Welcome to this Arkon APP!

Arkon APP (hereinafter referred to as ”this App”) is a mobile app published by Hangzhou Microimage Software Co., Ltd. ("Arkon", ”we”, ”ours” or ”us”). This Privacy Policy ("Policy") has been designed to inform you how this APP collects, stores, uses and shares your personal information and your rights within its application scope. This policy is applicable to all the services we provide to you through this APP and the functions contained in the services (hereinafter referred to as ”our product and/or services”).

We will do our best to protect your personal information and we promise that we will take appropriate security measures in accordance with the industry mature security standards.

Before further reading and understanding this Policy, it is important to note that this Policy does not apply to services provided by other companies or individuals ("Third Party Services "). For the convenience of users or for cooperation based on advertising, etc., our products and/or services may contain third-party services or their links; However, as third parties will independently collect and process your personal information beyond our control, we are not liable for the services of third parties unless otherwise provided by law. You need to read and refer to the privacy policies of these third parties and make your own judgment on whether to use their services.

This policy is the basic legal document for you to use our products and/or services. We hope you to carefully read and make sure that you have fully understood the content of this policy before using our products and/or services. We hope that you can make an appropriate choice based on your own understanding. If you continue to use our products and/or services after we update this Policy (we will inform you of the update in a timely manner), you agree to the contents of this Policy (including the updated version) and to our collection, use, storage, disclosure and transfer of your personal information in accordance with this Policy.

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

I. The information we collect and use

This APP include some core functions, including real-time video viewing, etc. We may collect, save and use some information about you to achieve these functions. If you do not provide this information, you will not be able to enjoy our products and/or services.

Our products and/services may also include some additional functions. \ If you use these additional functions, we will collect relevant personal information based on the additional functions you choose to use. If you do not provide such personal information, you can still use the core functions related to our products and/or services, but you will not be able to use the corresponding additional functions.

During the process you using our products and/or services, in order to provide to you or optimize our products and/or services, and protect the security of your account, we will collect information that you voluntarily provide or the information arising from your use of our products and/or services as follows:

1. When you connect your device using this APP, you can search for your device in the APP through the mobile hotspot or device hotspot or connect your device and your mobile phone to the same Wi-Fi. We do not collect your personal information during the process of connecting the device to the APP.

2. After the connection with this APP, you can watch the videos shot by your device in real time through this APP. During this process, we do not collect any of your video information.

3. You can unbound the device using this APP, or upgrade the software of the bounded device through the APP. During this process, we will not collect your personal information.

4. Please understand that when you using this APP and related services, we will receive and record the device you use and also its location-related information pursuant to your prior consent granted during the APP installation and use process Such information includes your mobile phone model, browser type, International Mobile Device Identity (IMEI), operating system version, hardware address (MAC), software version, IP address, network access mode and type, and operation log information. Please understand that such information is necessary for our products and/or services and the normal operation of this APP. For example, when you use our services in remote connection, we need to collect your IP address to determine the approximate location of your device, so that we can arrange a server for you to provide you with fastest access speed.

5. When error happens in this APP, we will collect the device attributes (including your hardware model, operating system version, equipment configuration, unique device identifier, international mobile equipment identity code IMEI, network equipment hardware address MAC), the software use record, software click record, logs about software crashes or blinks. Please understand that we collect such information to figure out the cause of errors and we will only collect it when errors occur.

6. Client services: We will provide product/service consultation, use support, after-sales service and other customer services through telephone, online system and other ways. In order to assist you to solve your problems or record the solutions & results as soon as possible, we may collect and save the communication/phone records with you and related contents (including account information, bounded product information, any other information you provide in support of the facts, or any contact information you provide), as the case may be. We may use your account information if you consult, complain or provide suggestions regarding specific orders.

7. Safety security and maintenance services: pursuant to the laws and regulations including the PRC Network Security Law, in order to protect the security of your account and system operation, we will collect relevant information generated during your use of our products and/or services, including: When you use this APP to manage your bounded devices, we will automatically receive and record the information related to such devices, including product type, model, firmware number, MAC address, system version number and system settings. Please understand that we will rely on such necessary information to provide you with services and ensure the safe operation of your devices.

8. Please note that individual device information, log information, etc. is information that cannot identify a specific natural person. In case we combine this kind of information with other information to identify a specific natural person identity, or combine such information with personal information, we will anonymize and de-identify such personal information, unless otherwise authorized by you or required by laws and regulations.

9. Specific application permissions are explained as follows:

Android:

 

IOS:

II. Rules of use of your personal information.

We will use your personal information in accordance with the following rules:

1. We will follow this Policy when using the information.

2. Please note that all personal information provided by you when using our products and/or services will continue to be deemed as authorized for use byus during your use of our products and/or services, unless you delete it, refuse to collect it through your account settings or system settings.

3. We will analyze the statistics on the usage of our products and/or services and may share such statistics with the public or third parties to demonstrate overall usage trends of our products and/or services. But these statistics do not contain any personal information of users.

4. In case we need to display any of your personal information, we will desensitize your information by means of content replacement and anonymous processing to protect your information security.

5. We will always get your prior permission by means of checking list if in some cases we need to use your personal information in any scenarios not listed in this Policy, or use any information collected for a specific purpose in any other scenarios.

 

III. Third Party Services

This APP and its related services may be invert or be linked to websites or other services provided by third parties include:

1. You can use the "Share" button to share some of your information to Third Party Services. These functions may collect your information (including your log information) and may install COOKIES to properly run the above features;

2. In order to achieve the purpose of this Policy, we may invert SDK or other similar applications (hereinafter generally referred to as the "Third Party SDK"), and we may share some of your information collected in accordance with this Policy to such Third Party Services providers, in order to provide better service and user experience to you. At present, the Third party SDK is mainly used to optimize product performance, including improving the capability of hardware distribution network, reducing the cost of server, and functional hot repair, etc.

We will only share your information with relevant Third Party Services providers for legitimate, necessary and specific purposes, and will use our best commercial efforts to require them to perform relevant confidentiality obligations and take corresponding security measures. Unless otherwise stipulated, the Third Party Services are operated independently by the relevant third parties; Your use of their services or provision of information to them is subject to their terms of service and/or privacy policies.

The Third Party SDKs are of follows:

 Android

 

IOS

 

IV. You fully understand that we do not need your prior consent for the collection or use of your personal information under following circumstances:

1. Situations directly relevant to national and national defense security;

2. Situations directly relevant to public safety, public health and major public interest;

3. Situations directly relevant to criminal investigation, prosecution, trial and execution of judgment, etc.;

4. Such collection and use is for the purpose of protection or your or other individual’s lives, properties and other substantial legitimate interests and at the same time difficult to get such consent

5. Such information is publicly disclosed by yourself;

6. Such information is collected from legally publicly disclosed information, such as legitimate news reports and government information disclosures;

7. Such information is necessary for sighing contracts based on your requirements;

8. Such information is necessary for the safe and stable operation of this APP or its functions and services, such as discovery or disposal of the errors of this APP;

9. Other situations stipulated by laws and regulations.

 

HOW WE SHARE, TRANSFER OR DISCLOSE YOUR PERSONAL INFORMATION

I. Share

1. We will not share your personal information to any other entities, organizations or persons other than Arkon, except:

(1) Arkon has already get your or your guardian’s express authorization or permission;

(2) It is required by judicial authorities, or administrative authorities, according to the legislative procedure requirements;

(3) When Arkon need to bring lawsuits or arbitrations against users to protect its own legitimate rights;

(4) When protecting Arkon and its affiliates, Arkon users and public interests from injuries, to the extent permitted by laws and regulations;

(5) In order to facilitate specific functions or services, we may share specific information with Third Party Services providers according to this Policy, License Agreement, and other agreements agreed by Arkon and you; we will only share your information for legitimate, necessary and specific purposes. We will require Third Party Service providers with whom we share information to perform confidentiality obligations and take appropriate security measures.

(6) Other conditions required by PRC Network Security Law and other applicable laws and regulations.

2. You may share your video, location information and identity information, etc. with specific or nonspecific objects. In case any of your sharing leads to information leakage and other serious circumstances, Arkon will not bear relevant legal liabilities thereof.

II. Transfer

1. After obtaining your express consent, we may transfer your personal information to other parties;

2. In the case of merger, acquisition or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this Privacy Policy; otherwise, we will require the company or organization to seek authorization from you again.

III. Disclose

We will only disclose your personal information under following circumstances:

1. After obtaining your explicit consent;

2. When required by applicable laws and regulations, legitimate procedures, or the compulsory requirements of governmental authorities.

I. Protection and security measures

1. We have taken and will continue to take the following measures to protect your personal information:

(1) The user's personal information is encrypted and saved by encryption technology, and isolated by isolation technology.

(2) When using personal information, such as display or association computing, we will use various data desensitization technologies including content replacement, encryption desensitization and other technologies to enhance the security of personal information in use.

(3) Strict data use and access system to protect personal information and avoid illegal use of data. We only allow authorized personnel to access personal information and require them to fulfill the corresponding confidentiality obligations.

(4) Conduct special data and technology security audit, set up log audit and behavior audit measures.

2. We have established a dedicated department of personal information protection and data security emergency response to promote and safeguard personal information security.

3. There are risks of information leakage in the network environment. When your information is leaked due to accidents, force majeure and other circumstances, we will try our best to control the situation and promptly inform you of the cause of the incident, the security measures we take, the security measures you can take on your own initiative and other relevant information. At the same time, we will timely inform you of the relevant information of the event by email, letter, phone, push notification and other ways. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish announcements. At the same time, we will report to the relevant competent authorities in accordance with the requirements of laws and regulations.

 

II. Preservation of your information

1. We will preserve personal information collected in China in accordance with laws and regulations and will not transmit your personal information outside China, unless required by regulations or otherwise with your express consent.

2. During the period when you use this APP, we will store your personal information in accordance with the PRC Network Security Law and other laws and regulations.

YOUR RIGHTS

I. Visit or rectify your information

You can visit your information, except where forbidden by laws and regulations

(1) You can see the bounded device model, serial number, firmware version and other product information in the “Settings” page of this APP.

(2) Except for the information listed above, we cannot provide you with access to or correction service for some of your information. Such information include your device information, for the purpose of improving your user experience and secure service safety, and necessary personal information for the proper operation of your selected functions. Such information will only be used within the scope of your authorization and you can contact us to delete or complete anonymous processing.

II. Delete your information

You can directly clear or delete some of your information including your private data stored in the device, and the operation path of deletion is the same as the above access or correction path; In the following situations, you can contact us and request to delete other information:

(1) If we are in violation of laws and regulations when handling your personal information;

(2) If we collect and use your personal information, without your consent;

(3) If we violated the agreement with you when handling your personal information;

(4) If we have terminated the service and operation of this APP.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it in a timely manner, unless otherwise provided by laws and r egulations or your independent authorization has provided to these entities. When you delete the information, we may not immediately backup system to remove the corresponding information. However, this information will be deleted during backup updates.

III. Change the scope of permissions or cancel the permissions

You can change the scope of your permission or cancel your permission by deleting information, closing certain service or function, setting privacy settings, or applying permission management. You may also cancel all your permissions by canceling your account.

Please understand that each function may require some basic information to be completed. After withdraw your consent or permission, we cannot continue to provide you with the corresponding services or functions and will no longer process your corresponding information. However, your decision to withdraw your consent or permission will not affect the prior processing of your information based on your permission.

IV. Acquire the copy of your personal information and require for responses

If you are unable to manage your personal Information in the above manner, or you need to obtain a copy of your personal information, or you have other requests for personal information rights, you may contact us by email at [info@arkonoptics.ru] or by other means specified in this Policy. For security purposes, we may require you to provide a written request, or otherwise prove your identity, and we will respond to your request within 15 business days of receiving your feedback and verifying your identity.

For your reasonable request, we do not charge any fees from you in principle, but for repeated requests or requests beyond reasonable limit, we will charge a certain cost, as the case may be. We may refuse requests that are unreasonably repeated or require excessive technical processing (for example, some of the requests may need the development of new systems or fundamental changes of existed practices), or pose a risk on the legitimate rights of others, or are highly impractical.

According to the PRC Network Security Law, PRC Personal Information Security Standard of Information Security Technology and other applicable laws and regulations and national standards, in the following situations, we will not be able to respond to your request:

(1) Situations related to the legitimate obligation of Arkon;

(2) Situations directly related to national security, national defense security;

(3) Situations directly related to public security, public health or major public interest;

(4) Situations related to criminal investigation, prosecution, trial and execution of the judgment

(5) Situations where there is sufficient evidence that you have subjective malice or abuse of rights;

(6) Situations where it is necessary to protect your or other person’s lives, properties or other lawful rights and interests, whereas it is hard to get your consent;

(7) Situations where any response may cause serious injuries on the legitimate rights of you or other individual or organizations;

(8) Your request may involve business secrets.

HOW WE PROCESS PERSONAL INFORMATION OF MINORS

1. We attach great importance to the protection of minors' personal information. If you are a child or other minor under the age of 18, please ask your parents or other guardians to carefully read this Policy and to use this APP and provide information to us with the consent of your parents or other guardians.

2. As for the information collected with the consent of parents or legal guardians, we will only use or publicly disclose this information when permitted by law, or permitted by the express consent of parents or legal guardians, or, when necessary for the protection of minors.

3. If a parent or legal guardian has reason to believe that a minor has submitted personal information to us without prior consent, or has questions about our Policy, please contact us through the means set out in this Policy.

AMENDMENT OF THIS POLICY

We may change this Policy from time to time. We will not reduce your rights under this Policy without your express consent. We will notify you of major changes in the form of push notifications, pop-ups or emails.

Significant changes in this Policy include but not limited to:

1. Major changes in our service mode. For example, the purpose of personal information processing, the type of personal information processing, the use of personal information, etc.

2. Significant changes in our ownership structure or organizational structure, etc. Such as owner changes caused by business adjustment or bankruptcy M&A;

3. Changes in the objects of personal information sharing, transfer or disclose;

4. Major changes in your rights or the form of your participation in the information processing;

5. Changes in the responsible department, contact information or complaint channel of personal information processing

6. High risks being indicated in the personal information security assessment report.

HOW TO CONTACT US

Should you have any questions, advice or suggestions regarding this Policy or any issues regarding your personal information, please send email to info@arkonoptics.ru to contact personal information protect commissioner. You can also send mails to:

Address: No. 518 IoT Street, Binjiang District, Hangzhou, Zhejiang, 310051

We will normally reply within 15 working days.

If you are not satisfied with our response, especially if our personal information processing has injured your legitimate rights and interests, you can also complain or report to the Cyberspace Administration of China, Public Security Bureu, Market Supervisory Authority, or other supervisory department or authorities.