Product Privacy Policy

Last updated: May 20th, 2021

We Value Your Privacy and Trust

We understand the importance of protecting your data. Our Privacy Policy is designed to maximize your ability to protect your personal, private data while at the same time allowing us to operate, provide, improve, understand, customize, support, and market our services to the best benefits of our users. This Privacy Policy for YI Products and services ("Privacy Policy") describes information that YI Technologies, Inc. and its subsidiaries and other group companies (collectively, "YI", "we," or, "us") collect, use, share, or store, including personal information (i.e., information that directly or indirectly personally identifies you) or a combination of data that can be reasonably used to infer information about you (such as your email address or mobile phone IMEI).

This document focuses on information related to the operation of the following YI products and services: YI camera, YI IoT camera, Kami camera (collectively, "YI Products"). In this Privacy Policy, the expression "YI Products" also includes our Mobile App, PC App, and YI Cloud as defined in our Terms of Use.

This Privacy Policy should be read in conjunction with the Terms of Use of which it forms part and which also apply when you visit our website or use YI Products. If you do not agree with this Privacy Policy, you must not submit information to us through or in connection with the website or use YI Products.

Our Privacy Policy

The information we receive and collect depends on how you use our services. We require, collect, and store certain data from or about you that can be used to uniquely contact, categories, or locate when you interact with our website, app, contact us, purchase our product, request YI Products and services or when you use YI Products, as further detailed below. We collect personal information in writing, by telephone and by email.

Personal Information You Provide As YI Customer

Types of personal information we may collect and/ or you provide it to us, include:

• Identity data – includes first name, last name, title, date of birth and gender.

• Contact data – includes address, email address and telephone numbers.

• Technical data – includes information about your internet protocol (IP) address, your login credentials used to verify your identity, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access YI products, website, and apps.

Types of personal information we may collect and/or you provide it to us when you subscribe to our services, may include the same information listed above, along with:

• Purchase and transaction data – including bank account and payment card details as well as details about payments to and from you and other details of services you have purchased from us, billing and shipping addresses (related for payment purposes).

• Marketing and communications data – where you have opted-in via your user preferences in your account settings, we hold details about your preferences for receiving marketing information from YI and/ or our third parties, your communication channel preference, language, demographic information, or your social network accounts.

• Business data – your function/job title within the company and your work email address, company's name, postal address, VAT and/or company number.

Specific YI Products collect specific additional data as further detailed below:

YI Camera Information Collection and Use

YI camera may collects:

• Setup information you provide

Information input during setup: When you set up a YI camera, you will be asked for certain basic information like your email address, your Facebook username, login credentials, internet or Wi-Fi information, and your general location (e.g. city or country).

• Video and audio signals and data

Video and audio signals and data: When you enable the recording or streaming features of your YI 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 face detection, human detection, motion sensing, sound detection, and other AI-based features on your YI camera, we will record and process video and/or audio recordings upon sensing motion, human figure, face, 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, analyse, 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 cloud subscription plan) and you will be able to access, download, and delete those recordings using YI services during your subscription period or stated otherwise for a specific time. At the end of your subscription period, or the storage plan according to your subscription plan, your video recordings are deleted from YI's storage systems.

• Technical information from the device

Technical information from the device: In order to improve our service and provide the best monitoring experience over time, help troubleshoot problems you may encounter, and provide updates to YI camera, we store your device information, such as the 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 YI 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.

• Saved and shared content

Saved and Shared Content: Your YI camera can utilize the YI Cloud subscription service to store audio, image, and video content during a selected subscription period (for example, 7, 15, or 30 days). After the subscription period, the content is deleted from YI's systems. We have technical barriers to prevent unauthorized viewing or hearing your audio, camera, and video content, 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 YI and has its own privacy and service policies.

The content you share by placing it on YI Community is available for sharing for a limited time (e.g. 30 days or less) after which it is deleted from YI's systems.

NOTE: YI is not responsible for the privacy practices of any website or third-party applications and services that it does not own or otherwise control and you should read the privacy policies of websites, applications and services owned and controlled by others before deciding whether to proceed. Privacy laws in your region may impose certain obligations on you and your use of security cameras or cloud storage products. You as a YI customer are solely responsible for ensuring that you comply with the regulation in your region. Depending on your region, you may be required to inform your guest, visitor, client, or other non-YI users that you are using a security camera to record audio and video. You may need to consider their privacy rights before sharing the video or clip that involves other non YI-users.

Types of Information Collected & Stored by YI During Account Login on the App.

• Wi-Fi Network Information: To connect your YI Product to YI services, including YI Cloud, or to access your YI Product over the Internet from a computer, a smartphone or a tablet, you may need to connect it to your existing Wi-Fi network. During setup, the YI Product will ask for your Wi-Fi network name (SSID) and a password to connect the YI product to your internet network. The Wi-Fi network information will be stored, and used on the selected devices to enable streamline monitoring access and control from your computer, smartphone or tablet. The connection will enable YI systems and devices to send the algorithm and video recordings or to update the software required on the app.
Once connected to your Wi-Fi network, your YI Product regularly sends the data described in this Privacy Policy (excluding your Wi-Fi password) to the YI systems to provide you with continuous services.

• Email Addresses Used for Login on YI app: When a YI account is created, we collect and store your email address or the alternative credentials, such as Facebook account, or MI account. These email addresses and login accounts are used to provide you with technical updates or marketing communications from YI.

• Basic Profile Information: Your account allows you to provide certain basic profile information like a profile picture, username of your choice, location of service, and so on. Usernames and profile photos may be shown to others in connection with YI services. As is true with most websites, we collect certain information and we routinely record log entries or technical information as you use our services from a mobile device, tablet, or PC.

More details on our App Privacy Policy, you can check on each app below:

• YI Life app, you can review it here: Privacy Policy of YI Life app.

• YI IoT app, you can review it here: Privacy Policy of YI IoT app.

YI's Interaction with the Third Parties Data Collection

Any 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. For example, when you elect to use Third-Party Products and Services, such as Amazon Alexa Skill or Google Assistant (as and when each is introduced), you agree that we may provide certain data about you to such partners in order to enable the activation, connection and integration with and to such Third-Party Products and Services you intend to use or otherwise choose to activate. Your consent is required to allow any of these exchanges or requests for control and you will be able to revoke or disable it at any time.

If you choose to enable or connect YI products with third-party products, applications, functionality, or services through the means authorized and directed by YI, you acknowledge and agree that we may share certain information for account authentication and management purposes.

Any data that YI 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 YI 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 YI account or the YI logs.

Use of the Information It Collects

YI uses the information as described above, to provide, develop and improve YI Products and Services, including making assessments and recommendations about products or safety. We may use your contact details to send you technical updates about your YI products and YI Cloud storage information, to participate in surveys, and/or to send you other forms of communications on behalf of YI.

We may also use this information in an aggregated, non-identified form for research purposes and to provide a better shopping experience on our sites, process payments, understanding your preference, and help us to build better business decisions for our customers. 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. YI conducts secure data protection and implements a reasonable contractual system to limit the use of a third-party service provider to perform some of these analytics functions. Those service providers are restricted from sharing your information for any other purpose. YI also provide a strict control and provisions against unauthorized YI employee access to your data recordings collected from your YI Products.

Except as otherwise explained in this Privacy Policy, YI may use your browsing history or behavioral data information to show you ads or send you marketing related information via the communications methods you have selected on your user preferences in the account settings. Not all YI Products conduct direct marketing. Where this functionality is available, you can change your preferences at any time and switch this option on/off. 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.

Depending on your location and type of data, YI may process your personal information on servers that are not in your home country. If you are in the United States, YI processes your personal information only in the United States. If you are outside of the United States, YI processes your personal information in Germany and/or Singapore-based secured servers.

Our Legal Bases for Processing Information

In order to store, hold and process your data lawfully where EU Data Protection Law (including the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016), read in conjunction with and subject to any consequential national data protection legislation) applies, we rely on one or more of the following legal grounds:

Where it is necessary for the performance of a contract • we process your data to provide and support a product or service you have asked for under a contract, including but not limited to delivering our Terms of Use.

When we are pursuing legitimate interests. We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:

• Offering and improving YI Products and services
• Developing new products and features
• performing research that improves our services for our users and benefits the public
• protecting against harm to the rights, property, and safety of YI, our users, and the public
• detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services
• maintaining and improving the integrity of our computing systems, and protecting our users' data security
• enforcing legal claims, including investigation of potential violations of applicable Terms of Use

When we are complying with legal obligations. We process your data when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable governmental request.

With your consent. Where necessary, we ask for your consent to process your information for certain specific purposes and give you the right to withdraw that consent at any time.

How We Share Your Information

We do not share or sell any personal information for any purpose unrelated to the activation and delivery of YI Products and services without seeking your consent.

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

• Third-party Customer Service Agency: We have customer 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 YI 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-YI 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.

• Transfer of the Company: 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.

• Legal requests: In response to a legal request (e.g. a search warrant, court order or subpoena), 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 YI 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 YI Product from a retailer, the retailer may collect personal information as part of the transaction.

Option to Delete Your Personal Information

YI generally stores your personal information on YI's systems until you delete or edit it, or for as long as you remain a YI customer, in order to provide you with YI Products, but your audio, photo, and video files are stored for a limited time (e.g., 7, 15, or 30 days). Your YI 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 privacy@yitechnology.com.

As described above, some information is processed and stored directly on the YI device. All personal information is encrypted as it is transmitted to YI and cannot easily be accessed.

You can access, amend or delete your personal information from YI's systems through the controls in your YI 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.

Retention of Personal Data

Your personal data will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Policy (unless longer retention is required by applicable law). However, we will not retain any of your personal data beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Third Party Websites and Social Media

Our Site may contain links to other websites operated by third parties and may include social media features such as but not limited to Facebook, Twitter, Instagram, Wordpress, Zendesk, and Pinterest buttons or links. These websites use cookies to improve the user experience. Some of the information automatically collected through Cookies and Analytics partners. These third-party sites may collect information about you if you click on a link and the social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button. Your interactions with these features are governed by the privacy policy of the company providing the link, not by YI Privacy Policy. To opt-out or remove the third-party cookies, you can visit their privacy policy.

Cookies, Web Beacons, and Website Analytics.

By using YI site, we assume your permission to deploy cookies in accordance with our Cookie Policy.

The YI site(s), website(s), and YI app(s) use cookies to distinguish you from other users of the other website and app. This helps us to provide you with a good experience when you browse YI service and allows us to improve our website(s) and/or app(s). If other YI Products use cookies we will inform you.

This section of the Privacy Policy explains what cookies are, why we use them and what you may do if you wish to restrict, remove or refuse to accept cookies. By continuing to use the YI Action camera website and/or app, you agree to the use of cookies for the purposes set out in this Privacy Policy.

A cookie is a small file that a website, app or its service provider transfers to your computer's hard drive, mobile phone or other device, through your web browser (if you agree) that enables the website's, app's or service provider's systems to recognize your browser and capture and remember certain information. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose Duration The table header
[Google Analytics _ga] Used to distinguish users 2 yrs These cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.
https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
[Google Analytics _gat] Used to throttle request rates to maintain Website performance 1 min
[Google Analytics _gid] Used to distinguish users 24 hr

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the relevant website and/or app.

International Transfers of Personal Data

Depending on your geographic location, your personal information may be collected, processed and stored by YI or its service providers in the United States and other countries. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country.

If you are located in the European Economic Area ("EEA"), the UK and Switzerland and using YI Products please be aware that we may transfer your personal data to a third party in countries outside the EEA for further processing in accordance with the purposes set out in this Privacy Policy. In particular, your personal data may be transferred to the United States and other countries (including to Germany and Singapore) where YI operates and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances. For transfers of data from the EEA to the United States or Singapore, YI (i.e., the controller) has entered into the European Commission's Standard Contractual Clauses with its service providers (i.e., processors) to protect user's privacy rights.

If you are using YI Products in other regions (outside of the EEA) with laws governing data collection and use that may differ from United States law, you consent to the transfer of your personal data to the United States and other countries (including to Germany and Singapore) where YI operates.

Individual Rights in the European Economic Area (EEA)

If you are located in the EEA, you may seek confirmation regarding whether YI is processing personal information about you, request access to your personal information and ask that we correct, amend or delete your personal information. In addition, you may object to YI's processing of your personal information at any time. However doing so may impact your use of the YI Products and services.

If applicable law provides you the right to request access to, (receive) port, object to or restrict processing, seek rectification or request erasure of personal information held about you by YI, you may do so, as applicable, through controls in the YI Home app or by contacting YI at privacy@yitechnology.com.

Further information on your rights in the EEA is set out below:

• Right to obtain a copy of your personal data – you have the right to obtain a copy of the personal information we hold about you. If you would like to make a SAR, i.e. a request for copies of the personal data we hold about you, you may do so by contacting us at the contact details above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity.

• Right to rectification – you may request that we rectify any inaccurate and/or complete any incomplete personal data.

• Right to withdraw consent – you may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal data is essential.

• Right to object to processing – including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your personal data. In relation to automated processing and profiling, you may object to the processing and you will have the right to obtain human intervention.

• Right to erasure – you may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.

• Right to data portability – in certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services.

• Your right to lodge a complaint with the supervisory authority – please contact us first about any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to contact the relevant EEA supervisory authority directly.

Compliance with the UK Law terms and condition

Under this agreement, the payment processing services for goods and/or services purchased on this website are provided by SUNLIGHT (UK) TRADING LIMITED & Old Street,167 City Road,London,EC1V 1AW,UK on behalf of YI Technology. In the event you choose to pay with credit card and the payment will be processed via an European Acquirer, these terms are an agreement between you and SUNLIGHT (UK) TRADING LIMITED & Old Street,167 City Road,London,EC1V 1AW,UK.

If there is any chargeback or reversal of any payment requested by a payment service partner, SUNLIGHT (UK) TRADING LIMITED has the right to refund the money so requested by the payment service partner without liability to YI Technology. SUNLIGHT (UK) TRADING LIMITED will use reasonable efforts to assist YI Technology in participating in the dispute resolution process of the relevant payment service partners.

For any enquiries if you choose DHpay for payment,you can contact:
SUNLIGHT(UK) TRADING LIMITED
Address: Old Street 167 City Road London, EC1V 1AW, UK

Change to Privacy Notice

Please note that this Privacy Policy may change from time to time. We will provide notice of any changes by contacting you through a notification in the YI mobile app or through the email contact information you provided when setting up your YI account.

Contact Us

Please contact us if you have any questions or comments about our privacy policy, you can share your question or comments through our contact us page or send us an email to: privacy@yitechnology.com.

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