantee the safety of your personal information when it is transmitted through unsecured channels. Therefore, we strongly recommend that you take active measures to ensure the safety of your personal information, such as: setting complex passwords, regularly changing your account password, not disclosing your account password and other personal information to others, and using information sharing or sharing functions with caution. In addition, you should be aware that AView will only take limited legal responsibilities with effective judicial decisions when your personal information is leaked as a result of your personal disposal actions (such as sharing, etc.).
4. 4.There is always a risk of information leakage in the network environment, when there is an accident, force majeure and other circumstances that lead to the risk of leakage of your information, we will do our best to control the situation, and promptly inform you of the cause of the incident, the security measures we have taken, the security measures you can take on your own initiative and other related information.
5. 5.We will make emergency response plans and immediately start them in the event of user information safety incidents, and strive to prevent the spreading of influences and consequences of safety incidents. Once a personal information safety incident occurs, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and the possible effects of the safety incident, the disposal measures we have taken or will take, the suggestions for your independent prevention and reduction of risks, the remedial measures concerned with you, etc. At the same time, we will promptly inform you with relevant information of the incident through e-mail, letter, phone calling and notices push, when there are difficulties in informing subjects of personal information separately, we will make public announcements by reasonable and effective means. If relevant incident involves personal information of children, we will lawfully inform children and their guardians. At the same time, we will report to relevant authorities in accordance with the requirements of laws and regulations.

II. Storage of your personal information

1. We distinguish between domestic and offshore servers in accordance with laws and regulations, and personal information stored is distinguished between domestic and overseas servers. AView will not transfer your personal information offshore unless required by laws and regulations or have otherwise obtained your express consent.
2. We will continue to store your personal information for you for the duration of your use of AView products or services. If you cancel your account or voluntarily delete your personal information, we will continue to store your specific personal information for a period of time after you cancel your account or delete your personal information in accordance with  E-Commerce Law, Network Security Law and other laws and regulations; for example, the E-Commerce Law of the People’s Republic of Chinarequires that information on goods, services information and transaction information be stored for a period of no less than three years from the date of completion of the transaction. Upon expiration, we will immediately delete or anonymize it.

Chapter 4: Your rights

In accordance with the relevant Chinese laws, regulations and standards, as well as the common practice in other countries and regions, we protect the exercise of your rights of subjects of personal information in accordance with the law, and AView Software provides online access to rights exercise (the specific scope of support may vary), taking AView APP as an example, you can conveniently exercise the following rights of subjects of personal information ：

I. Accessing or correcting personal information

You have the right to access your personal information, but for the exceptions for requirements of the laws and regulations. If you wish to exercise your right of access to data, you may access by yourself through the following means：

1. 1.Your account information: Under AView client, you can enter your personal information and account safety page through ‘User’in the main interface to check and update your avatar, nickname, cell phone number, password, email address and other registered information.
2. 2.Usage of your AView cloud services. Under AView video inspection client, you can view your bundled devices through ‘AView’in the main interface, and you can also view the device model and other product information, as well as the device’s network access, usage and sharing of value-added services, and other usage information through the ‘Settings’ page in the upper right corner of the individual device preview box.
3. 3.Personal information that you cannot access or correct: Except for the information listed above, we are unable to provide you with services of access or correction of part of your personal information, which mainly includes your device information collected to enhance your user experience and ensure transaction security, and personal information necessary for the proper operation of the business functions you have selected. The above information will be used within the scope of your authorization and cannot be accessed or corrected by yourself, but you may contact us for deletion or anonymization.

II. Deletion of personal information

Information that you can remove or delete directly from our product or service pages, including account registration information not necessarily required such as avatars, in the same path as the access or correction path described above.

You may make a request to us to delete other personal information in the following cases.

（1）If our handling of personal information violates laws and regulations；

（2）If we collect and use your personal information without obtaining your consent；

（3）If our processing of personal information violates our agreement with you；

（4）If you cancel your AView account；

（5）If we terminate our services and operations.

If we decide to respond to your request for deletion, we will also simultaneously notify the entities which obtained your personal information from us and request their prompt deletion, except as otherwise required by laws and regulations, or such entities have your independent authorization.

When your information deleted from our services , we may not immediately delete the corresponding information from our backup systems, but will delete it when the backup is updated.

III. Changing the scope of authorized consent or revoking authorization

You may change the scope of your authorization for us to continue collecting your personal information or revoking your authorization by deleting information, turning off a service or feature, making privacy settings inAView Software, or managing application permissions. You may also revoke your authorization for us to continue collecting your personal information in its entirety by canceling your account via the following path:

1. Changing or revoking sensitive permission settings

You can change the scope of consent or revoke your authorization by turning off the GPS geolocation, camera, microphone, and album permissions in the device’s own operating system. We will no longer collect information related to these permissions after you turn them off.

2. Changing or revoking authorized processing of information

Please understand that each business function requires some basic personal information to be completed. After you revoke your consent or authorization, we cannot continue to provide you with the service for which your revoking consent or authorization, and we will no longer process your corresponding personal information. However, your decision of revoking your consent or authorization will not affect the processing of personal information carried out previously on the basis of your authorization.
IV. Cancellation of accounts

You can cancel your previously registered account at any time, you can contact our customer service or do it by yourself through the following ways.

The specific path of AView client is: [User→ User Center → Cancel Account].

Please note that our account cancellation is only available overseas, not domestic, and account cancellation is an irreversible operation. After you cancellation, we will stop providing you with products or services, your rights and interests under your account will be completely erased, and your personal information will be deleted and cannot be retrieved, unless otherwise required by laws and regulations.

V. Constraining information system automatic decision making

Currently, there are no cases in which AView’s business functions are based solely on non-artificial automated decision-making mechanisms, including information systems and algorithms. If in the course of operation we believe it is necessary to use the aforementioned technical means, we will promptly inform you; if you believe that these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will provide a method of appeal without infringing on AView’s trade secrets or other users’ rights and interests or the public interests.

VI. Obtain copies of personal information and request responses

If you are unable to manage your personal information in the manner described above, or if you need to obtain a copy of the corresponding personal information, or if you have other personal information rights claims, you may contact us by sending an email to [[email protected]] or by other means as set forth in this Policy. For security purposes, we may require you to provide a written request or other ways to prove your identity, and we will respond to your request within 15 days after receiving your feedback and verifying your identity.

In principle, we do not charge a fee for your reasonable requests, but we will charge certain cost for repeated requests that exceed reasonable limits according to real circumstances. We may deny requests that are unnecessarily repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes of current practices), pose a risk to others’ legal rights and interests, or are highly impractical (for example, involving the backup of information stored on tape).

According to the applicable laws and regulations and national standards, such as  Network Security Law and Information security technology – Personal information security specification, we may not be able to respond to your request in the following circumstances.

1）In connection with AView’s fulfillment of its imposed by laws and regulations；

2）Those directly related to national security or national defense；

3）Those directly related to public safety, public health, and major  public interests；

4）Those directly related to criminal investigation, prosecution, trial and execution of judicial decisions, etc.；

5）Where there is sufficient evidence that you have malice with subjective awareness or abuse of rights

6）For the purpose of protecting of your or other individuals’ legitimate rights and interests, life safety and property safety and your authorization for collecting such information cannot be obtained for some reason；

7）When responding to your request will lead to serious damage to the legitimate rights and interests of you or other individuals or organizations；

8）Where trade secrets are involved；

9）Other circumstances specified in applicable laws and regulations.

VII. Use of mobile terminal device permissions

1. 1.Location-based services: We will access to get your location information once you open the location permission, and get your surrounding WIFI list information when you add devices based on your location information; if you refuse to provide your location information when you add devices, you will not be able to get your surrounding WIFI list information and achieve community social functions.
2. 2.Camera/camera-based services: you can use the photo/video function to scan the QR code to complete the device addition and upload the avatar after opening the camera/camera permissions.
3. 3.Album (photo gallery) based service: you can use this feature to upload your photos after opening the album permission to change avatars, save pictures/videos, and identify device QR code from the album to complete device addition.
4. 4.Microphone-based services: you can use the microphone to achieve two-way intercom with the device and customize the alarm sound after opening the microphone permission.
5. 5.Service based on storage permission: you can cache the text generated during your use after opening the storage permission, save the images and videos you actively download, call the photo album to select photos, after refusing this permission, you will not be able to use AView services normally.

The above-mentioned services may require you to turn on your storage, camera (camera), album, geolocation (location information), microphone, communication access permission of your mobile device for our collection and use of the information involved in these services. You can check the status of the above-mentioned permissions item by item in your mobile device settings Settings – Account and Security – Permission Management and decide to turn on or off these permissions by yourself at any time. Please note that the above-mentioned permissions will not be turned on by default and will only be used for specific functions or services with your explicit consent. It is important to note that even if you have authorized us to obtain these sensitive permissions, we will not collect information from you when it is not needed for the relevant function or service. Please note that by opening these permissions, you are authorizing AView to collect and use such information to perform the services described above, and if you revoke these permissions, AView will no longer collect and use such information from you and will not be able to provide you with the features described above based on these permissions. However, your decision to revoke your permissions will not affect the processing of personal information that was processed previously based on your authorization.

In addition, in accordance with the relevant laws and regulations and national standards, we may collect and use your relevant personal information without seeking your authorized consent in the following cases:

• Those directly related to national security or national defense and other national interests; those directly related to public safety, public health, public right to information and other major public interests;

（2）Those directly related to criminal investigation, prosecution, trial and execution of judicial decisions, etc.;

（3）For the purpose of protecting your or other individuals’ legitimate rights and interests, life safety, property safety and reputation and yourauthorization for collecting such information cannot be obtained for some reason；

（4）Where the personal information involved  has been made public by yourself；

（5）Where your personal information has been made publicly available in legitimate news

coverage, governmental announcements and other channels;

（6）According to the circumstances necessary for you to enter into and fulfill a contract  with us；

（7）For ensuring the safe and stable operation of the provided products or services , such as identifying and/or fixing failures of such products or services；

（8）Necessary for the conduct of legitimate news coverage；

（9）Necessary for the statistical or academic studies for the purpose of public interests. Whenit publishes the results of academic research or descriptions to the public, the personal information contained in the results is de-identified；

（10）Other circumstances specified in laws and regulations.

The third party services in our service are provided by external third party subjects and we do not have access to information generated during your use of such third party services. Please note that we currently do not actively obtain your personal information from third parties. If in the future we need to obtain your personal information indirectly from a third party for business development demands, we will make clear to you the source, type and scope of use of your personal information before obtaining it, and if our handling of personal information for our business goes beyond the scope of use of your personal information for which when you originally give your consent to third parties, we will obtain your express consent before processing such personal information; in addition, we will also strictly comply with the provisions of relevant laws and regulations and require third parties to ensure the legality of the information provided.

Chapter 5: Third party services

I. Third party services that may involve the collection or sharing of personal information

Our services may access or link to websites or other services provided by third parties, including：

1. You may use the ‘Share’button to share certain information about yourself with third party services. These features may collect information about you (including your log information) in order to function properly as described above；
2. we provide you with links to third party services or websites through advertisements or other means of our services；
3. Other circumstances of accessing to third party services. For example, for the purposes stated in his Policy, we may access SDKs or other similar applications provided by third party service providers (in the following being referred to as ‘Third Party SDKs’) and share certain information about you that we collect in accordance with this Policy with such third party service providers in order to provide a better customer service and user experience. Currently, we have access to the following types of third party SDKs：

（1）For advertising-related services, including ad display, ad data monitoring/statistical analysis, etc.;

（2）For message push services, including phone manufacturer push, inform of specific incidents, customized content recommendations, etc.;

（3）For payment-related services, including order payment, transaction behavior verification, revenue settlement, payment information gathering and statistical analysis, etc.;

（4）For obtaining device location permissions, collecting device information and log information, etc. with your consent;

（5）for third party authorized services, including third party account login, sharing relevant content to third party products, etc.;

（6）For supporting product function modules, including voice recognition, device wake-up, etc.;

（7）For optimizing product performance, including improving hardware configuration capacities, reducing server costs, functional hotfix, etc.;

（8）For related services such as account security, product reinforcement, including network monitoring, domain name resolution (HTTPDNS), anti-hijacking, anti-spam and anti-cheat, encryption and decryption services, etc.

II. Personal information collection and sharing of third party services

1. We will only share your information with relevant third party service providers for legitimate, necessary and specific purposes and will use our best efforts on commercial aspect to require them to meet their relevant confidentiality obligations and take appropriate security measures.
2. You should be aware that, unless otherwise stated, third party services are operated independently by the relevant third parties and that your use of their services or provision  of information to them is subject to their terms of service and/or privacy protection statements (instead of this Policy).

Chapter 6: How we handle personal information of minors

AView takes the protection of personal information of minors very seriously. We do not make age identification a prerequisite for providing products or services to our users, but the nature of our products or services requires that you should be an adult with full civil capacity. If you are a child or other minor under the age of 18, you are requested to ask your parents or other guardians to read this Privacy Policy carefully and to use our services or provide us with information with the consent and under the supervision of your parents or other guardians. If you collect or submit personal information about minors to us through our products or services for purposes such as interacting with children, please ensure that you have obtained the prior authorized consent of their legal guardians.

In cases where we collect personal information from minors with the consent of their parents or legal guardians, we will only use or publicly disclose such information as permitted by law, with the express consent of their parents or legal guardians, or able to protect the minors.

If a parent or legal guardian has reason to believe that a minor has submitted personal information to us without prior consent, or has questions about our approach to protecting the personal information of minors, please contact us through the means listed at the beginning of this Policy.

Chapter 7: Revisions to this Policy

We may make changes to this Policy from time to time. We will not reduce your rights under this Policy or voluntarily adjust the settings you have made regarding your personal information without your express consent. We will post any changes to this policy on this page.

For major changes, we will notify you by notice push, pop-up window, email, etc.

Major changes referred to in this Policy include, but are not limited to：

1）Significant changes in our service model. Such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;

2）Significant changes in our ownership structure, organizational structure, etc. such as change of ownership caused by business restructuring, bankruptcy and merger and acquisition, etc.；

3）A change in the primary subjects of the sharing, transfer or public disclosure of personal information；

4）When there is a significant change in your right to participate in the processing of personal information and its form and manner；

5）When there is a change in the department responsible for handling personal information security, our contact method and complaint channels；

6）When the personal information security impact assessment report reveals the potential of high risk.

Chapter 8: How to contact us

If you have any questions, comments or suggestions about this Policy or matters related to your personal information, please contact us by sending an email to 【supportcsb@

cnjabsco.com】. You may also send a letter as follows：
Address: Building 1, No105, Fulian Industrial Park, Jianhui Road, Hualian Community, Longhua Street, Longhua District, Shenzhen, China
Postcode: 518000

In general, we will reply within fifteen days.

If you are not satisfied with our reply, especially if our processing of personal information has infringed your legitimate rights and interests, you can also make a complaint or report to the supervision departments such as cyberspace administration, communications administration, department of public security and administration for market regulation.

【Appendix】

1. The headings in this Policy are for convenience reading only and shall not affect the meaning or interpretation of any provision.
2. The concepts and terms cited in this Policy shall be interpreted as follows.
3. 1.AView: refers to the video surveillance APP developed by Hongchuan Wulian.

2.AView Software: refers to AView Service Client, AView APP, and other domain names, systems, and software products launched by AView from time to time according to business operation needs. DifferentAView Software may be operated by different AView subjects, the specific circumstances shall be subject to AView Mobile Application Privacy Statement and other separate tips or statements.

3. Personal information: refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information; this interpretation is from GB/T35273-2020 Information security technology– Personal information security specification. The personal information involved in this Policy subject to the descriptions in the body of this Policy.
4. Personal sensitive information: refers to personal information that may endanger personal safety and property safety, and may easily lead to damage to personal reputation, physical and mental health or discriminatory treatment, etc. if leaked, illegally provided or misused. This interpretation is from GB/T35273-2020 Information security technology– Personal information security specification.

The sensitive personal information mentioned in this Policy is subject to the descriptions in the body of this Policy and will be indicated to you in bold and italic form.

5.Personal biometric information: a kind of sensitive personal information, including personal genes, fingerprints, voice print, iris, facial recognition features, etc.This interpretation is from GB/T35273-2020 Information security technology – Personal information security specification.

6. 6.Children: minors under the age of 14, this definition is from the Rules for protection of children’s personal information in cyberspace.
7. 7.Minor: a natural person under the age of eighteen is a minor; a minor over the age of sixteen who takes his or her own labor income as main source of living is considered to be a person of full civil capacity. This interpretation is from Civil Code of the People’s Republic of China(effective on January 1, 2021).
8. 8.Authorized consent: sometimes also expressed as ‘authorization’, ‘consent’, refers to the giving of express consent of specific processing of their personal information by the subjects of personal information, including authorization through positive action, but also authorization through the negative inaction. This interpretation is from GB/T35273-2020 Information security technology  – Personal information security specification.
9. 9.De-identification: refers to the technical processing of personal information without the help of additional information for the result of the inablility to identify or associate to the subject of personal information. This interpretation is from GB/T35273-2020Information security technology – Personal information security specification.
10. 10.Anonymization: technical processing of personal information which the subject of the personal information cannot be identified or associated with, and the processed information cannot be recovered. The personal information after the anonymization is not personal information. This definition is from GB/T35273-2020Information security technology – Personal information security specification.
11. 11.Deletion: refers to the act of removing personal information from the system which involved in achieving the completion of daily business functions concern with, so that it remains irretrievable unavailable for retrieval and inaccessible . This definition is from GB/T35273-2020 Information Security Technology– Personal information security specification.
12. 12.ISO27001: full name entitled GB/T 22080-2016/ISO/IEC 27001:2013，one of the international certification standards of information security management system, which is widely recognized by the industry. Its certification standards can be found on the official website of ISO （https://www.iso.org/isoiec-27001-information-security.html）
13. 13.ISO29151: full name entitled ISO/IEC29151:2017, an international general personal information protection implementation guide, focusing on the protection of users’ privacy data. The certification standards can be found on the ISO official website（https://www.iso.org/standard/62726.html）
14. SDK: also known as software development kit, being generally referred to as a specific collection of software packages, software frameworks, hardware platforms, operating systems and other development tools used in building application software.