PRIVACY POLICY

Update!

Our Privacy Policy was updated on June 13th 2019. 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 Sphere Camera]Mi Sphere Camera software and services provided by MADV.

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 Beijing MADV Technology Co., Ltd. and its affiliated companies ("MADV", "we", "our" or "us") collect, use, disclose, process and protect any information that you give us when you use Mi Sphere Camera software and services. Should we ask you to provide certain information by which you can be identified when using Mi Sphere Camera 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 MADV.

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 MADV has access about that individual.

By using Mi Sphere Camera 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 (e.g. General Data Protection Regulation in Europe Union), 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 privacy@madv360.com 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):

• Device information: We will collect the information of your Mi Sphere Cameraera equipment. For example: firmware version, serial number, IP address, camera usage.
• Information specific to you that may be shared during the third-party login: We will collect the third-party login information you use, such as gender, icon, e-mail, user nickname, user signature and user ID.
• Location information (only for specific services/functionalities):We may collect various types of information on your location. For example, GPS information (depending on your setting), time zone settings, language settings.
• Log information: information related to your use of certain functions, apps and websites. For example, network request information, temporary message history, standard system logs, crash information.
• Feedback and contact information: We will collect the feedback and contact information you filled out. For example: product suggestions, problem feedback, your contact details, etc.

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.
• Here are more details on how we use your information (which may include personal information):
• Provide location-based services. When using a MADV device, we may use location information to determine the time zone to ensure accurate display of time on the device. If you turn on the GPS function, we will collect your GPS information. In the image captured by the camera, you can choose to turn off the GPS function in the settings.
• Collect user feedback. The feedback you choose to provide is extremely valuable to help MADV improve our services. In order to track the feedback you choose to provide, MADV may use your personal information to contact you and keep records.

DIRECT MARKETING

We may use your Mi Account ID to provide marketing materials to you relating to goods and services of MADV companies and our business partners which offer network, mobile applications and cloud products and services. We will only so use your personal data after we obtain your prior explicit consent and involve a clear affirmative action or indication of no objection in accordance with local data protection laws, which may require separate explicit consent. You have the right to opt out of our proposed use of your personal data for direct marketing. If you no longer wish to receive certain types of email communications you may opt-out by following the unsubscribe link located at the bottom of each communication or by emailing us at privacy@madv360.com.We will not transfer your personal data to our business partners for use by our business partners in direct marketing.

COOKIES AND OTHER TECHNOLOGIES (only when browsing www.madv360.com)

• What information is collected and how we can use them: Technologies such as cookies, tags, and scripts are used by MADV and our Third Party Service Providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
• Log Files: As true of most websites, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we gather about you.
• Advertising: We partner with our Third Party Service Providers to either display advertising on our website or to manage our advertising on other sites. Our Third Party Service Provider may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. We will obtain your prior explicit consent and involve a clear affirmative action before providing this advertising service to you. If you wish to not have this information used for the purpose of serving you interest-based ads, you may sending your request to privacy@madv360.com.
• Mobile Analytics: Within some of our mobile applications we use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where crashes occur within the application. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.
• Local Storage – HTML5/Flash: We use Local Storage Objects (LSOs) such as HTML5 or Flash to store content and preferences. Third parties with whom we partner to provide certain features on our Sites or to display advertising based upon your web browsing activity also use HTML5 or Flash cookies to collect and store information. Various browsers may offer their own management tool for removing HTML5 LSOs.

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 MADV will only share your personal information in accordance with your consent. Your consent to MADV will engage sub-processors for the processing of your personal information. You should know that when MADV shares your personal information with a Third Party Service Provider under any circumstance described in this section, MADV will contractually specify that the third party is subject to practices and obligations to comply with applicable local data protection laws. MADV 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 MADV 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 MADV’s representatives. Such Third Party Service Providers would be processing your personal information on MADV’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 privacy@MADV.com.

SHARING WITH OUR GROUP’S ECOSYSTEM COMPANIES

Xiaomi works together with a cool group of companies, which together form the Mi Ecosystem. The Mi Ecosystem companies are independent entities, invested and incubated by Xiaomi, and are experts in their fields. MADV may disclose your personal data to Xiaomi or other Mi Ecosystem companies so as to provide you with and improve the exciting products and services (both hardware and software) from the Mi Ecosystem. Some of these products and services will still be under Xiaomi / Mijia / Mitu brands, while others may use our own brand. MADV will take appropriate organizational and technical measures to ensure the security of personal data during the process of sharing of information, including but not limited to the encryption of your personal data. If MADV is involved in a merger, acquisition or asset sale of all or a portion of our assets, you will be notified via email and/or a prominent notice on our website, of any changes in ownership, uses of your personal information, and choices you may have regarding your personal information.

SHARING WITH OTHERS

MADV 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, MADV 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

MADV’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 MADV products and services and on MADV websites. We will use all reasonable efforts to safeguard your personal information.

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 particularly on somebody else's computer or on public Internet terminals, you should always log out at the end of your session.
• MADV 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 MADV 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 after connecting the camera with the APP, go to the shooting page, click on the settings in the upper right corner, pull down to the bottom, click “Restore factory settings” and click OK to complete the operation. 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 privacy@MADV.com

YOU HAVE CONTROL OVER YOUR INFORMATION!

CONTROLLING SETTINGS

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

• Agree/disagree with privacy policy and user agreement;

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 emailing us at privacy@madv360.com.

ACCESS, UPDATING, CORRECTING OR ERASURE 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 write to or email us as soon as possible at the email address below. Email: privacy@MADV.com
• If you are Europe Union user under General Data Protection Regulation (GDPR), you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.
• If you are Europe Union user under GDPR, you have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
• If you are Europe Union user under GDPR, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• If you are Europe Union user under GDPR, you have the right to receive your personal information in a structured, commonly used format and transmit the information to another data controller.

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. This may be done by sending e-mail to privacy@MADV.com. 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 Sphere Camera 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 MADV for this transfer of your personal information

MADV may use overseas facilities operated and controlled by MADV to process or back up your personal information. Currently, MADV has data centers in China 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.

MADV 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 MADV 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 MADV 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 MADV 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. MADV 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.

OUR APPROACH TO MANAGE YOUR PERSONAL INFORMATION UNDER GDPR

If you are Europe Union user under GDPR, MADV will provide systematic approach to manage personal data deeply engages our people, management processes and information systems by applying a risk management methodology. According to the GDPR, for instance, (1) MADV set up a Data Protection Officer (DPO) in charge the data protection, and the contact of DPO is dpo@madv360.com; (2) MADV designate a representative in Europe, and the contact of representative is representative@madv360.com；（3）procedure like data protection impact assessment (DPIA).

CONTACT US

If you have any comments or questions about this Privacy Policy or any questions relating to MADV’s collection, use or disclosure of your personal information, please contact us at the address below referencing "Privacy Policy":

Beijing MADV Technology Co., Ltd.

No.80, Floor4, building17, Yard 30, shixingdajie,

Shijingshan District, Beijing

Email: privacy@madv360.com

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

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