At HELE,we take your privacy seriously.

Updated September 28,2021

This Privacy Policy for HELE Products and services ("Privacy Policy").

Your Consent:

What information does QCY Compact Digital Camera collect?

QCY Compact Digital Camera collects:

• 1.Setup information you provide

  When you setup a QCY Compact Digital Camera, you will be asked for certain basic information like your email address, your Facebook account information, and your general location (e.g., city or country).

• 2.Video and audio signals and data

  When you use the recording or streaming features of your QCY Compact Digital Camera, we will record and process video and/or audio recordings received from your device, subject to your configuration and settings. If you have enabled AI detection or sound detection, we will record and process video and/or audio recordings upon sensing motion or detecting sound and may send notifications to you regarding the sensed motion or sound. In addition, if you have the recording feature enabled, we will capture, process and retain video, photo, and audio data recordings received from your device for a limited time (for example, 7, 15, or 30 days, depending on your subscription) and you will be able to access, download, and delete those recordings using HELE services during that time. After the subscription period, the recordings are deleted from HELE's systems.

• 3.Technical information from the device

  In order to improve your experience over time, help troubleshoot problems you may encounter, and provide updates to QCY Compact Digital Camera, we store your device information, such as camera model and serial number, hardware and software versions, and mobile phone information like unique identifiers (including IMEI and MAC), operating system, crash logs, error logs, and language settings. In addition, we will collect your mobile phone's IMEI and MAC numbers. This information is used to login and authenticate you to your HELE Product. Further, to improve your experience, we collect but do not associate your account or email with aggregated, non-identified data on functions used and frequency of use.

• 4.Saved and shared content

  Saved and Shared Content: Your QCY Compact Digital Camera can utilize the cloud subscription service to store audio, camera, and video content during a selected subscription period (for example, 7, 15, or 30 days). After the subscription period, the content is deleted from HELE's systems. We have technical barriers to prevent our viewing or hearing your audio, camera, and video content without your intervention, and we do not share your audio, camera, or video content. You may choose to download your content for sharing, including through a third-party application or service, such as Facebook or YouTube that is not controlled by HELE and has its own privacy and service policies. Data protection and privacy laws in your locality may impose certain responsibilities on you and your use of HELE Products. You (not HELE) are responsible for ensuring that you comply with any applicable laws when you use HELE Products. For example, you may need to display a notice that alerts visitors to your home that you are using a HELE Product. Note that recording and sharing clips that involve other people may affect their privacy and data protection rights. .

  We use MobTechSDK service from a third party (Shanghai Youkun Information Technology Co., Ltd., hereinafter referred to as "MobTech") to provide you with message pushing function, social sharing function and SMS verification function. In order to successfully implement these functions, you need to authorize MobTechSDK to provide the corresponding services; after your authorization, MobTech will collect your relevant personal information. For more details on the types of information collected by MobTech, its usage, rules for personal information protection and opt-out mechanism, please refer to the Privacy Policy (www.mob.com/about/policy) on MobTech's website (www.mob.com).

  ShareSDK is a social sharing service provided by MobTechSDK, which supports one-click sharing and third-party login authorization services within 40+ mainstream social platforms worldwide, such as WeChat, Jitterbit, QQ, Weibo, Facebook, Twitter and so on. It not only facilitates the service experience of your end-users, but also provides you with real-time statistical analysis of the number of shares, return flows and intentional shares of your end-users. In order to trace the origin and geographic dimension of your closed-loop sharing function to help you fine-tune your operation, MobTechSDK collects your end-user's personal and sensitive geographic information. In order to mobilize the social platform app on your end-user's device for third-party login and social sharing, MobTechSDK collects your end-user's system list of installed apps. When your end-user needs to share a password, MobTechSDK will read the end-user's clipboard information, which is not collected information and will not be persistent. TASK permission to determine whether your application is front-loaded or not to help determine whether the sharing jump is successful.

  MobPush is an intelligent push service provided by MobTechSDK, which fully supports Huawei, Xiaomi, Meizu, OPPO, VIVO and other vendor-level channels, and is suitable for situations where you need to achieve different message push for different scenarios and end-user groups. In order to push messages to your end-users (including your end-users closing notifications, etc.), the behavior of your end-users will be divided into different groups for accurate pushing, and will form "push reports" and "statistics reports" for you. MobTechSDK will collect your end-user's information, including personal sensitive information about geographic location, by calling the relevant interface of the system. If your end-users do not agree to MobTechSDK's collection of geographic locations, MobPush will not be able to deliver messages to specific groups in the region. In addition, MobTechSDK will collect your end-user's system list of installed applications in order to generate a user profile and provide you with accurate push services.

How does my HELE Product or account interact with third parties?

Any HELE data that you choose to share with a third party is governed by that third party's privacy policy while in that party's possession.

Any data that HELE receives from third-parties (for example, information received from Facebook after you login to your Facebook account to share content) will be processed and stored by HELE and will be treated in accordance with this Privacy Policy. This information may be processed in the same manner as any other data that is a part of your HELE account or the HELE logs. What additional information does HELE collect and store when a user connects a HELE Product to the Internet or creates an account?

Wi-Fi Network Information: To connect your HELE Product to HELE services, including cloud, or to access your HELE Product over the Internet from a computer, a smartphone or a tablet, you may need to connect it to your Wi-Fi network. During setup, the HELE Product will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with HELE's systems and download software updates.

Once connected to your Wi-Fi network, your HELE Product regularly sends the data described in this Privacy Policy (excluding your Wi-Fi password) to HELE to provide you with services. Email Addresses: When you create a HELE account, we collect and store your email address. From that point forward, your email address is used for communications from HELE. In addition, HELE may provide you with the ability to login with alternative credentials, such as a Facebook account.

Basic Profile Information: Your account allows you to provide certain basic profile information like a username of your choice and profile photo. Usernames and profile photos may be shown to others in connection with HELE services. We routinely record log entries and technical information when your mobile device, tablet, PC, or HELE Product contacts our systems.

Related permissions and APIs

1. Camera permissions: For scanning QR codes, adding cameras or smart devices

2. Recording permission: For voice intercom with camera device

3. Positioning permissions: When adding a camera or smart device, the location permission is required to display the WiFi name normally

4. Read and write storage permissions :Used to modify user avatar and save camera image screenshots or videos

5. Read application list permission

5.1 In order to activate the social platform App on your end user's device to achieve third-party login and social sharing, we will collect the information on the installed application list of your end user's system. If you or your end users do not agree to our collection of this information, (ShareSDK) will not be able to implement third-party login and social sharing services for your end users. (http://pingma.qq.com)

5.2 In addition, we will collect your end user's system application list information to generate user portraits, so as to provide you with accurate push services. If you or your end users do not agree to our collection of this information, (MobPush SDK) will not be able to provide you with precise push services.

How does HELE use the information it collects?

We use this information to provide, develop and improve HELE Products and services, including to make assessments and recommendations about products or safety. We may use your contact details to send you this information, to ask you to participate in surveys about your HELE use, and to send you other communications from HELE .

We may also use this information in an aggregated, non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we use aggregated, non-identified information about the number of times users in a particular region use a particular function to help us determine if the function is desired by customers.

We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our systems.

In what circumstances does HELE share my information?

We do not share personal information for any commercial or marketing purpose unrelated to the activation and delivery of HELE Products and services without asking you first.

The following are the limited situations where we may share personal information:

• 1.For external processing

  We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers and systems for technical problems. These technicians (as well as HELE employees) can access certain information about you or your account relating to this work, but these technicians are not allowed to use this data for non-HELE purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video and audio recordings that you have not shared.

• 2.As part of business transitions

  Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request that a purchaser treat our data under the Privacy Policy.

• 3.For legal reasons

  We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, we may disclose information in response to legal process and we may disclose information in response to lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security.

  If you select an outside party for the purchase, installation, or service of your HELE device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a HELE Product from a retailer, the retailer may collect personal information as part of the transaction.

What choices do I have and how can I delete my personal information?

HELE generally stores your personal information on HELE's systems until you delete or edit it, or for as long as you remain a HELE customer, in order to provide you with HELE Products, but your audio, photo, and video files are stored for a limited time (e.g., 7, 15, or 30 days). Your HELE account allows you to delete audio, photo, and video files that you choose before the limited storage time has elapsed. In addition, should you wish to delete your entire account, including all recordings associated with it, contact app@qcymall.com.

As described above, some information is processed and stored directly on the HELE device. All personal information is encrypted as it is transmitted to HELE and cannot easily be accessed. You can access, amend or delete your personal information from HELE's systems through the controls in your account. Because of the way we maintain certain services, after your information is deleted, backup copies may linger for some time before they are deleted, and we may retain certain data for a longer period of time if we are required to do so for legal reasons.

Can the Privacy Policy be changed?

Please note that this Privacy Policy may change from time to time. We will provide notice of any changes by contacting you through the contact information you provide.

How can I contact HELE?

If you have any questions, please contact us at app@qcymall.com.