DoLynk Care Privacy Policy

Last modified:2026/01/30

Introduction

Dahua Europe B.V., DAHUA TECHNOLOGY (HK) LIMITED and our affiliates (“Dahua”, “we”, “us” or “our”), as the data controller of DoLynk Care product, respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (the “Policy”). This Policy describes how we process your personal data when you use the application and/or website of DoLynk Care (the "Product"), or use the service(s) as provided by us or our affiliates in connection with the Product (the “Service”). For specific usage or service scenarios, we may release a dedicated privacy policy to describe how to process your personal data and exercise your rights.

If you are located in the regions of the European Union and the United Kingdom, Dahua Europe B.V. is responsible for operating the Product and shall be the data controller when processing your personal data. For data subjects located in other regions apart from the European Union and the United Kingdom, DAHUA TECHNOLOGY (HK) LIMITED is responsible for operating the Product and shall be the data controller.

Please read this Policy carefully to understand our policies and practices regarding your personal data and how we will treat it. If you have any issues regarding this Policy, please contact us at supportoverseas@dahuatech.com.

Table of contents

1. How We Process Your Personal Data and Purpose of Processing

2. How We Share, Assign and Disclose Your Personal Data

3. Third Party Products and Services
4. How We Protect and Retain Your Personal Data
5. How We Protect Children’s Personal Data
6. International Transfers
7. Your Rights
8. Changes to Privacy Policy
9. How to Contact Us

1. How We Process Your Personal Data and Purpose of Processing

We may process several types of data from you, including data that identifies you personally, such as personal name, physical address, e-mail address and telephone number, etc. (“Personal Data”). We may also process data that is about you, but individually does not identify you, such as demographic data, data about your internet connection, the equipment you use to access our services and usage details. You have right to choose whether or not to provide the data we requested. However, we may not be able to provide you relevant services if you reject to provide your personal data.

1) Personal data processing details

Activity	Type of Data	Processing Purposes	Lawful Basis for Processing
When you sign up with the Product for the first time	User name; email address; country or region; password (encrypted); profile photo (if uploaded);	To allow us complete your registration, communicate with you and administer your account. Profile photo may be uploaded from local photo album in your mobile phone on a voluntary basis if you desire to have a more personalized account, omission to do so, does not affect the running of the Product.	Consent
When you add Compatible Device (refers to certain Dahua brand device)	Device SN; Device model; Wi-Fi info; Device Name; Device password (encrypted); Device time zone and DST status	To process your request to add a device to your account and allow configuration of your device. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of the Product’s other functions.	Consent
When you use Live View function which provides you a real-time video display	Device SN; Device IP; Device Port Information; (real time) Video Stream	To provide you with the basic services of video display through the Product.	To perform contract with you and provide you services
When you use Video Recording functions	Device SN, Device’s Channel ID, Record Files Path, (real time) video stream	To store your history record and allow you view it.	Consent
When you activate and configure the settings of the added Compatible Device	Mac address; IP address; Device SN; Device model; Device firmware version; Country information (via IP address); Device location (via IP); Date of Device register; Device channel information; Device offline/online status; Device configuration information	To allow activation of your Device and its registration with our server.	Consent
When you set Device name and cover image	Cover image; Device name; Channel information; Device model; Device SN	You can set device name, change cover image, and view channel name, device model and SN. The processing of such information is needed for us to allow the changes you have required for and to inform you about the details of the Device added on your account of the Product. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of the Product’s other functions.	Consent
When you enter Device password or use the reset function	Device SN; original password (encrypted), your email address (if you have pre-configured an email address on the Device reset password via email); IP address (if you reset password via DoLynk Care APP)	To allow you enhance the security of your Device by adding a password or reset your password; to send verification codes and reset the password as you request; to trace and identify the device from which the reset request is initiated (if you request). Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of the Product’s other functions.	Your legitimate interests and provide you services;
When you use Delete Device function	Device SN; Email and (or) telephone number (only of customers who sign up with DoLynk Care App via their telephone number).	To allow the removal of the Device from your account on DoLynk Care App and matched accessory as you requested us for. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of DoLynk Care App’s other functions.	Consent
When you subscribe alarm notification service	Device SN; Push notice ID/alarm snapshot	To send you alarm notifications and provide you the services you have requested us for.	To perform contract with you and provide you services
When you purchase services on the Product	Device SN; messages and video records; email address; order number	To process your orders from the Product.	To perform contract with you and provide you services
When you communicate with us through email or Feedback function	Email address; Text information and images of your communication with us.	To communicate with you, provide you with information you request about us, answer your questions or handle your complaints.	Our legitimate interests to communicate with you and reply your inquiries/comments
When you use device lending function	End user’s name, phone number, email, address	To allow you lend your devices to another user of the Product as requested by you. Refusing to provide such information may only result in your being unable to use this function, but does not affect your normal use of the Product’s other functions.	To perform contract with you and provide you services
When you use account sharing function	Email address; phone number	To allow you use the same account registered in this Product to login DH Partner APP, dahuasecurity.comand License Management Platform and obtaining the relevant services.	Consent
Statistical research	User ID，device ID, region, location, app version	In order to improve the Product features and enhance your user experience of the Product	Our legitimate interests and provide you services

2) Video and Audio Data

The Product allows you to access and view surveillance data captured or recorded by Compatible Device (as defined in the Terms of Use). “Surveillance Data” comprises (1) video (and in some cases audio) recordings or live feeds or streams and still photographic images; (2) readings or data from physical or virtual sensors (to the extent offered by or included with Compatible Device and supported by the Product), including motion detection sensors, event sensors, temperature sensors, window/door sensors, passive infrared sensors, water sensors, carbon dioxide sensors and ambient light sensors.

3) Processing in compliance with applicable laws

Apart from the detail activities specified above, we may process your personal data which is permitted or required by applicable laws:

Processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract.

Processing is necessary for compliance with a legal obligation.

Processing is necessary in order to protect the vital interests of data subject or of another natural person.

Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested.

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, in particular where the data subject is a child.

Other lawfulness of processing as specified in applicable laws.

2. How We Share, Assign and Disclose Your Personal Data

We may share, assign or disclose your personal data with our affiliated companies or third parties in the following circumstances:

1) Upon your explicit consent:

We may share, assign or disclose your personal data with third parties after obtaining your explicit consent or where you provide initiatively to us. You shall be fully responsible and liable for the personal data obtained from other resources or from other data subjects.

2) Trusted third parties:

We may share, assign or disclose your personal data with certain trusted third parties that perform business functions for us or provide services to us, being our subsidiaries and affiliates; or contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them：

· 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.

3) Required by applicable laws:

We may share, assign or disclose your personal data to comply with applicable legal requirements such as court order, legal process, including to respond to any government or regulatory authority’s request or for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).

4) Merger, acquisition or bankruptcy:

We may share, assign or disclose your personal data where there is a merger, acquisition or bankruptcy procedure. We will require the successor who holds your personal data to continue to perform the obligations in accordance with this Policy.

5) Public Interest:

We may share, assign or disclose your personal data for public interest purpose, such as to deal with public health emergencies, or, in case of emergency, to protect the health of natural persons and the safety of their property.

As regards the personal data we collected during your use of the Product, we use the services of cloud service providers. Apart from that, we ensure you that we will not share such data unless you have explicitly consent to such sharing.

3. Third Party Products and Services:

To facilitate transactions within our Application, we integrate a third-party payment service provided by [Oceanpayment Co., Ltd.] ("Payment Processor").

1) Purpose and Scope of Data Processing. When you initiate a payment, we transmit the information necessary to complete the transaction to our Payment Processor. This typically includes:

Transaction Details: Order ID, transaction amount, and currency;

Identification Data: Your name and contact information (if required for the transaction).

2) Independent Controller Status. Please be advised that the Payment Processor acts as an Independent Data Controller regarding the processing of your sensitive financial information. They collect this data directly from you via their integrated API or interface. This data may include, but is not limited to:

Credit/debit card numbers and CVV codes;

Bank account details and billing addresses;

Technical data required for fraud prevention and identity verification (KYC).

We do not store or have access to your full payment card numbers or security codes on our servers.

3) Legal Basis for Processing The transfer of your data to the Payment Processor is based on:

Performance of a Contract: To process your order and deliver the products or services purchased.

Legitimate Interests: To ensure secure payment processing, prevent fraudulent activities, and maintain accurate financial records.

4) Data Security and Compliance. All payment data transmissions are protected via industry-standard encryption (such as SSL/TLS). The Payment Processor is certified as compliant with PCI-DSS Level 1 standards. For detailed information on how the Payment Processor protects your data and the specific retention periods they apply, please contact the Payment Processor at: [Info@oceanpayment.com.cn].

4. How We Protect and Retain Your Personal Data

1) Data security measures

We attach great importance to the security of your personal data. We have taken appropriate physical, technical and management security measures to prevent your personal data from accidental losses and from unauthorized access, use, alteration and disclosure. For instance, we use encryption technology to improve the security of personal data and trusted protection mechanisms to prevent personal data from being maliciously attacked.

2) The retention of personal data

We will retain your personal data for no longer than it is necessary for the purposes stated in this Policy, unless otherwise extending the retention period is required or permitted by law. To determine the appropriate retention period for personal data, we may consider the amount, nature and sensitivity of the personal data, the potential risk from unauthorized 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 channels. If you want to learn more about the retention period of your personal data, you may directly contact us at supportoverseas@dahuatech.com.

5. How We Protect Children’s Personal Data

Our Product is not designed for children under 16 years of age, or equivalent minimum age in the relevant jurisdiction (refer to “Child” or “Children” below). If we become aware of any personal data related to Children, we will delete that Children’s personal data unilaterally, unless otherwise the processing is permitted by applicable law, explicitly consented by the Children’s parents or guardians, or deemed necessary for the protection of the Children.

6. International Transfers

Since we have affiliates around the world to offer you services and we may store your personal data on our servers located in different countries, including United States, Germany, and Singapore. In light of this, your personal data may be transferred outside the region or country where you use the Product or Service, which may have different legal rules and level of protection on personal data. In such circumstances, we will take necessary measures to ensure that your personal data is processed in conformity with the applicable laws, including obtaining your consent to the cross-border transfer of your personal data, signing standard contractual clauses approved by the EU Commission when necessary, and taking appropriate technical security measures to safeguard your personal data.

7. Your Rights

You can send us an email at supportoverseas@dahuatech.com to request exercising your rights in relation to your personal data. You may also object to or request us to restrict the processing of your personal data. If we process your personal data based on consent, you may withdraw your consent at any time by contacting us at supportoverseas@dahuatech.com. 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.

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.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data by entering into the page of Me-> Personal Info->Delete Account on the Product or contact us at supportoverseas@dahuatech.com, where there is no good reason 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 data unlawfully or where we are required to erase your personal data to comply with local law. However, for specific legal reasons, such as it is mandatory for us to retain your personal data as required by laws, we may not be able to comply with your request of erasure but we will notify you at the time of your request in such circumstance, if applicable.

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 personal data 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 data which you initially provided consent for us to use or where we used the data 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 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 the relevant Data Protection Authority.

8. Changes to Privacy Policy
We keep this Privacy Policy under review and may modify this Privacy Policy from time to time. If we make any changes to this Policy which may materially affect your rights or the way we process your personal data, we will provide you with reasonable prior notice through different channels, for example, by posting a pop-out notice on the Dolynk Care App/website. Unless otherwise stated, the updated Privacy Policy shall take effect on the indicated effective date.

9. How to Contact Us

If you have any questions or comment on this Privacy Policy or our privacy practices, please contact us through email at supportoverseas@dahuatech.com, or by mail at:

Dahua Europe B.V.

Louis Braillelaan 80, 2719EK Zoetermeer

DAHUA TECHNOLOGY (HK) LIMITED

13/F,GLOUCESTER TOWER, THE LANDMARK, 15 QUEEN'S ROAD CENTRAL,,CENTRAL HK