1.2 Device permission

       To collect the above, we may need you to turn on your device access to us in your device:

Permission Name	Type of System	Purpose of permission
Network	iOS/ Android	Control and Manage Cameras
Album	iOS/ Android	Download and Export Files from
Local Network	iOS/ Android	APP and camera communication
Notification	iOS/ Android	Receive timely APP Alerts
Location	Android	Get camera WiFi name
Personalized Recommendations	iOS/ Android	Community work recommendations and information notifications
Storage	iOS/ Android	Connect and control the camera

1.3 Personalized Recommendations（SJCAM Zone APP only）

       Function description: In order to show you and recommend more relevant information and provide services that better meet your requirements, SJCAM Zone will collect and use your personal information and automatically calculate and predict your preferences through computer algorithm models to match you. For information or services that may be of interest to you, below we will explain in detail how this personalized recommendation service operates and how you can control it.

       a) The scope of our personalized recommendation services includes but is not limited to displaying images, texts or videos.

       b) In order to predict your preferences, we may collect and use your device information and behavioral information when using SJCAM Zone. Behavioral information includes your content browsing, information posting, likes, browsing, and sharing when using SJCAM Zone. We will automatically analyze and calculate the above information, and the machine (or system) will automatically filter and push content that may be more interesting to you based on the calculation results.

       c) We will provide real-time feedback to the recommendation model based on your content browsing behavior while using SJCAM Zone, and continuously adjust and optimize the recommendation results to better provide you with high-quality content. Please be aware that the personalized recommendation algorithm in SJCAM Zone does not identify the true identity of a specific natural person, but only provides more relevant and richer information based on user behavior and characteristics.

       You can turn off personalized recommendations in the app settings.

1.4 Exceptions to the collection and use of personal information

       You understand and agree that we have the right to collect and use your personal information without your consent in the following circumstances.

       a) Processing is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract;

       b) Processing is necessary for compliance with a legal obligation to which we are subject;

       c) Processing is necessary in order to protect the vital interests of you or of another natural person;

       d) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

       e) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data.

       f) Other circumstances which are allowed by applicable laws.

2. Cookies and similar technologies we use

2.1 Cookie

       To ensure that the website functions properly, we store small data files called cookies on your computer or mobile device. Cookies usually contain an identifier, the site name, and some numbers and characters. With the help of cookies, websites can store data about your access preferences.

       We will not use Cookies for any purpose other than those stated 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 to block cookies. However, if you do this, you will need to change your user settings yourself each time you visit our website.

2.2 Web beacons and pixel tags

       In addition to Cookies, we also use other similar technologies such as web beacons and pixel tags on our website. For example, emails we sent you may contain click URLs linked to content on our website.

       If you click this link, we will track this click to help us understand your product or service preferences and improve customer service. A web beacon is typically a transparent image embedded into a website or email. With the help of pixel tags in emails, we can learn whether the emails have 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.

2.3 Do Not Track

       Many web browsers have a Do Not Track function, which can issue Do Not Track requests to websites. Currently, the major Internet standards organizations have no policies in place that govern how websites should respond to such requests. However, if your browser has Do Not Track enabled, all of our sites will respect your choice.

3. How we share, transfer, and disclose your personal information

3.1 Sharing of personal information

Our affiliates, partners or other third parties may share your personal information with us for the purpose of providing you with better, more optimal and personalized services, or jointly providing services to you, or for the purpose of preventing Internet fraud, as required by law or as agreed with you or with your consent. Please be aware that you have the right to refuse to consent to the sharing of your personal information with third parties, and that if you refuse to consent to the sharing of information with third parties, you may not be able to use the corresponding features. We will not share your personal information with third parties except in the following circumstances:

       3.1.1 Obtain your prior consent or authorization;

       3.1.2 In accordance with laws and regulations, administrative and judicial mandatory requirements;

       3.1.3 To the extent permitted by law or regulation, as necessary to protect our affiliates or partners, you or other users or the public from harm to their interests, property or safety;

       3.1.4 Enable the core functions of our products and/or services or to provide the services you require;

       3.1.5 Handling disputes or controversies between you and others for you at your request;

3.1.6 in accordance with the relevant agreement with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents agreed to be provided;

3.1.7 Based on academic research;

3.1.8 Based on the public interest of society in accordance with laws and regulations, public health emergencies and use.

The following lists the specific authorized partners and provides a link to the third party's privacy policy. We recommend that you read the third party's privacy policy:

Name of SDK: JPush SDK Purpose of use: Provide messages push services to APP users Infomation Collected:Device identifier (including IMEI, IDFA, AndroidID, GAID, MAC, OAID, IMSI, MEID, UAID), device hardware information (including device model, device screen resolution, device hardware manufacturer, device product name), operating system information (Including operating system version, system name, system language), network information (including network type, operator name, base station information, IP address, WiFi information, SSID, BSSID), push information log, precise location information, software list information ( Including software list and software running list information). Link of Privacy Policy: https://www.jiguang.cn/license/privacy

Name of SDK: umeng SDK Purpose of use: Conduct APP operation statistics and analysis Infomation Collected:Device information (IMEI/MAC/Android ID/IDFA/OAID/OpenUDID/GUID/SIM card IMSI/ICCID), location information, network information Link of Privacy Policy: https://www.umeng.com/page/policy

Name of SDK :MobTech SDK Purpose of use: Sharing, third-party login, SMS verification code Infomation Collected: Device information (IMEI/MAC/Android_ID/IDFA/OpenUDID/GUID/IP address/SIM card IMSI information, etc.), used for security incident investigation, and for detecting and preventing fraudulent activities, to detect and prevent network attacks and abuse, and to protect Cybersecurity and operational security. Link of Privacy Policy: www.mob.com/about/policy

Name of SDK :AMAP SDK Purpose of use: Implement camera video track playback function Infomation Collected:Location information (latitude and longitude, precise location, rough location) [through IP address, GNSS information, WiFi status, WiFi parameters, WiFi list, SSID, BSSID, base station information, signal strength information, Bluetooth information, sensor information (vector, acceleration, pressure, direction, geomagnetism), device signal strength information acquisition, external storage directory], device identification information (IMEI, IDFA, IDFV, Android ID, MEID, MAC address, OAID, IMSI, ICCID, hardware serial number), current application information (Application name, application version number), device parameters and system information (system properties, device model, operating system, operator information). Link of Privacy Policy: https://lbs.amap.com/pages/privacy/

Name of SDK :Qiniu SDK Purpose of use: Upload work Infomation Collected:Device information: including device name, device model, device settings, identifier, region and language settings, usage habits, operating system version and settings of the device used to access the service, device abnormality information; log information: when you use our When providing services on the website or related clients, we will automatically collect your detailed usage of our services and save them as relevant web logs. Including your search query content, IP address, browser type, telecom operator, language used, access date and time and web page records you visited; Link of Privacy Policy:https:www.qiniu.com/agreements/privacy-right

Name of SDK :Facebook SDK Purpose of use:For Facebook login Infomation Collected: 1.Device properties 2.Device operation 3.Identification information 4.Bluetooth signal and related information of peripheral WiFi access points,beacons and mobile phone cellular towers 5.Information from device settings,such as GPS location 6.Network and connection 7.Cookie data Link of Privacy Policy: https://www.facebook.com/privacy/policy?section_id=0-WhatIsThePrivac

Name of SDK :Douyin SDK Purpose of use:For sharing videos on Douyin Infomation Collected:Device properties、Network information Link of Privacy Policy: https://developer.open-douyin.com/docs/resource/zh-CN/dop/operation-standard/service-protocol/douyinsdk_pingtaiyinsizhengce

Name of SDK : Kuaishou SDK Purpose of use: For sharing videos on Kuaishou、and control the camera to push the stream on Kuaishou Infomation Collected:Device properties、Network information Link of Privacy Policy: https://www.kuaishou.com/about/policy?tab=privacy

Name of SDK : Scan Kit SDK（Android） Purpose of use:For scan QRCode Link of Privacy Policy: https://developer.huawei.com/consumer/cn/doc/HMSCore-Guides/sdk-data-security-0000001050043971

Name of SDK : VESDK Purpose of use: video clip Infomation Collected:Device properties、Network information Link of Privacy Policy:http://www.rdsdk.com/wiki#0-1

Name of SDK : WeChat OpenSDK Purpose of use: For WeChat login and sharing videos on WeChat Infomation Collected:Device properties、Network information Link of Privacy Policy: https://support.weixin.qq.com/cgi-bin/mmsupportacctnodeweb-bin/pages/RYiYJkLOrQwu0nb8

Name of SDK : QQ SDK Purpose of use: For QQ login and sharing videos on QQ Infomation Collected:Device properties、Network information Link of Privacy Policy: https://wiki.connect.qq.com/qq%e4%ba%92%e8%81%94sdk%e9%9a%90%e7%a7%81%e4%bf%9d%e6%8a%a4%e5%a3%b0%e6%98%8e

       We will sign strict confidentiality agreements with 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.

3.2 Transfer of personal information

We will not transfer your personal information to any company, organization or individual, except for the following:

       a) Obtain your prior consent or authorization;

       b) provided in accordance with the relevant agreement or other legal document signed with you;

c)In the event of a merger, acquisition, transfer of assets, liquidation or similar situation involving the transfer of personal information, you understand and agree that your personal information will be transferred to the relevant third-party company or organization. We may require the new company or organization holding your personal information to continue to be bound by this Policy, or we may require that company or organization to seek your authorized consent again.

3.3 Disclosure of personal information

We will only disclose your personal information if we take security measures that are consistent with industry standards and if:

       a) After obtaining your consent;

       b) In the case of laws and regulations, legal proceedings, litigation or mandatory requirements by government authorities.

3.4 Exceptions to obtaining prior authorization and consent when sharing, transferring, or disclosure

You understand and agree that we have the right to disclosure your personal information without your consent in the following circumstances.

       a) Processing is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract;

       b) Processing is necessary for compliance with a legal obligation to which we are subject;

       c) Processing is necessary in order to protect the vital interests of you or of another natural person;

       d) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

       e) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data.

       f) Other circumstances which are allowed by applicable laws.

4. How we protect and store your personal information

       We have taken reasonable and practicable security measures, consistent with industry standards, to protect your information from unauthorized access, disclosure, use, modification, damage or loss of personal information. We take the following steps to keep your data secure:

       a) Using encryption technology to improve the security of personal information, protected by SSL protocol encryption when exchanging data between your browser and the server, providing HTTPS protocol for secure browsing;

       b) Use of trusted protection mechanisms to prevent malicious attacks on personal information;

       c) Deploy access control mechanisms and make every effort to ensure that only authorized personnel have access to personal information;

       d) Conducting security and privacy training courses to enhance employees' awareness of the importance of protecting personal information;

e) Specialized data compliance management systems, processes and organizations are in place to safeguard information. For example, we strictly limit the scope of people who access information, require them to comply with confidentiality obligations, and conduct audits. We will take all reasonably practicable steps to ensure that no unrelated personal information is collected. We will retain your personal information only for the shortest period necessary to achieve the purposes described in this Policy, unless otherwise required by the laws and regulations of your location.

The Internet environment is not 100% secure and we will endeavor to ensure or warrant the security of any information you send us. If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legal rights and interests, we will assume appropriate legal liability. After the unfortunate occurrence of personal information security events, we will strictly follow the requirements of the laws and regulations of your location and inform you in a timely manner of: the basic situation and possible impact of the security event, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents and fulfill the obligations stipulated in other laws and regulations in accordance with the requirements of regulatory authorities.

5. Your Rights and Choices Regarding Collected Information

In accordance with the relevant laws, regulations and standards of, as well as the prevailing practices in other countries and regions, we protect your right to exercise the following rights with respect to your personal information. Please note, however, that we may not be able to respond to your request for personal information rights if the relevant personal information you have requested has exceeded the minimum period necessary to achieve the purposes described in this policy or has been deleted. The personal information rights you may exercise include:

       5.1 Right to Access to personal information

       You have the right to access your personal information as provided by law and regulation. If you wish to access and edit your personal information in your account, you may do so by logging into your account on our website or App and accessing the relevant pages for personal information, changing your password, changing your email address, etc.

       5.2 Right to correct your information

       If you discover that we have processed your personal information incorrectly, you have the right to request that we make corrections. You may contact us at any time through the contact information provided on the website or in the App, or send email to privacy@sjcam.com.

       5.3 Right to delete personal information

       You may make a request to us to delete personal information in the following cases, unless otherwise provided by law or regulation:

       a)We collect and use personal information in violation of laws and regulations;

       b)Our processing of personal information is in breach of the agreement with you;

       c)We collect and process your personal information without your consent;

       d)You no longer use our products or services, or you cancel your account;

       e)We no longer provide products or services to you.

       If we decide to respond to your request for deletion, we will also simultaneously notify the entities(if any) from which we obtained your personal information to request its prompt deletion, unless otherwise required by law or regulation, or unless such entities have your independent authorization. When you delete information from our Platform, we may not immediately delete the corresponding information from our backup systems, but will delete it when the backup is updated.

       5.4 Right to object to personal information

       You have the right to object at any time to our processing of your personal information for direct marketing purposes, as well as the right to object to automated decision-making, including analysis that has legal effect or significant impact on you. You have the right to adjust the scope of the personal information we continue to collect or withdraw your authorization at any time, and when you withdraw such consent or authorization, we will no longer process the corresponding personal information and will not be able to continue to provide you with the services for which you have withdrawn your consent or authorization. Your adjustment of the scope of your authorization will not affect the processing of your personal information by SJCAM based on your consent or authorization prior to the adjustment.

       5.5 Cancellation of accounts

       You can cancel the previously registered account at any time. You can do it by yourself in the following ways: Cancel account operation process (click on the user - user avatar - enter the user center - click on cancel account). After canceling your account, we will stop providing you with products or services and delete or anonymize your information based on your request, unless otherwise provided by laws and regulations. This may also cause you to lose access to the data in your account, so please proceed with caution.

       5.6 Right to portability of personal information

       You have the right to obtain a copy of your personal information and you can do so at any time by send email to privacy@sjcam and we will respond to your request within 15 business days. Provided that it is technically feasible for us to do so, for example by matching data interfaces, we can also transfer a copy of your personal information directly to the third party you specify at your request.

       5.7 Stop automated decision making

       In some business functions, we may make decisions based solely on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you have the right to an explanation. If these decisions significantly affect your legal rights, you have the right to seek an explanation from us and we will provide appropriate remedies.。

       5.8 Respond to the above request

       If you are unable to fulfill your rights as described above, or if you believe that SJCAM has violated any laws, administrative regulations, or agreements with you regarding the processing of your personal information, you may contact us through the channels set forth in this Policy. For security purposes, you may be required to provide a written request or otherwise prove your identity. We may first ask you to verify your identity and process your request within the period specified by the laws and regulations of your region .In principle, we do not charge any fees for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits, as appropriate. We may refuse requests that are unwarrantedly repetitive, require excessive technical means (requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are impractical (involving backups of information stored on tapes).

       In the following cases, according to the laws and regulations, we cannot respond to your request:

       a)directly related to national security or national defense security.

       b)directly related to public safety, public health, and significant public interests.

       c)directly related to crime investigation, prosecution, trial and execution of judgments, etc.

       d)where there is sufficient evidence that you have subjective malice or abuse of rights.

       e)where responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations.

       f)where trade secrets are involved.

If we respond to your request for deletion, we will also notify the entities from which we obtained your personal information and request that they delete the corresponding information in a timely manner, unless otherwise provided by law or regulation or unless these entities have your independent authorization. *If you are a Hong Kong resident, in principle, we will respond to your request for access within 40 days, unless:

a)The request is neither made in writing in Chinese nor in writing in English; b)You have not provided us with information that is reasonably necessary to respond to the request, etc.

If you are a Hong Kong resident, in principle we will respond to your request for correction within 40 days of unless: a)We are unable to determine your identity;

b)The request is neither made in writing in Chinese nor in writing in English;

c)We are unable to determine whether the correction request is accurate/confident that the correction request is inaccurate, etc.

6. Protection of minors’personal information

       We do not knowingly collect personal information from minors. Minors may not register for an account on our Platform or send us personal information such as their names, address, phone numbers, email address, etc., unless permitted by local law and their guardians have given their consent. We will only use or publicly disclose personal information collected from minors with the consent of their guardians as permitted by law, with the consent of the guardian, or as necessary to protect the minor.

       If we become aware that we have collected personal information from a minor without the consent of the minor's guardian, we will delete the data as soon as we are aware of it. If you believe that we may improperly hold personal information from or about a minor, please contact us.

7. How your personal information is transferred globally

       Currently, we use AWS database (Singapore) to store your personal information. This means that your personal information may be transferred to, or accessed by, countries or regions other than your place of residence. These countries or regions may have different regulations on the protection of personal information, or even no corresponding regulations on the protection of personal information. In such cases, we will make every effort to ensure that your personal information is adequately protected in accordance with this Policy. We will strictly follow the laws and regulations of your location and the regulations of the relevant regulatory authorities, and fulfill our obligations under the laws and regulations, such as explaining to you the purpose of the outbound of personal information and the type of personal information involved, and requesting the overseas organizations to keep your personal information obtained confidential through effective measures such as signing agreements and on-site verification.

8. Notification and Revision

       This Policy may be updated to provide you with better service and as our business evolves. However, we will not reduce your rights under this Policy without your consent. We will notify you of updates to this Policy by posting updated versions on our website and mobile devices and by appropriate means before they become effective, and we invite you to visit our Platform to keep up to date with the latest Privacy Policy.

       We will also provide more prominent notice of material changes (we will provide specific notice of changes to our Policy, including, but not limited to, a special notice on the viewing page). Material changes within the meaning of this Policy include, but are not limited to:

       a)Significant changes in our service model,such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;

       b)Significant changes in our ownership structure, organizational structure, etc. such as changes in ownership due to business restructuring, bankruptcy and mergers, etc;

       c)Changes in the primary recipients of personal information sharing, transfer or public disclosure;

       d)Significant changes in your rights to participate in the processing of personal information and how they are exercised;

       e)In the event of a change in the department responsible for handling the security of personal information, our contact information and complaint channels;

       f)When the personal information security impact assessment report indicates a high risk.

        We will also keep an older version of this Policy on file for your review.

9. How to contact us

       If you have any questions, comments or complaints about our Privacy Policy, or wish to contact us, please do so as follows:

       email：privacy@sjcam.com

       Normally, we will respond within 30 business days.

       If you are not satisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you may also file a complaint or report to the regulatory authority in your area.

       This version of the Privacy Policy was updated on【12, December】2023, and will become effective on【12, December】2023. Click to review older versions of the Privacy Policy.