Victure HomePrivacy Policy

Last updated as of [], 2021
Effective Date: [], 2021


Victure Home(the "Product") is a smart device product and service developed, operated and managed by Shenzhen Apeman Innovation Science & Technology Co., Ltd. ("Apeman" or "we") . Our registered address is at 18/F, Henglu E Times Building, No. 159 North Pingji Avenue, Pinghu Sub-district, Longgang District, Shenzhen, China. We fully respect and will protect the privacy of our users. While providing quality services to you, we will collect, use, disclose, store and protect your personal data in accordance with this Privacy Policy (the "Policy"). Through this Policy, we wish to provide you with an introduction to how we process your personal data and to provide you with access to and control over your personal data. 
This Policy will help you understand the following:
I How we collect and use your personal information
II How we use cookies and similar technologies
III How we share, transfer and disclose your personal information
IV How we store and protect your personal information
V Your rights to your personal information
VI How we process children’s personal information
VII Third-party service providers and their services
VIII  How we transfer your personal information globally
IX How we update this Policy

For the purposes of this Policy, "personal data" refers to any information relating to an identified or identifiable natural person. 
Before using this Product and submitting your personal data, please read this Policy carefully, so as to understand our practices with respect to customer privacy. If you have any questions about this Policy, or have any complaints or suggestions, please contact us at the contact information disclosed in this Policy. 


I How we collect and use your personal information
Apeman collects information in order to operate more efficiently and provide you with better product experience. The personal data is collected from (1) your direct provision of personal data, (2) data we record about how you interact with our products, and (3) third parties which we obtain your personal data indirectly.
The information we collect depends on the environment in which you interact with the Apeman, the choices you make, including your privacy settings, and the products and features you use. 
1. Personal data we collect
(1)Personal data directly provided by you

Some of our services will need you to provide us with your information directly:
-    When you are in the process of registering an account, you need to provide your user nickname, email address [regional information] to complete the account registration. 
-    If you make an after-sale or warranty request, you will need to provide the product order information, your contact information, address, email address, mobile phone number, so that we may respond to your request. 
-    During the [login] process, you need to provide your [email address, regional information, cell phone model, cell phone system language] to complete the [login function]. 
(2)Data we record about how you interact with our products
In addition to the information you provide directly, we may also collect information about your use of our services through your device and other means, so as to analyze the status of your use of our products. For example, we may collect:
- Device information: including device attribute information, such as the model of the phone you are using, operating system version, device screen size, unique device identifier, International Mobile Equipment Identity Code IMEI, network device hardware address (MAC); device location information, such as location information obtained through GPS, Bluetooth or WIFI signal; device other information, such as the type of browser, telecommunication carrier, the device setting language, device setting time zone, device application list, unique application number, [phone push code, phone brand]
- Log information and operation record information: including your use of our products or services, your operation record of using various functions of the products, such as registration time, recent login time, logout time, time and number of device additions, use of video viewing, recording, photo taking, intercom, mute, timer function, number of verification code requests, video/photo download records, as well as your IP address, download and installation or use of mobile applications, software information, [crash information]
- Location information. When you turn on your smart device location function and use our location-based services, we may collect and process information about your actual location, so that you will be able to access services without manually entering your own geographic coordinates. We use various technologies to determine your location, including IP addresses, GPS and other sensors that can provide relevant information (such as information about nearby devices, Wi-Fi access points and base stations). 
- Environmental information captured by the camera: including indoor layout, ground object information, distribution of objects, indoor people and pets, etc. Depending on the specific scenario in which you use the product, this information may contain personal data of you or other subjects, including personal facial information, [motion detection information, sound detection information], etc.
- Voice information: the voice information that you produce when you use remote conversation functions, voice information of other individuals having remote conversations with you via our smart device and voice information that you produce when you use the smart voice control function.
Please be noted that due to your use of the Product, the Product may collect information containing others’ personal data, including other persons’ facial and voice information, which will be depended on your use of the Product under certain circumstances. Please obtain the consent of such persons in advance when you use the Product and reasonably expect that such other persons’ information will be collected.

- Bluetooth information:When you use with Bluetooth device connection, this product uses cell phone Bluetooth to search and connect the device.
(3)We obtain your personal data indirectly from a third party
- When you log on the Product using a third party account, we shall, based on your authorization, obtain your nickname, mobile phone number, email address, gender, photo, birth date, domicile, age, current city where you are located and personal statements you provided to the third party platform. 
- When you purchase our products on a third-party e-commerce platform (Amazon), we obtain information about your nickname on the platform, order number, mailing address, payment amount and payment time from the third-party e-commerce platform and payment service provider. 
Please note that in the specific circumstances disclosed above, certain personal data about you may be received and stored by third party service providers working with us. We will use commercially reasonable efforts to ensure that such third parties do not use this information for any other purpose. 
2. How do we use your personal data
When we fulfill our obligations to you under the user agreement and/or service contract, or our bound legal obligations, or we think it is necessary to protect the legitimate interests of us or any third party through evaluation, we will process your personal data for the purposes described in this Policy with your consent. 
We will use your personal data in strict accordance with this Policy and its updated versions. Your personal data is only used for the purposes explicitly stated upon collection and to the extent you agreed. Any use for other purposes shall be subject to your prior consent.
The relevant scenarios of using your personal data are as follows:
(1)To provide you with the functions or features of our products and services :
- We will create an account for you using the user name, email address provided by you, or information about your account on a third party account that we obtain from such third party platform. 
- In order to provide you with video surveillance, video/picture capture, live video, video storage, video download, remote conversation functions, our smart device will take videos and provide you with video content, or transmit sounds/voices in real time based on the way you operate the Product. We take or record such video and sound/voice information only for the purpose of performing the relevant functions of the smart device. Without the consent of you or any other relevant persons, we will not access or process such information, nor use such information to recognize the identity of you or any other person, or use such information for any other purposes.
- This product is equipped with Amazon Alexa, Google Assistant voice services, when you enable intelligent voice services, third-party intelligent voice service providers will collect and process your voice information based on your operation, so that our smart devices can respond to your voice commands. We do not collect, access, or process this voice information in any way.
- This product provides automatic wifi name acquisition, which requires location access to obtain the name of the wifi to which the phone is connected.
- This product provides avatar setting function and scanning QR code function, which requires device camera permission to take photos.
- This product provides the function of saving to the cell phone album, which requires the device cell phone album read/write permission to save and read photo and video files.
- This product provides intercom functions for cell phones and security equipment, requiring equipment microphone privileges to collect and transmit data.
(2)To maintain, improve or enhance the performance of products or services: we use your personal data to maintain the normal operation of products or services, to troubleshoot products or services, to improve the security performance of products or services, and to update the function of products or services, etc. 
(3)To send you selected products: when you purchase our products or services through online sales channels, we will use the address and contact information provided by you to contact you and deliver the products to you. 
(4)To provide after-sale service or warranty service: when you make a request for after-sale service or extension of warranty, we will need you to provide the order and the product information for verification, and to provide the specific contact information so that we may contact you in time. 
(5)Information subscription and push: we will send information and notices to you, including but not limited to verification code necessary to ensure the completion of a service, push notices necessary for using our products or services, news about our products or services, product marketing campaigns and promotions, product or service surveys or other content that may be of interest to you. If you do not wish to continue receiving the information above, you may opt out in accordance with the method provided in the information we send to you. 
(6)Statistical Analysis of Product Use: in order to understand the use of various functions of our products and services, we may conduct statistics and analyze our users' use of our products or services. 
(7)To protect the security of your account and our products or services: we may comprehensively analyze the information we collect and determine the security of your account and trading risks based on your using habit, carry out identity verification, detection and prevention of security incidents, and take necessary recording, auditing, analysis and handling measures according to the law to better prevent security risks such as website phishing, fraud, network loopholes, computer virus, network attack, network intrusion and other security risks and to more accurately identify actions in violation of laws and regulations or the relevant product or service agreements to protect the legitimate rights and interests of you, other users and us. 
(8)To respond to law enforcement requests as required by applicable laws, court orders or government regulations. 
If we intend to use the information for other purposes not specified in this Policy, we will seek your consent in advance. We will also seek your prior consent when we use information collected for a specific purpose for other purposes. We will not provide personal data and behavioral data of users to third parties without their consent. 
We may also provide additional information about our personal data practices through product notes, supplementary privacy statements, or notices before or during data collection. Some of our websites or features may have a separate privacy statement that specifically describes how these websites or features process personal data. If there is a conflict between the notice or the privacy statement of a specific website or feature provided at the time of collecting information and this Policy, the specific notice or supplementary privacy statement will prevail. 

II How we use cookies and similar technologies
1. Cookie

(1)What is a cookie? 
A cookie is a small file that our application or service transfers and stores on your device. The Product may use cookie technology. Cookies may be stored on your device for a shorter or longer period of time, or even years. Except for using cookies set by the browsers, we don't set any cookies in websites, applications or services. 
(2)Cookies we use
Apeman uses cookies or similar tracking technologies to better understand how often you use the product, what happens within the product, cumulative usage, performance data, and overall audience profile of the user group so that we can analyze trends, manage websites, and track user behavior on the site.
(3)Clean /Disable cookies
Managing cookies and cookie preferences must be done within your browsers’ options/preferences. Here are guidelines on how to do this in commonly used browser software:
• Microsoft Internet Explorer
• Microsoft Edge
• Mozilla Firefox
• Google Chrome
• Safari for macOS
• Safari for iOS
(4)More about cookies
For more information about cookies and instructions on how to set up your browser to accept, remove, or disable cookies, see www.allaboutcookies.org. 
2. Beacons and pixel labels
In addition to cookies, we will use similar technologies on our websites such as beacons and pixel labels. For example, we may send you an email that contains a click URL that links to the content of our website. If you click on the link, we will track the click to help us understand your product or service preferences and improve customer service. 
A beacon is usually a transparent image embedded in a website or email. With pixel labels in an email, we may identify whether the email is open. If you do not want your activity to be tracked in this way, you may opt out of our mailing list at any time. 
3. Do Not Track
Many web browsers have the Do Not Track feature, which allows you to send Do Not Track requests to websites. Currently, major Internet standards organizations have no policy in place to govern how websites should respond to such requests. But if your browser has enabled the Do Not Track feature, all of our websites will respect your choices. 

III How we share, transfer and disclose your personal information
1. Apeman may share some personal data with third parties from time to time. Your personal data will not be shared with third parties for their own marketing or business purposes. 
2. Only for the purposes stated in this Policy, some of our services will be provided with the assistance of authorized partners. We may share some of your personal data with our partners to provide better customer services and user experiences. We will share your personal data only for legal, legitimate, necessary, specific, and explicit purposes, and will only share personal data necessary for provision of our services. Our partners are not allowed to use shared personal data for any other purpose. 
Our authorized partners include the following types:
(1)Technical Service Providers: We work with third-party technical service providers who will provide technical support for specific features of our products or services to you, as well as back-office support for our smart devices. In this sense, third-party technical service providers may need to obtain your user name, email address, log and operations, and location information. 
(2)Smart Voice Service Providers: This product is equipped with Google and Amazon Smart Voice Services. When you enable Smart Voice Services, third-party Smart Voice Service Providers will collect and process your voice information based on your actions so that our smart devices can respond to your voice commands. We do not collect, access or process this voice information in any way. If you would like to know how third-party smart voice service providers collect and process your personal data, please visit Google Assistant Privacy Agreement at https://developers.google.com/assistant/console/policies/privacy-policy-guide?authuser=1, Alexa Privacy Agreement at https://www.amazon. com/gp/help/customer/display.html?nodeId=468496&pop-up=1.
(3)Cloud Service Providers: we engage third-party cloud storage service providers, so as to provide you with video and audio content storage services. Please be noted that without your prior consent, neither we nor any of our third-party service providers will access, process or use such information, or to use such information to recognize the identity of you or other persons or for any other purpose. 
(4)Advertising Service Providers: in order to promote our marketing information to you, we may share your email address to third-party advertising service providers, so that they may push marketing information that may be of interest to you. If you do not wish to continue receiving such information, you may opt out in accordance with the methods disclosed within such information;
(5)Message Push Service Providers: We share your email information and device push codes with third party message push service providers to push product or service related information or notifications to you on our behalf.
(6)User data analysis: We may use a third-party analysis service provider (Google Analytics) to analyze your data. Therefore, during your use of this product, the provider may obtain your [Used functions, Information such as the result of the performed operation, the time, frequency and duration of its online activities, and crash log] will be stored in the third-party server. We will obtain data analysis reports based on the above information from the supplier to optimize the performance of our products and provide you with services more in line with your needs. These third-party services and functions may operate independently of us. The privacy practices of relevant third parties, including detailed information about the information they may collect about you, are governed by the privacy statements of these third parties. We strongly recommend that you carefully read these statements on the third party's official website.
3. If the transfer of personal data is involved in a merger, acquisition or bankruptcy liquidation, we will require the new company or organization that hold your personal data to continue to be bound by this Policy; otherwise, otherwise, additional authorization and consent will be obtained from you by said company or organization. 
4. We sign stringent confidentiality agreements with companies, organizations and individuals to which we share your personal data and require them to use personal data in strict accordance with the purposes set forth in this Policy, and take relevant confidentiality and security measures to process personal data.  
5. We will comply with relevant laws and regulations and keep your personal data confidential. We will not disclose your personal data to a public extent we obtain your prior explicit consent or authorization or as required by law. We will only disclose your personal data to the public where the disclosure are required by law, or when we need to comply with a subpoena or other legal process, lawsuit, or when we are mandatorily requested by a government authority. We may disclose your personal data to the public if we believe in good faith that such disclosure is necessary to protect our rights, the security of you or other persons, investigate fraud or respond to a government request.

IV How we store and protect your personal data
1. The personal data we collect will be retained for the minimum period necessary to achieve the purpose of collection stated in this Policy, unless a longer retention period is required by law. We will delete or anonymize your personal data when the aforementioned retention period expires. For example, we will continuously retain your personal data during the period you register and use our products or services. If you cancel your account, we will delete or anonymize your personal data once you have finished account cancellation, unless otherwise required by laws and regulations.
2. If we cease to operate some or all of our products or services for special reasons, we will promptly notify you and cease the collection and processing of personal data of the related products or services, and delete or anonymize personal data in our possession in relation to that products or services, unless otherwise required by laws and regulations. 
3. We take reasonable and practical management and technical measures to protect the information we collect which relates to our products or services. Please note, however, that, although we take reasonable steps to protect your information, no website, internet transport, computer system or wireless connection is absolutely secure. 
4. We have used security measures which are in compliance with industry standard to protect the personal data of you against unauthorized access, public disclosure, use, modification, or damage or loss of data. We will take all reasonably practicable steps to protect your personal data, including the following:
(1)At present, we have taken measures to ensure the security of data transmission and storage, such as encrypting the data itself or encrypting the documents, and we have adopted strict management measures and access restrictions for our servers, which can only be accessed in our LAN environment. 
(2)We have set up authority allocation for internal data access and data export within the company, and we only allow the employees necessary to know the personal data for purpose of processing such information to access such personal data. Where high-sensitivity information such as user privacy is involved, the relevant personal data may be accessed only upon the approval of superior managers;
(3)The security of your information is very important to us. Therefore, we will continue to ensure the security of your personal data, and implement security measures such as encryption throughout the storage and transmission process to prevent your information from being accessed, used or disclosed without authorization. Meanwhile, the details of some encrypted data are not accessible to anyone other than the user. 
5. In the event of a personal data security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the incident, the measures we have taken or will take to deal with it, suggestions that you can take on your own to guard against and mitigate the risks, and our remedial measures to you. We will inform you of the relevant information of the incident in a timely manner by email, letter, telephone, push notice or otherwise. When it is difficult to inform the subject of personal data one by one, we will take reasonable and effective means to issue announcements. At the same time, we will also follow the requirements of the regulatory authorities, and take the initiative to report the handling of personal data security incidents.  

V  Your rights to your personal data
Apeman respects your rights to your personal data. Below is a list of your rights under the law, and how we will protect them. Please note that for security reasons, we may verify your identity before processing your request. 
1. Right to know: we inform you of how we process your personal data by releasing the Policy. We are committed to ensuring the transparency in use of your information. 
2. Right to access: you can directly inquire or access your personal data in our product or service interface. You can login your account at any time through the product or App page, to access your account related personal data, including basic information, operation records, audio and video information, etc. 
You can inquire and access your personal data through the following ways: [Victure home personal information page, app feedback and sending customer service email (email address: app.support@govicture.com) to inquire personal data]. 
3. Right to rectification: you have the right to ask us to rectify or supplement any incorrect or incomplete processing of your personal data (if any). You can directly rectify and modify part of your personal data on the related function pages of products or services. Otherwise, you can contact us via the contact information disclosed herein to request the rectification or supplement of your personal data, if the self-modification channel is not provided. In such circumstances, we will process your request and give feedback in time according to the laws and regulations.
You can correct your personal data in the following ways: [Victure home personal information page, app feedback and sending customer service email (email address: app.support@govicture.com) to correct your personal data].
4. Right to erasure/deletion: You can directly erase/delete your submitted information in the product interface under your account, such as email address, etc. You can contact us via the contact information disclosed herein to request the erasure/deletion of your personal data collected and used by us in violation of our agreement with you (if any), and we will deal with it in a timely manner according to the requirements of laws and regulations. 
You can delete your personal data through the following ways: [app feedback and send customer service email (email address: app.support@govicture.com) to delete personal data].
5. Right to restriction of processing:you have the right to ask us to restrict our processing of your personal data.This means that we can store your personal data, but cannot further process it. We will only keep the data necessary for responding to your request in the future.
You can realize your right to restrict processing by sending an email to the following address [email address: app.support@govicture.com].
6. Right to data portability: you are entitled to obtain your personal data in structured, commonly used and machine-readable formats to the extent permitted by laws and regulations. For example, if you decide to change to a new service provider, you can move, copy or transfer your personal data between our IT system and their IT system in a reliable, secure and easy way without affecting its use.
After providing a formal authorization, you can realize your data portability rights by sending an email to the following address [email address: app.support@govicture.com]
7. Right to object: Even if your data is processed for our legitimate interests, exercise of public authority, direct marketing (including data pooling), and statistical reasons, you have the right to deny creative processing of your personal data by apes. 
You can realize your right of refusal by sending an email to the following address [email address: app.support@govicture.com]. 
8. Right to withdraw consent: If you agreed to our processing of your personal data, but changed your mind later, you may withdraw your consent at any time, and we must stop processing your personal data. You can change the scope of your consent for us to continue to collect your personal data or withdraw your consent by deleting information, turning off device permission settings, changing related product or feature settings, cancelling your account, etc. 
You may also submit your request to withdraw your consent by sending an email to:[email address: app.support@govicture.com]. .
9. If you no longer wish to receive our commercial advertisements, you can unsubscribe at any time by: [app feedback, send customer service email (email address: app.support@govicture.com)]. Right to reject automated decisions: You have the right not to be subject to decisions made by fully automated processing, including user profiling. If these decisions significantly affect your legal rights, you may reject automated decisions by sending an email to the following address: [email address: app.support@govicture.com] and we will respond to your request and take appropriate steps to resolve it if necessary.
10. Right to complaint:You have the right to contact us to make a complaint via the contact information disclosed herein, or make a complaint to the data protection agency in your country about our processing of your personal data.
We will respond to your request within 30 days from the date of receiving your request and communicate with you in an appropriate way. We may extend the aforementioned period (up to 60 days), if necessary, and inform you of the reasons for the extension within 30 days from the date of receiving your request. If we have reason to believe that there is no need to take any measures against your request, we will inform you of our decision within 30 days from the date of receiving your request and explain it accordingly. If you are not satisfied with the reply you received, you can also complain or report to the competent supervisory authority in jurisdiction, or bring a lawsuit to the judicial organ with jurisdiction.

VI    How we process children’s personal data 
1. This product is not intended for children under the age of 16 (or the age stipulated in local legislations of the Member States of the European Union). For such children, we will only process their information with the consent of the minors’ guardian to the extent legally permissible. 
2. We will use our best efforts to verify that a child's personal data has been processed with the consent of their guardian. If we find that personal data has been collected on a child without first obtaining a verifiable guardian's prior consent, we will endeavor to delete relevant information as soon as possible. 
3. Please note that while you use our product with a camera or a smart voice control product, our product, or the relevant smart voice service provider, will photograph or record certain content that may contain personal data about a child, including a child's facial information, voice information, etc., solely due to implementation of the product function. Although we will not access or process this information, we will remind you in a prominent way of what personal data about a child might be photographed or recorded by such function when you activate relevant feature and obtain the explicit consent of you, as the child's guardian, or prompt you for the child's verifiable guardian’s explicit consent.

VII Third-party service providers and their services
1. Our websites, products, and services may contain links to third-party websites, products, and services. You may choose whether to visit third-party websites, products, and services. 
2. We cannot control the privacy and data protection policies of third parties, and such third parties are not subject to this Policy. Before submitting your personal data to these third parties, please refer to their privacy policies.

VIII How we transfer your personal information globally
1. In principle, your personal data will be stored within the territory of European Economic Area (EEA). 
2. As we provide products and services globally. Therefore, your personal data (including the categories of data listed in the Clause “How we collect and use your personal data”) may be transferred to other jurisdictions outside the country/region where you use the Products, or may be accessed by users from these jurisdictions for the sake of our global business.These jurisdictions include, but not limited to, mainland China, the Hong Kong Special Administrative Region of China etc. 
3. When your personal data is transferred to a country outside the EEA, we will ensure that appropriate measures are taken. For example:
­    The country or region where the personal data recipient is located benefits from the adequacy decision made by the European Commission under Article 45 of the General Data Protection Regulation ("GDPR"); or
­    The personal data recipient has  signed the standard data protection contractual clauses which have been approved or adopted by the European Commission pursuant to Article 46 of the GDPR. 
4. In the absence of aforementioned appropriate protection measures, will ask your explicit consent to the international transfer of your personal data, and take encryption, de-identification and other security measures to protect your personal data. 
5. If you would like to obtain the standard data protection contractual clauses or to know more about the protection measures related to the transfer of personal data outside the European Economic Area, please contact us by email at app.support@govicture.com.

IX How we update this Policy
We reserve the right to update or modify this policy from time to time. We will send you a change notification via a message reminder in our app. 
This policy allows adjustments, but without your express consent, we will not weaken your rights in accordance with this policy. 

If you have any questions or concerns about our privacy policies or practices, please contact us at:
Address: 18/F, Henglu E Times Building, No. 159 North Pingji Avenue, Pinghu Sub-district, Longgang District, Shenzhen, China
Email: app.support@govicture.com
You may also contact our European Data Protection Officer (DPO) at:
Email: app.support@govicture.com