Privacy Policy

Updated: May 13, 2025

       Shenzhen Zhencheng Technology Co., Ltd. (hereinafter referred to as "Speed ​​Shadow ", "we", "us") is well aware of the importance of privacy to you and will respect your privacy. The CameraDV Privacy Policy (hereinafter referred to as "this Policy") applies to the products and services we provide and their extended functions, including the SportCam app, CameraDV app, and the new forms that emerge with the development of technology (hereinafter referred to as "our platform") Provided to you with various products and services. If a product or service we provide has a separate privacy policy or user service agreement, the privacy policy or user service agreement of the product or service will take precedence. Contents not covered by the privacy policy and user service agreement of the product or service shall be subject to the content of this policy . or services. Unless otherwise agreed, the terms used in this policy have the same meaning as those in the CameraDV User Service Agreement.

       If you are a minor or a person who does not have full civil capacity (hereinafter referred to as a "minor") according to the laws of the jurisdiction where you live, please read this Agreement carefully and fully understand it in the presence of your legal guardian, and use CameraDV products and services only after obtaining the consent of your legal guardian.

This policy will help you understand the following:

1. How we collect and use your user information

2. How we use cookies and similar technologies

3. How we share, transfer, and publicly disclose your user information

4. How we protect your user information

5. Your rights

6. How we handle children's personal information

7. How your user information is stored and how it is transferred globally

8. How to update this policy

9. How to contact us

        We are well aware of the importance of user information to you and will do our best to protect your user information. protect your user information in accordance with the industry's mature security standards.

Please read and understand this privacy policy carefully before using our products (or services).

1. How we collect and use your user information

(I) Information we collect and use when you use our products or services

       We will only collect and use your user information for the business functions described in this policy. The purpose of collecting user information is to provide you with products or services. You have the right to choose whether to provide this information. However, in most cases, if you do not provide it, we may not be able to provide you with the corresponding services or respond to the problems you encounter:

1.Improve or optimize our services

       Visit our platform webpage or use our platform services through mobile electronic devices. In order to improve or optimize our services, we may read the geographic environment and location information of your device, information related to your mobile device, such as device model, device identification code, operating system, resolution, telecom operator, Android ID, Android SD card data, etc.

2. Provide basic services and improve security

       When you use our products or services, we need to collect information such as usage log records generated by them.

       When you submit information using our platform, we need to collect information such as your WI-FI connection status and hardware serial number.

       When you visit our webpage through a computer, or visit our mobile webpage through a mobile smart terminal, download, use our or our affiliates' client software to use our services, we may read information related to your device, such as media access control (MAC) address, browser name and version, language, geographic location information, device manufacturer and model, device identification code, operating system, resolution, telecom operator, etc.

       In order to improve the security of your use of our services and more accurately prevent phishing scams and Trojan viruses, we may determine the risk of your account by understanding some of your network usage habits, your user behavior data, the user's basic device information, URL access records (such as device terminal type, device terminal screen resolution, device network operator, etc.), and may record some URLs that we believe are risky.

3. Other information you send to us in addition to the above information

       The above information you provide will continue to authorize us to use during your use of this service. When you stop using the push service, we will stop using and delete the above information.

       We guarantee that the collected user information will be de-identified or anonymized in accordance with the law. Information that cannot identify the personal identity of a natural person alone or in combination with other information does not constitute personal information in the legal sense.

       In order to better operate and improve our technology and services, or due to changes in business strategies, when the collection, use, and processing of user information required for the products or services we provide exceeds the above scope or the collected user information is to be used for other purposes not specified in this Privacy Policy, or when we want to use the information collected for a specific purpose for other purposes, we will notify you within a reasonable period after obtaining the user information or before processing the user information, and obtain your authorization and consent.

(2) Device permission call

       To achieve the above purposes, we may need you to open your device access permissions to us in your device:

(III) Exceptions to obtaining authorization and consent

       Please understand that according to laws, regulations and relevant national standards, we do not need your authorization to collect and use your user information in the following circumstances:

       1. Directly related to national security and national defense security;

       2. Directly related to public safety, public health, and major public interests;

       3. Directly related to criminal investigation, prosecution, trial and execution of judgment;

       4. To protect your or other individuals’ life, property and other major legal rights and interests, but it is difficult to obtain their consent;

       5. The user information collected is disclosed to the public by you on your own initiative;

       6. Your user information collected from legally disclosed information, such as legal news reports, government information disclosure and other channels;

       7. Necessary for signing or performing a contract according to your requirements;

       8. Necessary for maintaining the safe and stable operation of the software and related services, such as discovering and handling failures in the software and related services;

       9. The controller of personal information is a news organization and it is necessary for them to carry out legitimate news reporting;

       10. When academic research institutions conduct statistical or academic research based on public interests and provide the results of academic research or descriptions to the outside, they shall de-identify the personal information contained in the results.

       11. Other circumstances prescribed by laws and regulations.

2. How do we use cookies and similar technologies?

1. Cookies

       To ensure the normal operation of the website, we will store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With cookies, the website can store your access preference data.

       We will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences. You can clear all cookies saved on your computer, and most web browsers have the function of blocking cookies. However, if you do this, you will need to change the user settings yourself every time you visit our website.

(II) Web beacons and pixel tags

       In addition to Cookies, we also use other similar technologies such as web beacons and pixel tags on our websites. For example, the email we send to you may contain 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. Web beacons are usually transparent images embedded in websites or emails. With the help of pixel tags in emails, we can know whether the email has been opened. If you do not want your activities to be tracked in this way, you can unsubscribe from our mailing list at any time.

III. How do we share, transfer, and publicly disclose your user information?

1. Sharing

We will not share your user information with any other company, organization or individual, except in the following circumstances: 1. Sharing with explicit consent: After obtaining your explicit consent, we will share your user information with other parties.

       2. We may share your user information with external parties in accordance with laws and regulations or the mandatory requirements of government authorities.

       3. Sharing with our affiliates: Your user information may be shared with our affiliates. We will only share necessary user information and will be subject to the purposes stated in this Privacy Policy. If an affiliate wants to change the purpose of processing user information, it will ask for your authorization again.

       4. Sharing with authorized partners: Some of our services will be provided by authorized partners only for the purposes stated in this policy. We may share some of your user information with partners to provide better customer service and user experience. We will only share your user information for legitimate, legal, necessary, specific and clear purposes, and will only share user information necessary to provide services. In order to better operate and improve technology and services, you agree that we and authorized partners may use the collected information for other services and purposes in compliance with relevant laws and regulations.

       The following lists specific authorized partners and provides links to the privacy policies of the third parties. We recommend that you read the privacy policies of the third parties:

       We will sign a strict confidentiality agreement with the companies, organizations and individuals with whom we share user information, requiring them to handle user information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

(II) Transfer

We will not transfer your user information to any company, organization or individual, except in the following circumstances:

       1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your user information to other parties;

       2. In the event of mergers, acquisitions or bankruptcy liquidation, if user information transfer is involved, we will require the new company or organization holding your user information to continue to be bound by this Privacy Policy, otherwise we will require the company or organization to re-ask for your authorization and consent.

(III) Public Disclosure

We will only publicly disclose your user information in the following circumstances:

       1. After obtaining your explicit consent;

       2. Disclosure based on law: We may publicly disclose your user information when required by law, legal procedures, litigation or government authorities.

(IV) Exceptions to obtain prior authorization and consent when sharing, transferring, and publicly disclosing information

Please understand that, according to laws, regulations, and relevant national standards, we do not need to obtain your authorization and consent to share, transfer, and publicly disclose your user information in the following circumstances:

       1. Directly related to national security and national defense security

       2. Directly related to public safety, public health, and major public interests;

       3. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

       4. For the purpose of safeguarding your or other individuals' major legitimate rights and interests such as life and property, but it is difficult to obtain the consent of the person concerned;

       5. Information you disclose to the public on your own;

       6. Information collected from legally disclosed information, such as legal news reports, government information disclosure, and other channels.

IV. How we protect your user information

       (I) We have used security protection measures that meet industry standards to protect the user information you provide and prevent data from being accessed, disclosed, used, modified, damaged, or lost without authorization. We will take all reasonable and feasible measures to protect your user information. mechanisms to ensure that only authorized personnel can access user information; and we will hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting user information.

       (ii) We will take all reasonable and feasible measures to ensure that no irrelevant user information is collected. We will only retain your user information for the period required to achieve the purposes stated in this policy, unless the retention period needs to be extended or is permitted by law.

       (iii) The Internet is not an absolutely secure environment, and emails, instant messaging, and communication methods with other users are not encrypted. We strongly recommend that you do not send user information through such methods.

       (iv) The Internet environment is not 100% secure, and we will do our best to ensure the security of any information you send to us. Even if we have made great efforts and taken all reasonable and necessary measures, it is still possible that we cannot prevent your user information from being illegally accessed, illegally stolen, illegally tampered with or destroyed, resulting in damage to your legitimate rights and interests. Please understand the above risks of the information network and voluntarily bear them.

       (V) After the unfortunate occurrence of a user information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the telephone disposal measures we have taken or will take, your suggestions for self-prevention and risk reduction, and your remedial measures in accordance with the requirements of laws and regulations. We will promptly inform you of the relevant circumstances of the incident by email, letter, letter, push notification, etc. When it is difficult to inform the user information subject one by one, we will take reasonable and effective ways to issue an issue announcement. At the same time, we will also proactively report the disposal of the user information security incident in accordance with the requirements of the regulatory authorities.

V. Your rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights to your user information:

       (I) Access your user information

       You have the right to access your personal information under the provisions of laws and regulations. If you wish to access and edit the personal information in your account, you can log in to your account on our website or App and access your profile, change your password, change your email address, and other related pages to perform operations.

       (II) Correcting your user information

       If you find that we have made mistakes in handling your personal information, you have the right to ask us to make corrections. You can contact us at any time through the contact information provided on the website or App, or send an email to privacy@sjcam.com at any time.

       (III) Deleting your user information

       In the following circumstances, you can ask us to delete your user information:

       1. If our handling of user information violates laws and regulations;

       2. If we collect and use your user information without your consent;

       3. If our handling of user information violates the agreement with you;

       4. If you no longer use our products or services, or you cancel your account;

       5. If we no longer provide you with products or services.

       We will evaluate your deletion request and take corresponding steps to handle it if it meets the relevant regulations. When you make a deletion request to us, we may ask you to authenticate your identity to ensure the security of your account. When you delete information from our services, due to applicable laws and security technologies, we may not immediately delete the corresponding information from the backup system. We will store your information securely until the backup can be cleared or anonymized.

       (IV) Change the scope of your authorization

       Each business function requires some basic user information to be completed (see "Part I" of this policy). You can give or withdraw your authorization and consent for the collection and use of user information at any time. You can do this by yourself in the following ways: send an email to privacy@sjcam.com.

       When you withdraw your consent, we will no longer process the corresponding user information. At the same time, please note that your withdrawal of authorization and consent may result in certain consequences, such as we may not be able to continue to provide you with the corresponding services or specific functions, but your decision to withdraw consent will not affect the user information processing previously carried out based on your authorization.

       (V) User Information Subject Obtains a Copy of User Information

       You have the right to obtain a copy of your user information, and you can do this by yourself in the following ways: You can send an email to privacy@sjcam.com, and we will reply with a copy of your user information.

       Under the premise that it is technically feasible, such as data interface matching, we can also directly transfer a copy of your user information to a third party designated by you at your request.

       (VI) Constraints on Automatic Decision-making of Information Systems

       In certain business functions, we may make decisions based solely on non-manual automatic decision-making mechanisms including information systems and algorithms. If these decisions significantly affect your legal rights and interests, you have the right to ask us to explain, and we will also provide appropriate relief.

       (VII) Respond to your above requests

       For security reasons, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.

       In principle, we do not charge any fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost fee depending on the circumstances. We may reject requests that are unreasonably repeated, require too many technical means (for example, the development of new systems or fundamental changes to current practices), pose risks to the legitimate rights and interests of others, or are extremely impractical. Please also understand that for security reasons, the requirements of relevant laws and regulations, or technical limitations, we may not be able to respond to some of your requests, such as the following situations:

       1. Related to the user information controller's fulfillment of obligations stipulated by laws and regulations;

       2. Directly related to national security and national defense security;

       3. Directly related to public security, public health, and major public interests;

       4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;

       5. The user information controller has sufficient evidence to show that the user information subject has subjective malice or abuses rights;

       6. For the purpose of maintaining the major legitimate rights and interests of the user information subject or other individuals, such as life and property, but it is difficult to obtain the consent of the person concerned;

       7. Responding to the user information subject's request will cause serious damage to the legitimate rights and interests of the user information subject or other individuals and organizations;

       8. Involving commercial secrets.

VI.How we handle children's personal information

       We attach great importance to the protection of children's personal information. Our products, websites and services are mainly for adults. Children should not create their own user accounts without the consent of their parents or guardians. Although local laws and customs have different definitions of children, we regard anyone under the age of 14 as a child.

       In the case of collecting child user information with the consent of their parents or guardians, we will only store, use or publicly disclose this information when permitted by law, with the explicit consent of their parents or guardians, or when necessary to protect children, otherwise we will try to delete the relevant data as soon as possible.

       Given the limitations of existing technology and business models, it is difficult for us to actively identify children's personal information. If you find that we have collected children's personal information without their knowledge or without the prior consent of a verifiable guardian, you can contact us in time and we will try to delete it in time after discovery. If we find the above situation ourselves, we will also delete it in time, unless the law requires us to retain it.

VII. How your user information is stored and transferred globally

       In principle, the user information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China. We will only retain your user information for the period required for the purposes and uses described in this policy and for the shortest period required by laws and regulations. After the above retention period, we will delete your user information or anonymize it in accordance with the requirements of applicable laws and regulations. etc., or with your separate authorization and consent, we may need to retain the relevant data for a longer period of time.

       Because we provide products or services through resources and servers around the world, this means that, after obtaining your authorization and consent, your user information may be transferred to or accessed from jurisdictions outside the country/region where you use the product or service.

       Such jurisdictions may have different data protection laws or even no relevant laws. In such cases, we will ensure that your user information is sufficiently protected as in the People's Republic of China. For example, we will request your consent to the cross-border transfer of user information, or implement security measures such as data de-identification before cross-border data transfer.

VIII. How this policy is updated

       Our privacy policy may change. Without your explicit consent, we will not reduce your rights under this privacy policy. We will post any changes to this policy on this page.

       For major changes, we will also provide more prominent notices. Major changes referred to in this policy include but are not limited to:

       1. Major changes in our service model. Such as the purpose of processing user information, the type of user information processed, the way user information is used, etc.;

       2. Major changes in our ownership structure, organizational structure, etc. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;

       3. Changes in the main objects of user information sharing, transfer or public disclosure;

       4. Major changes in your rights to participate in user information processing and the way you exercise them;

       5. When our responsible department, contact information and complaint channels for handling user information security change;

       6. When the user information security impact assessment report indicates a high risk.

       We will also archive the old version of this policy for your review.

IX. How to Contact Us

       If you have any questions, comments or suggestions about this privacy policy, please contact us through the following methods:

       Email: privacy@sjcam.com

       Generally, we will respond within thirty days.

       If you are not satisfied with our response, especially if our user information processing behavior has harmed your legitimate rights and interests, you can also seek solutions through the following external channels: You can also file a complaint or report to the regulatory authorities in your area.

       This policy version was updated on [May] [13], 2025, and will take effect on [May] [13], 2025.