SDK Privacy Policy of Imou Cloud Open Platform

Last modified: August 29, 2024

Welcome to use Imou Cloud Open Platform SDK ("SDK")!

This SDK provides developers ("Developer") of smart device management applications (including mobile applications and websites, collectively referred to as "Application") with service capabilities such as device addition/network configuration, video playback, video download and smart recognition. After integrating this SDK into its Application, Developer can provide its Application end-user (“End-user”) with services related to smart device management and Imou cloud. When Developers use this SDK, Hangzhou Huacheng Network Technology Co., Ltd. (“Imou”) will process certain data and information related to the Developer's Application, which may include personal information of End-user. This privacy policy is intended to help Developer and End-user understand the types of personal information Imou collects from End-user and how Imou use and protect the personal information of End-user.

Special Note:

If Developer integrates this SDK into its application, the Developer shall undertake the followings: (1) Developer shall comply with all applicable laws, policies and regulations regarding the collection and use of End-user’s personal information and protect the security of users’ personal information. If Developer believes that the use of this SDK will cause its Application to be non-compliant with applicable laws, policies or regulations, it shall contact us or stop using this SDK.
(2) Developer shall notify End-user of the integration of this SDK in its Applications, as well as the rules governing the collection, use and protection of End-user’s personal information using this SDK (i.e. this privacy policy), in a prominent position in its Application or in other ways that can reach End-user(including but not limited to: providing a link to this privacy policy in a conspicuous place in the Application’s user agreement or privacy policy where the End-user can browse this privacy policy), and obtain End-user’s complete, lawful and continuing consent to Imou’s collection, use and protection of its personal information during the use of the SDK. If the End-user is a minor under the age of 16, or equivalent minimum age in the relevant jurisdiction (refer to “Child” or “Children” below), Developer shall ensure that it obtains the complete, lawful and ongoing consent of the End-user's parents or other guardians to the collection and use the End-user's relevant personal information while using this SDK.
(3) Developer shall provide End-user with an easy-to-operate mechanism for realizing user rights such as accessing, correcting, and deleting his/her personal information, revoking or changing his/her authorization consent, and canceling his/her personal account.
(4) Developer shall ensure that End-user or regulatory authorities will not make any claims, requests, complaints, penalties, etc. against Imou due to Imou’s collection or use of End-user’s personal information in accordance with the provisions of this Privacy Policy. If an End-user suffer any kind of claims, requests, complaints, penalties, etc. due to the collection, use and disclosure of his/her personal information under this Privacy Policy, Developer shall be fully and entirely responsible for resolving the issue; if it causes Imou to suffer any form of losses, Developer shall be responsible for compensating Imou in full.
Imou hopes that Developer’s Application that integrates the SDK collects and uses End-user’s personal information in a legal and compliant manner, but Imou does not know and cannot control how the Developer and its Applications use End-user’s personal information under its control, and therefore Imou should not be held responsible for Developer’s actions. Imou recommends that End-user carefully read the user agreements and privacy policies related to Developer’s Application, and use the Developer’s Applications only after End-user fully understands and agrees to how the Developer collects and uses End-user’s personal information.
This privacy policy applies only to the SDK. The privacy policy of third parties applies to third-party services displayed in the SDK or third-party services linked to this SDK. Although third parties are displayed in or linked to this SDK in certain circumstances, Imou does not know or control third party’s behavior, and therefore Imou will not be responsible for third party’s behavior. Imou recommends that End-user carefully read the user agreement and privacy policy of the Developer’s Application, and use the Developer’s Application only after he/she fully understands and agrees to how the Developer collects and uses End-user’s personal information.
The specific SDK function obtained by End-user is selected by the Developer according to the needs of its Application, which may vary due to the different Developer’s Application used by the End-user. The personal information that this SDK may obtain depends on the specific type/version of the Developer’s Application and the functions used by the End-user. If certain service content is not covered or specific functions are not provided in some Developer’s Application versions, the content of this privacy policy involving the above services/functions and related personal information will not apply.

This privacy policy (“Policy”) will help Developer and End-user understand the following. Developer and End-user are requested to read this Policy carefully and confirm that they fully understand and agree to it before integrating and/or use this SDK:
1.Definition
2.How does Imou collect and use End-user's personal information?
3.How does Imou share, transfer, and publicly disclose End-user's personal information?
4.How does Imou protect and retain End-user's personal information?
5.International Transfer
6.End-User's Rights
7.How does Imou handle children’s personal information?
8.Changes to this Policy
9.How to contact Imou

1. Definition

1.1 Developer: refers to an individual, legal person or other organization that has effectively applied and registered on Imou Cloud Open Platform, and provides various services directly to End-user by developing, creating or obtaining legal authorization to operate applications that integrate this SDK in its own name and independently bears legal responsibility.
1.2 Application: refers to an application and related services that are developed and created by the Developer in its own name, enjoy legal operating rights, operate and independently bear legal responsibilities, and integrate this SDK after being registered on Imou Cloud Open Platform.
1.3 Imou Cloud Open Platform: refers to the website (https://open.imoulife.com/) and the subordinate sub-pages of the aforementioned platform website that owned, controlled and operated by Hangzhou Huacheng Network Technology Co., Ltd., hereinafter referred to as "Open Platform" or "Platform".
1.4 Personal information: refers to any information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person alone or in combination with other information.
1.5 Personal sensitive information: Personal data that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions or offences.
1.6 Client device: refers to the mobile terminal device used by the End-user.
1.7 Children: minors under the age of sixteen, or equivalent minimum age in the relevant jurisdiction.

2. How does Imou collect and use End-user's personal information

By integrating into Developer’s application with SDK via Imou’s cloud open platform, Developer can provide device management service, cloud services, cloud storage services and other services to its End-user. In order to achieve these services, Imou will process following information.

2.1 Device management service

When Developer integrates this SDK into its application and its End-user needs to use the device management service, Imou needs to collect the End-user's device serial number, device password and personal address for the purpose of configuring the device network and adding the device to the Developer's application account. Refusing to provide this information will prevent the End-user from using the device management service normally. The device serial number is the unique identification information of the device. If the End-user needs to modify the device name, configure the device, and perform other management operations on the selected device, he/she needs to provide the device serial number of the corresponding device to Imou, otherwise Imou will not be able to provide device management service to the End-user. Legal basis that permits this purpose is Legitimate Interest.

2.2 Device access to Imou cloud service

When Developer integrates this SDK in its applications and its End-user needs to use the device to access Imou Cloud Services, Imou needs to collect the End-user's device serial number, device IP address, and device MAC address, each of which is the basic information Imou must collect to provide Imou cloud services. If the End-user does not provide this kind of information, the End-user will not be able to use Imou cloud service normally

2.3 Cloud storage service

When Developers integrates this SDK in its applications and its End-user needs to use cloud storage service, Imou needs to collect the End-user's device serial number in order to open a cloud storage channel for the End-user and save the video or alarm message images of the specified device at the corresponding time point in the cloud. Imou will store this information in an encrypted manner, and the End-user can delete this information on its own initiative at any time. Refusing to provide this information will prevent the End-user from using the cloud storage function, but will not affect the End-user's normal use of other functions.

2.4 Smart recognition service

When Developer integrates this SDK in its applications, and the application and end-user’s device is capable of realizing the smart recognition function, and the End-user needs to use the smart recognition function, Imou needs to collect the device alarm message images and image information provided by the End-user on its initiative, in order to compare the device alarm message images with the image information provided by the End-user.

It should be noted that Developer integrates this SDK into its application to provide its End-user with real-time device preview and voice intercom functions, and Imou only performs real-time encrypted transmission and does not store audio or video stream information. End-user can save the information locally on its device through relevant application functions (video download, etc.); audio, video and alarm picture information uploaded by the End-user using the cloud storage function will be stored in Imou’s cloud server, because storage is necessary to achieve this function. Imou will store the information in an encrypted manner, and the End-user can delete the aforementioned information at any time. Unless the End-user chooses to do so or complies with relevant laws and regulations, Imou will not provide the above information to the public or use it for purposes other than this function.

2.5 Client permission usage

System type	Customer-side permissions	Functions and services	Is it necessary	Permission authorization method
Android	ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION	Get customer-side GPS information and implement device connect to network	Yes	The authorization method is determined by the customer-side system developer and developer apply, and is enabled when the final user agrees to grant the developer apply this permission
ACCESS_NETWORK_STATE	Implement connect to network function	Yes
BLUETOOTH_CONNECT, BLUETOOTH_ADMIN, BLUETOOTH_SCAN	bluetooth pairing function	Yes
READ_EXTERNAL_STORAGE, WRITE_EXTERNAL_STORAGE	snapshot, recording function storage to app system album	No
CAMERA	Realize the code scanning function	No
RECORD_AUDIO	Realize intercom function	No
iOS	Location Always and When In Use	bluetooth pairing, softApconnect to network requires location permission, search for current ring device information	Yes
Local Network	SoftApconnect to network requires local network permission, search for current ring device information	No
Photo Library	snapshot, recording function storage to app In the system album	No
Camera	The video call function requires access user camera permissions	Yes
Microphone	Realize intercom function	Yes

2.6 Processing in compliance with applicable laws

Apart from the detail activities specified above, Imou may process End-user’s personal data which is permitted or required by applicable laws without seeking the authorization and consent of the End-user in the following circumstances:

Processing is necessary for the performance of a contract or in order to take steps at Developer’s 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 Imou 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.

Imou may share, assign or disclose End-user’s personal data with Imou’s affiliated companies or third parties in the following circumstances:
1)Upon End-user’s explicit consent:
Imou may share, assign or disclose End-user’s personal data with third parties after obtaining End-user’s explicit consent or where End-user provides initiatively to Imou. End-user shall be fully responsible and liable for the personal data obtained from other resources or from other data subjects.
2)Trusted third parties:
Imou may share, assign or disclose End-user’s personal data with certain trusted third parties that perform business functions for Imou or provide services to Imou, being Imou’s subsidiaries and affiliates; or contractors, service providers, and other third parties Imou use to support its business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which Imou disclose it to them.
3)Required by applicable laws:
Imou may share, assign or disclose End-user’s 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:
Imou may share, assign or disclose End-user’s personal data where there is a merger, acquisition or bankruptcy procedure. Imou will require the successor who holds End-user’s personal data to continue to perform the obligations in accordance with this Policy.
5)Public Interest:
Imou may share, assign or disclose End-user’s 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.

4. How does Imou protect and retain End-user's personal information?

4.1 Data security measures

(a)Imou attaches great importance to information security and privacy protection. Imou strives to take appropriate physical, technical and management security measures to protect personal information and prevent personal information from being accessed, disclosed, used, modified, damaged or lost without authorization. For instance, Imou uses encryption technology to improve the security of personal information and trusted protection mechanisms to prevent personal information from being maliciously attacked, and deploys access control mechanisms to ensure that only authorized personnel can access personal information.
(b)Imou has passed the following certifications related to information security and privacy protection: Information Security Level Protection Level 3 Certification, ISO 27001 Information Security Management System Certification, ISO 27017 Cloud Service Information Security Management System Certification, ISO 27018 Cloud Personal Data (PII) Privacy Protection Certification, ISO 27701 Privacy Information Management System Certification, CSA STAR Cloud Security Certification, ITSS Cloud Service SaaS Service Level 3 Certification and IoT Service Privacy Protection Certification in line with GDPR.
(c)Imou strongly recommends that End-user use complex passwords to ensure account security. Imou will try its best to ensure the security of any information sent by the End-user. Notwithstanding the above, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, Imou cannot guarantee that end-user’s information is under absolute security with the existing security technology. End-user is requested to properly protect his/her personal information and only provide or share it with others when necessary. If the End-user finds that its personal information has been leaked, especially if its account and password have been leaked, the End-user shall contact Imou immediately so that Imou can assist in taking appropriate measures.
(d)If a security incident such as personal information leakage occurs, Imou will handle it as required by applicable data protection law which includes, where required, notifying the incident to the relevant data protection supervisory authority and data subjects.

4.2 The retention of personal data

Imou will retain End-user’s 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 applicable laws and regulations. To determine the appropriate retention period for personal data, Imou may consider the amount, nature and sensitivity of the personal data, the potential risk from unauthorized use or disclosure of End-user’s personal data, the purposes for which Imou processes End-user’s personal data and whether Imou can achieve those purposes through other channels. If End-user wants to learn more about the retention period of his/her personal data, he/she may directly contact Imou at cloud_openteam_intl@imou.com.

5. International Transfers

Since Imou has affiliates around the world to offer services and Imou may store End-user’s personal data on Imou’s servers located in different countries. In light of this, End-user’s personal data may be transferred outside the region or country where End-user uses the Application integrating the SDK, which may have different legal rules and level of protection on personal data. In such circumstances, Imou will take necessary measures to ensure that End-user’s personal data is processed in conformity with the applicable laws, including obtaining End-user’s consent to the cross-border transfer of his/her personal data, signing standard contractual clauses approved by the EU Commission when necessary, and taking appropriate technical security measures to safeguard End-user’s personal data.

6. End-User’s Rights

In accordance with applicable laws and regulations, End-user may have the right to query, correct, delete his/her personal information, withdraw authorization, cancel account or obtain copies of his/her personal information during the use of the SDK. Since Imou does not provide services directly to End-user, End-user may contact to realize the foregoing rights by means of Section 9 of this Privacy Policy.
For security reasons, Imou may take steps to authenticate End-user’s identity before providing access to the personal data. End-user has the right to lodge a complaint with the relevant Data Protection Authority.

7. How does Imou handle children’s personal information?

This SDK is mainly for adults. If the End-user is a minor under the age of 16, or equivalent minimum age in the relevant jurisdiction (refer to “Child” or “Children” below), please be sure to read this privacy policy and the privacy policy of Developer’s Application carefully under the supervision and guidance of End-user’s parents or other legal guardians before using the Application, and use the Application or provide personal information only with the consent of End-user’s legal guardian. If Imou finds it collecting personal information of children without prior verifiable parental or legal guardian consent, Imou will delete that Children’s personal data unilaterally, unless otherwise the processing is permitted by applicable law or deemed necessary for the protection of the Children.

8. Changes to this Policy

Imou will keep this Policy under review and may modify this Policy from time to time. If there is any major changes to this Policy, Imou will notify Developer through different channels, for example, by posting a pop-out notice on the App to notify the major changes or announcing the changes on the main exposure page of the official website of Imou Cloud Open Platform. If Developer does not agree to such changes, it shall stop integrating/using this SDK. If Developer continues to integrate/use the SDK, it shall be deemed that Developer agrees to be bound by the revised Privacy Policy and notify End-user of such changes to obtain complete, legal and valid authorization and consent from End-user for such changes during the use of this SDK. If End-user does not agree to such changes, he/she shall stop using products and applications that integrate the SDK. Developer shall provide End-user with corresponding implementation mechanisms. If End-user continues to use products and applications that have integrated this SDK, it shall be regarded that End-user agrees to be bound by the revised Privacy Policy.

9. How to Contact Imou

If Developer or End-user has any question or comment on this Privacy Policy, please contact Imou through email at cloud_openteam_intl@imou.com, or by mail at:
Hangzhou Huacheng Network Technology Co., Ltd
13th Floor, Building 3, No. 582, Liye Road, Binjiang District
Hangzhou, Zhejiang Province, P.R. China
310053