DoLynk Care Privacy Policy
Last modified: 2023/11/21
Introduction
Dahua Europe B.V. (“Dahua,” “we,” or “us”), as the data controller of DoLynk Care product, respects your privacy and is committed to protecting it through our compliance with this DoLynk Care Privacy Policy (the "Policy"). This Policy describes the types of information, including but not limited to personal data, we may collect from you or that you may provide when you interact with us, use our application, and/or products or services in relation to DoLynk Care APP and DoLynk Care website (“Product”), including any subdomains and any content, functionality and services offered on, by or through it or them, or any other websites, e-mails, applications that link to this Privacy Policy (collectively referred to as “Services”). This Privacy Policy also describes how we collect, use, maintain, share, protect, disclose or otherwise process that information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.
The“Personal Data” or “Personal Information” specified in this Privacy Policy shall mean any information that identifies you or can, identify you directly or indirectly, in particular if in combination with another identifier of you.
Information We Collect About You, Purposes of Processing and Legal Grounds
We collect several types of information from and about users of our Services, including information that you directly provide to us and it identifies you personally, such as, without limitation, name, postal address, e-mail address and telephone number.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. We try to ensure that we only collect and hold personal data that we need for the services and products we are offering to you. Therefore, unless otherwise indicated in the table below, the provision of personal data is a requirement for us to enter into a contract with you or which is permitted by applicable laws. In case that you choose not to provide certain information, you might not be able to use partial services, but it will not affect your normal use of other functions of the Product.
Purposes of Processing:
· Registration of the Product
In order to access and use the functions of the Product, you may be required to register an account (“Account”) and you can use the Account information to login the Product and obtain our services. Certain services may only be used after our evaluation of your qualification. The Account information may include a user name, email address, password or any other information as part of our security procedures (“Account information”).
You represent and warrant that: (i) all required Account information you submit is truthful, accurate and complete. (ii) you will maintain the accuracy, security, and confidentiality of Account information; and (iii) your use of the Account does not violate any applicable law or regulation. You also acknowledge that your account is personal to you and agree not to provide any other person with access to these services or portions of them using your Account information. You agree to notify us immediately of any unauthorized access to or use of your Account information or any other breach of security by contacting us at support@cce-soft.com. You also agree to ensure that you exit from your account at the end of each session. You should use particular caution when accessing your account from a public or shared computer so that others are not able to view or record your Account information.
· Accessing the functions and services of the Product
When you use certain functions of the Product and obtain our services, including but not limited to Live View function, Video Recording function, Adding Product function, Product Delete function, Product Trust function, Product Lend function, Alarm Notification function, we may process your certain information, such as your email address, telephone number, Account information, Product Serial Number (“SN”), Mac address, IP address; Product model, personal address, Mobile time zone. We will only process your Personal Information when it is necessary. Refusing to provide such information may only result in your being unable to use certain function, but does not affect your normal use of the Product’s other functions.
· Managing your Account information and the Product information
For purpose of managing your Account information or the Product information on the Product, such as changing your account name, password, product model, cancel your account, etc., we may collect and process your personnel information such as your email address, your telephone number. We will only collect your personal Information when it is necessary. Refusing to provide such information may only result in your being unable to use certain function, but does not affect your normal use of the Product’s other functions.
· Processing your Orders and Communicate with you
For purpose of processing your orders from our product, for instance, cloud storage service orders, video access service orders, product operation and maintenance orders, we may process information such as Product Serial Number, messages and video records, your email address, your order number, etc., we will only process your personal information when it is necessary.
In order to communicate with you, provide you with information you request from us, answer your questions or handle your complaints, we may process your personal information such as your email address, your upload pictures etc., we will only process your personal information when it is necessary.
· Account Sharing Function
For purpose of promoting the experience when you using our services, we provide the Account Sharing Function which enables you to use the same account registered in this Product to login DoLynk Care APP/Website, DH Partner APP, dahuasecurity.comand License Management Platform (hereinafter collectively referred to “Applications”) and obtaining the relevant services thereof smoothly and seamlessly. We may process your Personal Information for implementing the Account Sharing function, such as your email address and mobile phone number and we will only process your Personal Information which is necessary.
· Device Lending Function
For convenience purpose of managing the Product, we provide you Device Lending function to allow you lending devices to the end users registered on DMSS Product for a specific period. You may cancel the Device Lending function at any time. By invoking the Device Lending function, you need to add devices and fill out the information of the installation project as well as the personal information of the end users, including the end users’ name, telephone number, email, address. You must obtain the end users’ consent to process their personal information and conclude agreements with the end users for using the Device Lending function. You shall be fully liable for the authenticity and accuracy of the end users’ personal information.
· Processing Permitted by Laws
We will obtain your explicit consent before processing your Personal Information unless there is any applicable law permits the processing without your consent.
1) Processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.
2) Processing is necessary for compliance with a legal obligation.
3) Processing is necessary in order to protect the vital interests of data subject or of another natural person.
4) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested.
5) 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 data subject which require protection of personal data, in particular where the data subject is a child.
6) Other lawfulness of processing as specified in applicable laws.
Cookies and Similar Technologies
As it is common practice with almost all websites, we may use cookies to store information on the Product. This allows the website to function properly and provide you with a good user experience. We will use essential cookies as it is necessary to provide you service and operate the website. We will use non-essential cookies under the condition of obtaining your consent. For further details related to the cookies, please review our Cookies Statement.
How We Protect Children’s Personal Data
The Product is not intended for children under 16 years of age, or equivalent minimum age in the relevant jurisdiction (refer to “Child” or “Children” below), and we does not knowingly collect Personal Information from Children. Children shall obtain the consent of your parents or legal guardians (“Consent of Guardian”) and carefully read this Policy before using this Product. If we acknowledge that the Product has collected or received Personal Information from a Child, without verification of Consent of Guardian, we will delete that Personal Information. If you believe we might have any Personal Information from or about a Child, please contact us at support@dolynkservice.com.
How Long We Store Your Personal Data
We will retain your personal data for no longer than it is
necessary for the purposes stated in this Privacy Policy or in so far as such
is necessary for compliance with statutory obligations.
To determine the appropriate retention period for personal data, we consider
the amount, nature and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal data, the purposes
for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements. In the
event where we cease our products or part or all of our services, we will
notify you and delete your personal data in concern or anonymize such
information within a reasonable period of time.
We might disclose your personal data with certain trusted third parties for the following reasons:
· To our subsidiaries and affiliates to provide you the services you have requested us for and for the purposes of our legitimate interests of customer relation management
· To forwarders/carriers and other business partners to the extent that we need to deliver your orders
· To IT services providers who offer support during our daily operations, such as the maintenance of digital databases
· To third party hotline service provided for receiving and following up on your request for after-sales
· To marketing services providers in order to provide you the services you have requested us for, such as receiving the news you have opted-in
· To a buyer or potential possible buyer of our business for evaluation and completion of transactional corporate matter.
All such third parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws.
We may also disclose your personal data:
· To comply with any court order, law or legal process, including to respond to any government or regulatory request or for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).
· To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
· If we believe disclosure is necessary or appropriate to protect the legitimate rights, property or our safety, our customers or others.
As regards the personal data we collected during your use of the Product, we use the services of cloud service providers, including: Alibaba Cloud Computing Co., Ltd for the regions associated with the data center in Singapore, Amazon Web Services. Inc for regions associated with the data centers in the United States and in Germany. Apart from that, we ensure you that we will not share such data unless you have explicitly consent to such sharing.
We have implemented appropriate technical and organizational measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. In the case of information leakage or other incidents involving information security, we will initiate contingency plans to prevent the wide spread of security incidents and inform you in the form of push notifications and announcements.
Third Party Suppliers and Their Services
To ensure you have a smooth browsing experience, you may receive content or network links from third party suppliers (hereinafter referred to as the third party) beside us and our partners. Except as otherwise expressly stated in this Policy, this Policy does not apply to situations where a third party independently provides services to you through our services, such as websites that may include the services we offer or other third parties’ sites that have a link to our services. Please note that if you use such third parties’ products and/or services (including but not limited to PayPal or other credit card payment services) and provide your personal information, your information will be handled in compliance with that third party's privacy statement or similar policies. We cannot control the privacy and data protection policies of the third parties, and the third parties are not bound by this policy. Before submitting personal information to third parties, please read carefully about the privacy policy of these third parties. You can choose whether to access links, contents, and services provided by third parties. We take no responsibility when your information was misused or improperly disclosed in such occasions. We will not be liable for the personal data processing activities independently conducted by third parties.
We are headquartered in the P.R. China and we operate globally. We have established subsidiaries in different regions around the world and we offer our services through the use of servers located in different countries. Currently, we have data centers in the United States, Germany and Singapore. For the purposes described in this Policy, your information may be stored and processed in these data centers in accordance with applicable law. As such, your information might be transferred outside the region and country you use our website and services, including to regions/countries outside the European Economic Area (“EEA”) which might have different legal rules and might not offer an adequate level of protection as determined by the European Commission. However, we have taken the necessary measures to ensure that your information is processed in conformity with the applicable laws and appropriate technical security measures are adopted to safeguard your privacy.
You can review and change your personal data by logging into your account on our website and visiting your account profile page. You may also send us an e-mail at support@dolynkservice.com to request access to, or require us to correct or delete any personal data that you have provided to us. You may also object to or request us to restrict your processing. If we process your personal data based on consent, you may withdraw your consent at any time by contacting us (refer to Contact Information below). A summary of your legal rights is set out below:
· Request access to your personal data (commonly known as a“data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you want to access your user name, email address and other information, you can go to the upper right corner of the web client and click on your username – Account Management. Forvideo, image, order, device and other service information related to your DoLynk Care account, you can go to “Sites” tab of the menu located at the left of the interface.
· Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you want to change your username，you can go to the upper right corner of the web client and click on your username – Account Management. If you want to change your email address, please contact our local team of the region where you are located or contact us via email at support@dolynkservice.com.
· Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no legal ground for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you want to delete the information such as email address, and password, or service information such as video, image, cloud record and alarm on your DoLynk Care account, you can delete your information by tapping on related data clear function button through “Me-> Personal Info->Delete Account”.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
For security reasons, we will take steps to authenticate your identity before providing access to your personal data. You also have the right to lodge a complaint with Dutch Personal Data Protection Authority.
We reserve the right to modify this Policy from time to time at our sole discretion. If we made material modifications to the Policy, we will notify you sending you an alert the first time you use the Product after making the changes. The date this Policy was last modified is identified at the top of the page. All changes are effective immediately when we post them and apply to all access to and use of the Product thereafter; provided, to the extent required by law, we will seek your affirmative consent prior to applying material modifications to this Policy on how we use or disclose Personal Information that we collected or received prior to the date of the modification. You are expected to check this Policy frequently, so you are aware of any modifications, as they are binding on you once you providing affirmative consent.
To
ask questions or comment about this Privacy Policy and our privacy practices,
please contact us via email at DH_Privacy@dahuatech.com,
or by mail at:
Dahua Europe B.V.
Louis Braillelaan 80, 2719EK Zoetermeer