Update on June 1, 2022

Introduction

This Privacy policy (hereinafter referred to as "the Policy") is used for users (hereinafter referred to as "you") to log in to Sengled Optoelectronics Co., Ltd. and its subsidiary (hereinafter referred to as "our") products and APP services (hereinafter referred to as hereinafter referred to as "our products and/ or services") through registration.

Please carefully read the Policy. Once you check the box below and use our services, it will be deemed that you have understood and expressly agreed to all the terms of the Policy, and the Policy shall immediately become legally binding between you and us.

Important: If you disagree with the Policy, you cannot use our services.

As the provider of Sengled Optoelectronics Co., Ltd and its subsidiary products and the publisher of APP, we attach great importance to your comments and suggestions on our services. Our contact information is shown below.

Company name: Shanghai Bweetech technology co., LTD,

Address: Rm.707, #1, Plaza Jindi, Lane 99, North Huting Rd, Songjiang District, Shanghai, China

Entity code: 91310113MA1GK8MT1G

For personal data protection, please contact our data protection officer. The contact information is as follows.

Address: Rm.707, #1, Plaza Jindi, Lane 99, North Huting Rd, Songjiang District, Shanghai, China

The Privacy Policy will help you understand the following information:

1. About Our Service

2. Your Personal Data Protection

3. Third-party Product and Service

4. Export Control

5. Compensation

6. Disclaimer of Warranty and Liability

7. Copyright Policy

8. Miscellaneous

9. Specific information concerning FancyLink

1. About Our Service

1.1 The specific content of our service is provided by us according to the actual situation, including but not limited to controlling products, providing services, and accessing and modifying above and other data through your registered account. We may make changes to the services we provide in accordance with legal changes or APP optimizations, and you will be notified of the changes.

1.2 Free services such as APP download, installation and update require access to the Internet, so you need to learn the relevant information from the operator, and bear the relevant costs.

1.3 To the fullest extent permitted by law, we are not responsible for the following:

1.3.1 Inaccuracies, errors or faults of the software;

1.3.2 Any loss or damage (including but not limited to any consequential, indirect, incidental, special or disciplinary damage) caused by downloading or using the software or any such inaccuracy, error or fault of the software.

1.4 Form of service

1.4.1 In order to use our products or services, you need to download our APP. When using the APP, we require you to comply with the Policy, and we grant you a limited, personal, non-transferable and non-exclusive license, which means that you can use our products or services only for the purpose of accessing or using them.

1.4.2 When we should stop providing APP, the Policy and the rights stipulated in the Policy should also be terminated immediately. The "Disclaimer of Warranty and Liability" contained in the Policy shall remain valid after the termination of the Policy.

1.4.3 Our APP provides multiple application versions including but not limited to iOS, Android, etc., you shall select the software version that matches the installed terminal device.

1.5 When you agree to register as our user, you should know and observe the following:

1.5.1 You need to ensure that the email account provided is correct. If the information you provided is wrong, which causes you to take risks or take legal responsibilities and adverse legal consequences according to the law, we shall not be liable for it.

1.5.2 You have the obligation to keep your account details and password properly, and use them correctly and safely in strict accordance with the Policy. You should not transfer or lend the account details and password to others. If you find that the account has been illegally used by others, you should inform us immediately. If your password is lost or your account details are stolen due to the reasons depending on you, which causes damage to the civil rights of yourself and others, you shall bear the corresponding responsibilities by yourself, and we shall not bear legal responsibilities.

1.5.3 After you register as our user, if you need to modify or change the personal identification information provided, you should inform us in accordance with this Policy. We may ask you to confirm your identity so that your request could be granted.

1.6 In the process of using our services, you should not use our services in any illegal way, for any illegal purpose, or in any way inconsistent with the Policy.

2. Your Personal Data Protection

2.1 In order to provide our services to you, we may process your personal data. We will only process personal data that is necessary for its concrete, explicit and legitimate purposes as follows:

2.1.1 Your email address. We process your email address in order to create your APP account, store and identify your personal data under this account, and provide after-sales service, information about controlling functions. We will send you promotional messages with your consent, or you may choose not to accept such messages. This personal data is processed on the legal grounds of executing and performing a contract between you and us.

2.1.2 Equipment information. It includes the operating system type and other basic information of identification device. We process this kind of information only to provide you with appropriate services on the legal grounds of executing and performing a contract between you and us.

2.1.3 Information related to your application usage. It includes application basic information, such as application ID information, SDK version, system update settings, application settings (region, language, time zone, font), and application status record (e.g. downloading, installing, updating, deleting). We collect above information only to ensure that the services you enjoy can run well on the legal grounds of executing and performing a contract between you and us.

2.1.4 Log information related to your application usage. It refers to information related to your use of certain features, apps, and websites of our products and/or services. For example, MAC address, Wi-Fi signal strength, Wi-Fi name, cookies and other anonymous identifier technologies, Internet protocol (IP) addresses, network request information, standard system logs, crash information, log information generated by using the services (such as registration time, access time, activity time, etc.). We use this information to provide you with customer service and product support, handle your questions or requests for device and services, improve services, and monitor the quality and types of customer service and product support we provide to customers. This personal data is processed on the legal ground of executing and performing a contract between you and us.

2.1.5 Payment Information. When you purchase our product from our website, you鈥?/span>ll be asked for certain payment information (your name, shipping address, billing address, phone number and payment method). We collect above information only for your payment charge on the legal grounds of executing and performing a contract between you and us.

2.2 How we process your personal data

The purpose of processing personal data is to provide you with our products and/or services, develop our products and/or services and ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:

2.2.1 Providing, processing, maintaining, improving and developing our products and/or services to you, such as delivery, activation, verification, after-sales, customer support.

2.2.2 Advertising our products and/or services provided that your informed knowledge and consent has been granted to us when applicable.

2.2.3 Implementing and maintaining security safeguards for the purpose of preventing loss and fraud, such as assisting in identifying users, verifying the user identity. We use your information for anti-fraud purposes only when the following two conditions are met: it is necessary; and the data used for evaluation is in accordance with our legitimate interests to protect users and services.

2.2.4 Handling your questions or requests about device and services, questions, or requests, such as answering customer inquiries, sending system and application notifications, managing your activities.

2.2.5 Internal purposes, such as data analysis, research, and development of statistical information related to the use of our products or services to better improve our products or services. For example, machine learning or model algorithm training is performed after de-identification processing.

2.2.6 Storing and maintaining information related to you for our business operations (such as business statistics) or for fulfilling our legal obligations.

2.2.7 Deleting data according to our Retention Policy (section 2.6.2 below) and your requirements.

2.2.8 Other purposes with your consent.

2.2.9 Here are more detailed examples on how we use your information (which may include personal data):

(1) Activating and registering our products or services purchased by you.

(2) Creating and maintaining your account. Personal data collected when you create an account through mobile devices, is used to create the personal account and profile page for you.

(3) Provide services.

(4) Verifying user identity. Avoid unauthorized login.

(5) Collecting user feedback. The feedback you choose to provide is valuable in helping us make improvements to our services. In order to follow up on the feedback you have chosen to provide, we may correspond with you using the personal data that you have provided and keep records of this correspondence for problem solving and service improvement.

(6) Send notices. From time to time, we may use your personal data to send important notices, such as notices about purchases and changes to our terms, conditions, and policies. Since we may send critical notices, we recommend you not to refuse the receipt of such notices.

2.2.10 How we use cookies and other technologies

Log files: As true of most websites and apps, we gather certain information and store it in log files. This information may include Internet protocol (IP) addresses, device MAC address and operation logs. We do not link this automatically collected data to other information we gather about you.

Provided it does not constitute information directly or indirectly identifying an individual we treat information collected by cookies and other technologies as impersonal information. Where Internet Protocol (IP) addresses or similar identifiers directly or indirectly identifies an individual we treat such information as personal data and process them in accordance with the Privacy Policy, GDPR and other applicable laws.

2.3 How we transmit, transfer and disclose your personal data

We promise not to offer, sell or rent out to any irrelevant third party, share or transact with or otherwise transfer or make available to any irrelevant third party any personal data unless we obtain the prior consent from you or such third party that provides to you services independently or jointly with us. Any third party will be forbidden to access all your personal data. We will also prevent any third party from collecting, editing, selling or freely spreading your personal data in any way.

2.3.1 Data transmission

We may sometimes transmit your personal data to third parties (however only as described below) to provide or improve our products or services. If you no longer wish to allow us sharing the data as provided below, please contact us.

(1) Transmitting data to third-party service providers and business partners To help us provide you with products and services described in the Policy, with the approval of our data protection officer, we can transmit your personal data to our third party service provider when necessary, provided that we fully comply with the requirements of GDPR and other applicable personal data protection laws.

2.3.2 Data migration

We will not transfer your information to any subject except in the following cases:

(1) Where you request for transfer voluntarily;

(2) Where we have obtained your explicit consent; or

(3) If we are involved in the merger, acquisition, or sale of all or part of our assets, we will notify you of any change in personal data by e-mail and/or posting a prominent notice on our websites.

2.3.3 Disclosure

In accordance with legal requirements, legal procedures, litigation and/or requests from government institutions, we may need to disclose your personal data. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you strictly following requirements and procedures of applicable law.

In order to enforce our terms or protect our business, rights, assets or products, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the product, violations of our terms or policies or other harmful or illegal activities), we may also disclose information about you. For the avoidance of doubt, we may collect, use or disclose your personal data without your consent if it is and only to the extent it is expressly permitted under applicable data protection laws This may include providing your personal data to government institutions; communicating with third-party partners about the reliability of your account to prevent fraud, violations, and other harmful behaviors.

In addition, we may share your personal data with:

(1) our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advices; and

(2) investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to our entity; and

(3) any other third party, if authorized by you to do so in relation to a specific disclosure.

2.4 Your rights to control your personal data

2.4.1 Control setting

We provide you following ways to restrict the collection, use, disclosure, or processing of your personal data and control your privacy settings:

(1) Sign in or out of your account; and

(2) Consent and withdrawal of privacy authorization; and

(3) Unsubscribe your account. Special note: If you unsubscribe your account, you will permanently and irrecoverably lose all the data stored in your account.

You may also tell us your thoughts at any time by writing to us or emailing us.

2.4.2 Your rights to your personal data

Depending on national or regional laws and regulations applicable to you, including GDPR, you have rights to control your personal data processed by us, including access, rectification, erasure of your personal data, restriction of personal data processing, withdrawal of your previous consent concerning your personal data, deletion of your account in our APP. You may exercise any of your rights independently. If you have any doubt or difficulty in exercising your rights, please contact our data protection officer.

The Privacy Policy requires that your request satisfies applicable laws and regulations and the following conditions:

(1) Your request should be in writing or by email (unless the local law explicitly recognizes the oral request);

(2) Provide sufficient information to enable us to verify your identity and ensure that the applicant is the subject or legally authorized person of the requested information.

(3) Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

a. Right to access

You have the right to inquire whether we process your personal data and request for a copy of your personal data. However, we can charge you a certain fee according to the increase of management cost.

b. Right to rectification

You are entitled to correct your personal data or request us to make corrections. To help you exercise this right, we provide you two ways, i.e. on-line independent correct and request for correction:

(1) You can make corrections of some of your personal data directly in our APP.

(2) If you have any difficulty in exercising this right or where the on-line independent correction is not authorized or unavailable, you can request us to make corrections.

c. Right to erasure

Based on the requirements of applicable laws, you have the right to request the deletion of your personal data. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures.

d. Right to object

Based on the requirements of applicable laws, you have the right to object to processing of your personal data in certain cases.

e. Right to data portability

You have the right to data portability if processing of such data is carried out by automated means and we have obtained such data from you based on your consent or for the purpose of concluding a contract. If you opt to exercise this right, we will transmit at your request a copy of the data submitted by you to another data controller.

f. Withdrawal of consent

If you have given us your explicit consent to process your personal data, it may be withdrawn by you at any time. Should you intend to change the scope of authority relating to certain functions, you can modify your personal settings through your APP or on the related setting interfaces contained in our products and/or services. Alternatively, you can withdraw all authorizations upon us to continue collecting your personal data by unsubscribing your account. If you have any difficulty in doing this, please contact our data protection officer.

We will no longer collect your personal data and you will not receive corresponding services from us when you withdraw the authorization relating to collection of personal data. However, you recognize and agree that the withdrawal of your consent or authorization will not affect the validity of our processing and storage carried out on the basis of the consent up until the point of withdrawal unless you exercise the aforementioned 鈥?/span>Right to erasure鈥?/span>.

g. Right to unsubscribe

You have the right to unsubscribe your account. Please unsubscribe your account prudently. After you unsubscribe your account, we will no longer provide to you all our products and services and all your information, data and records of your use of our products and services with such account will be deleted or anonymized unless otherwise specified in applicable laws and regulations.

h. Restriction of processing your personal data

You have the right to obtain from us the restriction of processing your personal data. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal data under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.

2.5 Your right to complaint

If you consider that our processing of your personal data does not meet requirements of applicable law you are entitled to lodge a complaint. You may approach your national Data Protection Authority by filing a complaint.

2.6 How we store and protect your personal data

We are always committed to keeping your personal data secure. In order to prevent your information from disclosure, destroy, misuse, unauthorized access, unauthorized disclosure or modification risks, we have formulated corresponding rules and regulations and taken corresponding measures, including multi-level protection measures including technical security measures, supporting organization and management system.

2.6.1 Safeguards

To create a secure environment for personal data processing and guarantee the privacy and integrity of data processing, we have applied the Transport Layer Security protocol and other encryption technologies to prevent our transmission link from sniffing, eavesdropping and intercepting in the various ways.

All your personal data is stored on secure servers, and protected in controlled facilities. We classify your information based on importance and sensitivity, and ensure that your personal data has the required level of security. We have special access controls for cloud-based data storage, and we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal data. We also check that appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and wherever necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third party service providers who access your personal data are subject to enforceable contractual obligations of confidentiality.

We conduct security and personal data protection training courses and tests to enhance our employees' awareness of the importance of protecting personal data. We will take all practicable and legally required steps to safeguard your personal data.

Should a personal data security incident occur, we will notify the breach to the relevant data protection supervisory authority and, where applicable to data subjects and handle the incident as required by applicable data protection laws.

If you detect the leakage of your personal data, please contact us immediately. Hence, we can take countermeasures to protect the privacy of your personal data.

2.6.2 Retention policy

(1) We retain personal data only for the purpose necessary to provide a specific product or service under the Policy and to ensure that such service meets the relevant legal requirements.

(2) The longest retention period of personal data processed is permanent. We will cease to retain and delete or anonymize personal data once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding product or service. An exception to this is personal data that we are processing for public interest, scientific, historical research or statistical purposes or requirement to store the personal data applies under law to which we are subject.

2.7 Protection of minors

We consider it the responsibility of the parent or guardian to supervise the child's use of our products or services. However, we do not offer services/ products directly to a child or use personal data of children. We use proper measures enabling us to make sure that personal data of children is not processed by us. If we find out that personal data has been collected from children, we will immediately delete that personal data.

If you are a parent or guardian and you believe that the minor has provided us with personal data, please contact us to ensure that the personal data is removed immediately and that the minor is unsubscribed from any of the applicable services.

3. Third-party Product and Service

3.1 The products or services we offer include products or services of third parties, which may be accessed in the form of an SDK or a link to a third party website. They may also collect personal information about you in your use.

3.2 When you use our services or require us to provide specific services, you understand and agree that the software may call a third-party system or support your use or access through a third party, and the results of use or access will be provided by the third party.

3.3 To ensure your legitimate rights and interests, please be sure to carefully read the relevant user agreement provided by any third party in the use of these third party products or services. We are not responsible for the use by third parties of the personal information they collect from you and have no control over this use. Any and all your use of third party applications is not our responsibility. We shall not be liable for any disputes or disagreements arising therefrom. Our Privacy Policy will not apply to these third party services.

3.4 The SDK we currently use is Bugly SDK锛?/span>for statistical analysis purposes, please refer to this link: https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56. The types of personal information collected by this SDK are: device information (IMEI/Mac/android ID/IDFA/OPENUDID/GUID/SIM card IMSI/geolocation information).

3.5 You should make your own judgment on resources such as mobile applications in our products or services, and bear all risks arising from the use of related resources. We can鈥?/span>t and will not shoulder the responsibility for any loss or damage due to aforementioned risks.

4. Export Control

You agree not to export any part of the application or any derivative thereof provided to you in any way, unless necessary licenses and approvals are made in accordance with applicable export laws, regulations and rules.

5. Indemnification

You hereby agree to indemnify, hold harmless and defend us and our affiliates from and against any kind or nature of responsibility, loss, injury (including death), demand, lawsuit, cost, expense or claim (including but not limited to attorney fees) arising from or related to your use or possession of this application.

6. Disclaimer of Warranty and Liability

To the extent permitted under applicable laws, we and our affiliates make no warranty, express or implied, on quality, performance, merchantability, suitability for a particular purpose or non-infringement. Any oral or written advice or information provided by us does not constitute any guarantee, and, to the extent permitted under applicable laws, you have no right to rely on any such advice or information. The disclaimer of warranty and liability is the foremost condition of the Policy.

7. Copyright Policy

7.1 Any text, pictures, graphics, audio and/or video data included in the software or services provided by us are protected by copyright, trademark and/or other property ownership laws. Without the consent of the relevant right holder, the above information shall not be published, played, adapted or redistributed for the purpose of playing or distributing or for any other commercial purpose in any media, directly or indirectly.

7.2 All rights in software (including but not limited to any text, pictures, graphics, audio and/or video data contained therein) provided by us shall be vested in such software's copyright holder, and without permission from such holder, you shall not reversely engineer, decompile or disassemble such software.

8. Miscellaneous

8.1 We solemnly remind you of the clauses in the Policy that exempt us from liability and restrict your rights. Please read them carefully and consider the risks on your own. Minors should be accompanied by their legal guardians to read the Policy.

8.2 The validity, interpretation and dispute resolution of the Policy shall be regulated by the Chinese laws. In case of any dispute or controversy between us, it shall first be settled through friendly negotiation. If negotiation fails, you hereby agree to submit such dispute or controversy to the competent people's court in the place where we are located.

8.3 In case any provision of the Policy becomes invalid or unenforceable for whatever reason, the remaining provisions of the Policy shall remain valid and binding on both parties.

9. Specific information concerning FancyLink

What information does FancyLink collect?

FancyLink collects:

•Information input during setup

•Video and audio signals and data

•Technical information from the device

•Shared content

Video and audio signals and data: When you enable the recording or streaming features of your FancyLink, we may record and process video and/or audio recordings from the device, subject to your configuration and settings. This may include capturing and emailing to you portions of this data as part of a notification or analyzing the data to identify motion or other events. We may process information from your FancyLink so that we can send you alerts when something happens. In addition, if you have the recording features enabled, we will capture, process and retain video and audio data recordings from your device for the duration of your recording subscription period (for example, 7 or 30 days) and you will be able to access those recordings using the Services during that time.

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with FancyLink we record your FancyLink model and serial number, software version, and technical information such as Wi-Fi signal strength.

Saved and Shared Content: You may save and may choose to share certain content like video clips, live video streams, images, captions, and comments for other people to access using the Services. We will collect and store information that will allow us to save or share your content as directed by you through the Services.

Data protection and privacy laws in your country may impose certain responsibilities on you and your use of FancyLink. You (not Sengled) are responsible for ensuring that you comply with any applicable laws when you use FancyLink. For example, you may need to display a notice that alerts visitors to your home that you are using FancyLink. Note in particular that recording and sharing clips that involve other people may affect their privacy and data protection rights.