Privacy Policy
Last modified: October, 2024
Introduction
Hangzhou CE-soft
Technology Co., Ltd (“CE-soft”, “we” or “us”) respects your privacy and is
committed to protecting it through our compliance with this Privacy Policy (the
“Policy”). This Policy describes how we
process your personal data when you use DMSS (the "App"), or use the service(s) as provided by us or our
affiliates in connection with the App (the “Service”). For specific usage or service scenarios, we may release a dedicated privacy policy to describe
how to process your personal data and exercise your rights.
Please read this Policy
carefully to understand our policies and practices regarding your personal data
and how we will treat it. If you have any issues regarding this Policy, please
contact us at support@cce-soft.com.
Table of contents
1. How We Process Your Personal Data and Purpose
of Processing
2. How We Share, Assign and Disclose Your Personal
Data
3. Third Party Products and Services
4. How We Protect and Retain Your Personal Data
5. How We Protect Children’s Personal Data
6. International Transfers
7. Your Rights
8. Changes to Privacy Policy
9. How to Contact Us
1. How We Process Your Personal Data and Purpose of Processing
We may process several types of data from you,
including data that identifies you personally, such as personal name, physical
address, e-mail address and telephone number, etc. (“Personal Data”). We
may also process data that is about you, but individually does not identify
you, such as demographic data, data about your internet connection, the
equipment you use to access our services and usage details. You have right to
choose whether or not to provide the data we requested. However, we may not be
able to provide you relevant services if you reject to provide your personal
data.
1) Personal
data processing details
|
Activity |
Type
of Data |
Processing
Purposes |
Lawful
Basis for Processing |
|
A. Use of DMSS APP and Cloud |
|
When you sign up with DMSS App for the first time |
Email address; country or region you choose; nickname you use; password
(encrypted); profile photo (if uploaded); |
To allow us complete your registration, communicate with you and
administer your account. Profile photo may be uploaded from local photo album
in your mobile phone on a voluntary basis if you desire to have a more
personalized account, omission to do so, does not affect the running of DMSS
App. |
Consent |
|
When you change the details you used for registration |
Email address; country or region nickname; password (encrypted); profile
photo; |
To allow the changes you have requested for. Refusing to provide such
information may only result in your being unable to use this function, but
does not affect your normal use other functions of DMSS App. |
Consent |
|
When you log in and use services in App |
GPS, mobile device’s operating system, unique model and its unique
identifier, IP address, MAC address, software version, network access mode
& type, latitude & longitude (if necessary), accelerator
(gravity-activated device) and operation logs |
To offer our services to you, maintain our services’ normal operations,
optimize our services and secure the safety of your account. |
To perform contract with you and provide you services |
|
When you add Compatible Hardware |
Hardware SN; Hardware model; Wi-Fi info; Hardware Name; Hardware
password (encrypted); Hardware time zone and DST status |
To process your request to add a hardware to your account and allow
configuration of your hardware. Refusing to provide such information may only
result in your being unable to use this function, but does not affect your
normal use of DMSS App’s other functions. |
Consent |
|
When you use Live View function which provides you a real-time video
display |
Hardware SN; Hardware IP; Hardware Port Information; (real time) Video
Stream |
To provide you with the basic services of video display through DMSS
App. |
To perform contract with you and provide you services |
|
When you use Playback and Video Recording functions |
Hardware SN, Hardware’s Channel ID, Record Files Path, (real time) video
stream |
To store your history record and allow you view it |
Consent |
|
When you activate and configure the settings of the added Compatible
Hardware |
Mac address; IP address; Hardware SN; Hardware model; Hardware firmware
version; Country information (via IP address); Hardware location (via IP);
Date of Hardware register; Hardware channel information; Hardware
offline/online status; Hardware configuration information |
To allow activation of your Hardware and its registration with our
server |
Consent |
|
When you set Hardware name and cover image |
Cover image; Hardware name; Channel information; Hardware model;
Hardware SN |
You can set
device name, change cover image, and view channel name, device model and SN.
The processing of such information is needed for us to allow the changes you
have required for and to inform you about the details of the Hardware added
on your DMSS account. Refusing to provide such information may only
result in your being unable to use this function, but does not affect your
normal use of DMSS App’s other functions. |
Consent |
|
When you enter Hardware password or use the reset function |
Hardware SN; original password (encrypted), your email address (if you
reset password via email |
To allow you
enhance the security of your Hardware by adding a password or reset
your password. Refusing to provide such information may only result in
your being unable to use this function, but does not affect your normal use
of DMSS APP’s other functions. |
Consent |
|
When you use Hardware Share function |
Hardware SN; Email address |
To allow you
the sharing of your Hardware with another user of DMSS App as
requested by you. Refusing to provide such information may only result
in your being unable to use this function, but does not affect your normal
use of DMSS App’s other functions. |
Consent |
|
When you use Delete Hardware function |
Hardware SN; Email and (or) telephone number (only of customers who
sign up with DMSS App via their telephone number). |
To allow the removal of the Hardware from your account on DMSS App
and matched accessory as you requested us for. Refusing to provide such
information may only result in your being unable to use this function, but
does not affect your normal use of DMSS App’s other functions. |
Consent |
|
When you receive notification |
Hardware SN; Push notice ID/alarm snapshot |
To send you
alarm notifications and provide you the services you have requested us for |
To perform contract with you and provide you services |
|
When you use DMSS App’s cloud services to extend your storage capability |
Hardware SN; messages and video record; Hardware channel information |
To allow you
use of the cloud storage service (either free or added value
version). Refusing to provide such information may only result in your
being unable to use this function, but does not affect your normal use of
DMSS App’s other functions. |
To perform contract with you and provide you services |
|
When you use User Experience Plan function |
Browsing history & clicking behavior, email address, mac address and
your unique identifier. Device ID of the phone, location of the phone, app
version number. |
When you
enable user experience plan, you give us consent to collect such information
and help us improve our products and services and analyse your usage of
different functions. Refusing to provide such information may only
result in your being unable to use the user experience program, but does not
affect your normal use of DMSS App’s other functions. |
Consent |
|
When you communicate with us through email or Feedback function |
Text information and images of your communication with us. |
To communicate
with you, provide you with information you request about us, answer your
questions or handle your complaints |
Our legitimate interests to communicate with you and reply your
inquiries/comments |
|
When you de-register from DMSS App and cease to use our service |
Telephone number (only of customers who sign up with DMSS App via
their telephone number), email address. |
To allow us to
complete your deregistration, and to delete all your personal data collected
by us during the period of your use of DMSS App. |
Provide you services |
|
When you use hosting service for device trusteeship purpose |
Email address and your precise geographical location |
To notify the
administrator of hosting service the device and DMSS user, and allow the
administrator to confirm the location of DMSS device. |
Consent |
|
When you request for diagnoses of any abnormal problem in the App |
App logs, fault records, technical data and necessary system information |
To diagnose
the abnormal problem in the App |
Provide you services |
|
Statistical research |
User ID，device ID, region, location, app version |
In order to
improve the App features and enhance your user experience of the App |
Our legitimate interests and provide you services |
|
B. Other uses of your information |
|
|
Performance of contract and legitimate
interests to keep our services updated and improve them |
|
|
We collect records and copies of your correspondence (including email
addresses), if you contact us. We use your contact details to communicate
with you, provide you with information you request about us, answer your
questions or when we handle your complaints. We might use these details
to send important notifications to you, such as changes in our relevant
terms, conditions and policies. Since this information is very important for
you to communicate with us, it is suggested that you receive and read such information |
Performance of contract and legitimate
interests to administer the contractual relationship with you |
|
We may be required by law to collect and share your identifying
information and personal data with public or governmental organizations for
the purpose of compliance with the law, a court order, or to respond to any
government or regulatory request. |
Compliance with a legal obligation |
2)
Video and Audio Data
The App allows you to access and view surveillance
data captured or recorded by Compatible Hardware (as defined in the Terms of
Use). “Surveillance Data” comprises (1) video (and in some cases audio)
recordings or live feeds or streams and still photographic images; (2) readings
or data from physical or virtual sensors (to the extent offered by or included
with Compatible Hardware and supported by the App), including motion detection
sensors, event sensors, temperature sensors, window/door sensors, passive
infrared sensors, water sensors, carbon dioxide sensors and ambient light
sensors.
3)
Processing in compliance with
applicable laws
Apart from the detail activities specified
above, we may process your personal
data which is permitted or required by applicable laws:
Processing is necessary for the performance of a
contract or in order to take steps at your request prior to entering into a
contract.
Processing is necessary for compliance with a legal
obligation.
Processing is necessary in order to protect the vital
interests of data subject or of another natural person.
Processing is necessary for the performance of a task
carried out in the public interest or in the exercise of official authority
vested.
Processing is necessary for the purposes of the
legitimate interests pursued by us or by a third party, except where such
interests are overridden by the interests or fundamental rights and freedoms of
data subject, in particular where the data subject is a child.
Other lawfulness of processing as specified in
applicable laws.
2. How We Share, Assign and Disclose Your Personal Data
We may share, assign or disclose your personal
data with our affiliated companies or third parties in the following
circumstances:
1)
Upon your explicit consent:
We may share, assign or disclose your personal
data with third parties after obtaining your explicit consent or where you
provide initiatively to us. You shall be fully responsible and liable for the
personal data obtained from other resources or from other data subjects.
2)
Trusted
third parties:
We may share, assign or disclose
your personal data with certain trusted third parties that perform business functions for us
or provide services to us, being our subsidiaries and affiliates; or
contractors, service providers, and other third parties we use to support our
business and who are bound by contractual obligations to keep personal data confidential
and use it only for the purposes for which we disclose it to them.
3)
Required by applicable laws:
We may share, assign or disclose your personal
data to comply with applicable legal requirements such as court order, legal
process, including to respond to any government or regulatory authority’s
request or for investigations (e.g. disclosure to prevent crime or fraud, or to
comply with a court order or legislation).
4)
Merger, acquisition or bankruptcy:
We may share, assign or disclose your personal
data where there is a merger, acquisition or bankruptcy procedure. We will
require the successor who holds your personal data to continue to perform the
obligations in accordance with this Policy.
5)
Public Interest:
We may share, assign or disclose your personal
data for public interest purpose, such as to deal with public health
emergencies, or, in case of emergency, to protect the health of natural persons
and the safety of their property.
3. How We Protect and Retain Your
Personal Data
1) Data
security measures
We attach great importance to the security of
your personal data. We have taken appropriate physical, technical and
management security measures to prevent your personal data from accidental
losses and from unauthorized access, use, alteration and disclosure. For
instance, we use encryption technology to improve the security of personal data
and trusted protection mechanisms to prevent personal data from being
maliciously attacked.
2) The
retention of personal data
We will retain your personal data for no longer
than it is necessary for the purposes stated in this Policy, unless otherwise
extending the retention period is required or permitted by law. To determine
the appropriate retention period for personal data, we may consider the amount,
nature and sensitivity of the personal data, the potential risk from
unauthorized use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other channels. If you want to learn more about the retention period of your
personal data, you may directly contact us at support@cce-soft.com.
4. How We Protect Children’s Personal Data
Our Apps are not designed for children under 16
years of age, or equivalent minimum age in the relevant jurisdiction (refer to
“Child” or “Children” below). If we become aware of any personal data related
to Children, we will delete that Children’s personal data unilaterally, unless
otherwise the processing is permitted by applicable law, explicitly consented
by the Children’s parents or guardians, or deemed necessary for the protection
of the Children.
5. International Transfers
Since we have affiliates around the world
to offer you services and we may store your personal data on our servers
located in different countries, including United States, Germany, and
Singapore. In light of this, your personal data may be transferred
outside the region or country where you use the App or Service, which may have
different legal rules and level of protection on personal data. In such
circumstances, we will take necessary measures to ensure that your personal data is processed in conformity with the applicable laws, including obtaining
your consent to the cross-border transfer of your personal data,
signing standard contractual clauses approved by the EU Commission when
necessary, and taking appropriate technical security measures to safeguard your
personal data.
6. Your Rights
You can send us an email at support@cce-soft.com to request exercising your rights in relation to your personal data. You may also object to or request us to
restrict the processing of your personal data. If we process your personal data
based on consent, you may withdraw your consent at any time by contacting us at
support@cce-soft.com. A summary of your
legal rights is set out below
Request access to your personal data (commonly known as a “data subject access
request”). This enables you to receive a copy of the personal data we hold
about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to
have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or
remove personal data by entering into【Account – Delete Account】where there is no good reason for us continuing to process it. You also
have the right to ask us to delete or remove your personal data where you have
successfully exercised your right to object to processing (see below), where we
may have processed your data unlawfully or where we are required to erase your
personal data to comply with local law. However, for specific legal reasons,
such as it is mandatory for us to retain your personal data as required by
laws, we may not be able to comply with your request of erasure but we will
notify you at the time of your request in such circumstance, if applicable.
Object to
processing of your personal data where we are
relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to object to
processing on this ground as you feel it impacts on your fundamental rights and
freedoms. You also have the right to object where we are processing your
personal data for direct marketing purposes. In some cases, we may demonstrate
that we have compelling legitimate grounds to process your personal data which
override your rights and freedoms.
Request restriction
of processing of your personal data. This
enables you to ask us to suspend the processing of your personal data in the
following scenarios: (a) if you want us to establish the data's accuracy; (b)
where our use of the data is unlawful but you do not want us to erase it; (c)
where you need us to hold the data even if we no longer require it as you need
it to establish, exercise or defend legal claims; or (d) you have objected to
our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.
Request the
transfer of your personal data to you or to
a third party. We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format. Note
that this right only applies to automated data which you initially provided
consent for us to use or where we used the data to perform a contract with you.
Withdraw consent at
any time where we are relying on consent to
process your personal data. However, this will not affect the lawfulness of any
processing carried out before you withdraw your consent. If you withdraw your
consent, we may not be able to provide certain Apps or services to you. We will
advise you if this is the case at the time you withdraw your consent.
For security reasons, we will take steps to
authenticate your identity before providing access to your personal data. You
also have the right to lodge a complaint with the relevant Data Protection
Authority.
7. Changes to Privacy Policy
We keep this Privacy Policy under review and may
modify this Privacy Policy from time to time. If we make major changes to this
Policy, we will notify you through different channels, for example, by posting
a pop-out notice on the App to notify the major changes.
8. How to Contact Us
If you have any questions or comment on
this Privacy Policy or our privacy practices, please contact us through email
at support@cce-soft.com.