QAMSONG TECHNOLOGY (HK) LIMITED. (hereinafter collectively referred to as "we" or "Qamsong") is committed to protecting your personal privacy. This "CamPal Privacy Policy" (hereinafter referred to as "this Policy") outlines how we handle personal information and protect information privacy during your use of the following services, products, and related mobile applications (collectively referred to as "Products").
• CamPal Mobile Application
When using our Products, please ensure to carefully read this Policy and understand the purposes and security measures for the collection and processing of your personal data, including how we use, store, share, and transfer personal data. This Policy also outlines how you can exercise your privacy rights over your personal data, such as access and deletion rights, through our instructions.
By agreeing to this Policy or by initiating and continuing to use our Products or services in an appropriate manner without expressing any objection to us through appropriate channels, we will consider it as your full understanding and acceptance of this Policy.
If you have any questions, comments, suggestions, or complaints during your reading, please contact us through the following information:
Customer Service: [ campal@163.com ]
In this Policy:
Personal Information: Refers to various types of information recorded electronically or otherwise that can be used alone or in combination with other information to identify an individual or reflect the specific activities of a particular individual.
Sensitive Personal Information: Includes personal biometric data and precise location information. When providing you with specific products or services that involve the collection of sensitive personal information, we will obtain your consent through prominent and clear notifications before collecting such information.
Smart Device: Refers to non-standard computing devices produced or manufactured by hardware manufacturers, featuring a human-machine interface and capable of transmitting information over wireless networks, including smart cameras.
Application: Refers to the mobile application developed by Qamsong, which enables end-users to remotely control smart devices and connect to the Internet of Things (IoT) platform.
To provide our services to you, we will request personal information necessary for such services. If you do not provide personal information, we may not be able to offer our products or services to you. For details on our data collection practices, please refer to the dynamically updated "List of Collected Personal Information" .
• Account or Profile Information: When you register or log into your account, we may collect your username and contact information such as your email address, phone number, and login credentials. During your interactions with our products, we may further collect your account nickname, profile picture, country code, language preferences, or timezone information.
If you choose to log in using a third-party account, we will obtain the account information shared by you (e.g., profile picture, nickname, location) and link it to your Qamsong account for quick login. We will use your personal information in accordance with our agreement with the third party, as well as the terms related to sharing personal information in the third party's privacy policy, and under the premise of compliance with relevant laws and regulations.
• Feedback: When you use the feedback and suggestion function in our products, we will collect your email address, phone number, and feedback content (including but not limited to files, images, videos, voice recordings, etc.) to promptly address your issues and device malfunctions.
Furthermore, depending on the specific application, product, or service, Qamsong will collect corresponding and necessary personal information to provide you with the products and services.
• Device Information: When you interact with our products, we automatically collect device information such as the device's MAC address, IP address, wireless connection information, operating system type and version, application version number, push notification identifiers, log files, mobile network information (including SSID, BSSID), clipboard content, app installation list, SD card root directory information, etc.
• Usage Information: During your interactions with our website and services, we automatically collect usage information related to visits, clicks, downloads, sent/received messages, and other activities on our website and services.
• Log Information: When you use our applications, system and exception logs may be uploaded, including your IP address, language used, operating system version, access date and time, etc.
Please note that individual device information and service log information are not identifiable to a specific individual. If we combine such non-personal information with other information to identify a specific individual, or use it in conjunction with personal information, during the period of combined use, such non-personal information will be treated as personal information. Except with your authorization or as otherwise stipulated by laws and regulations, we will anonymize or de-identify such information.
• Location Information: When you enable the location function of your mobile device through system authorization and use location-based services, we will collect and use your location information to facilitate the pairing of your application with smart devices. Additionally, when you use specific products or services, we may collect real-time precise or imprecise geolocation information about you. You can disable location services in your mobile device's system to stop us from collecting your location information.
• Basic Smart Device Information: When you use smart devices connected to our products or services, we may collect basic information about the devices, such as device name, device ID, online status, activation time, firmware version, upgrade information, WIFI name, WIFI signal strength, device battery level, etc.
• Information Reported by Smart Devices: Depending on the different smart devices you choose to connect with our products or services, we may collect information reported by your smart devices. For example, smart cameras may collect images or videos captured by them.
• Information for Alarm and Troubleshooting of Smart Devices: When you use devices connected to our products or services for voice calls, if enabled, you can communicate with smart devices at the camera end. We may collect information such as alarm time, alarm content, etc. To troubleshoot device issues, we may collect device operation logs. Access to camera, photos, and videos permissions: This permission is used for saving purposes.
For detailed information about our access to system permissions, please refer to[CamPal Application Permission Usage List].
We may collect encrypted International Mobile Equipment Identity (IMEI) and Media Access Control (MAC) addresses, along with phone models, system ID numbers, and software crash logs, to count the number of users of our products, analyze product usage, investigate crash causes, reduce crashes, and continuously improve our products. This information does not involve your personal identity or other private information.
The purposes for which we process your information are as follows:
• To Provide Services to You: We process your account and personal profile information, device information, usage information, location information, and smart device-related information to provide the products and services you request. The legal basis for this processing is to fulfill our contract with you in accordance with our terms of use.
• To Improve Our Services: We process your device information, usage information, location information, and smart device-related information to ensure the functionality and security of our products, develop and improve our products and services, analyze our operational efficiency, and prevent and track fraud or misuse. The legal basis for this processing is to fulfill our contract with you in accordance with our terms of use.
• Non-Marketing Communications: We process your personal information to send you important information related to services, terms/conditions and policy changes, and/or other administrative information. As this information is important, you may not be able to opt out of receiving such emails. The legal basis for this processing is to fulfill our contract with you in accordance with our terms of use.
• Compliance: We may process your personal information when we believe it is necessary or appropriate to (a) comply with applicable laws and regulations (b) comply with legal proceedings (c) respond to requests from public authorities and government agencies (d) enforce our terms and conditions (e) protect our operations, business, and systems (f) protect the rights, privacy, safety, or property of us and/or other users, including you and (g) seek available remedies or limit damages that we may need to provide.
We may also use your personal information in other ways, and we will provide specific notifications at the time of collection and obtain your consent in accordance with applicable laws. If there are any changes to the purpose of processing your personal information, we will notify you of such changes via email and/or prominent notices on our website, and inform you of your options regarding your personal information.
According to relevant laws and regulations, the collection and use of your personal information does not require your authorization or consent in the following circumstances:
(1) Related to our fulfillment of obligations stipulated by laws and regulations
(2) Directly related to national security and national defense
(3) Directly related to public safety, public health, and significant public interests
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments
(5) Necessary to safeguard the vital legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the authorization or consent of the individual
(6) The personal information involved is voluntarily disclosed by the personal information subject to the public
(7) Collecting your personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels
(8) Necessary for signing and fulfilling contracts upon the request of the personal information subject
(9) Necessary for academic research institutions to conduct statistics or academic research based on public interests, and when providing the results of academic research or descriptions externally, the personal information contained in the results is de-identified
(10) Necessary for maintaining the safe and stable operation of XXX products and/or services, such as detecting and addressing product or service failures
(11) Other circumstances stipulated by laws and regulations.
If you are a minor user over 14 years old, please carefully read and agree to this policy under the accompaniment and guidance of your legal guardian. You and your legal guardian shall bear responsibilities in accordance with laws and this policy. Once a minor uses CamPal products and/or services, we consider it as having the consent or guidance of the legal guardian. CamPal does not provide services to children under 14 years old. If we inadvertently collect personal information from children under 14 years old, we will delete it immediately.
We protect the personal information of minors in accordance with relevant national laws and regulations, and will only collect, use, store, share, transfer, or disclose minors' personal information when permitted by law, with the consent of the legal guardian, or when necessary to protect the minors. If we discover that we have collected minors' personal information without prior verifiable consent from their guardians, we will endeavor to delete the relevant information as soon as possible.
If you have any questions about our practices and protection measures for collecting minors' personal information, you can contact us through the contact information disclosed in this policy.
To ensure that you can promptly receive push notifications, some SDKs (such as push notification SDKs) integrated into our APP have the capability to automatically launch, which may lead to autonomous app behaviors. The frequency of these automatic launches is defined by the SDK vendors and may result in multiple auto-starts.
To provide you with more comprehensive and high-quality products and services, certain functions may be provided by our technical service partners. We may entrust these partners to process some of your personal information. For companies, organizations, and individuals entrusted to process your personal information, we will sign stringent confidentiality agreements with them, clarifying both parties' responsibilities, processing matters, processing periods, processing nature, and processing purposes. We require them to handle personal information solely in accordance with our requirements, this policy, and any other relevant confidentiality and security measures.
Qamsong shares your personal information only in ways that you are aware of. We share your personal information with the following participants. For details on our data sharing practices, please refer to ["Third-Party Personal Information Sharing List]:
(1) We disclose your personal information to third-party service providers who offer us certain business-related services, such as website hosting, data analysis, payment and credit card processing,infrastructure provisioning, IT services, customer support services, email sending services, and other similar services, to ensure they can provide services to us.
(2) To ensure the stable operation of Qamsong services or to achieve related functions, we may incorporate software development kits (SDKs) provided by third parties. We conduct rigorous security checks on the application program interfaces (APIs) and SDKs through which authorized partners access relevant information, and agree with authorized partners on strict data protection measures, requiring them to handle personal information in accordance with this policy and any other relevant confidentiality and security measures.
(3) We disclose your personal information to customers and other business partners who directly or indirectly provide you with smart devices and/or networks and systems for accessing and using our websites and services.
(4) We disclose your personal information to our subsidiaries or affiliated companies for regular business activities.
We will not transfer your personal 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 personal information to other parties.
(2) Compliance with Laws, Regulations, Legal Proceedings, or Compulsory Governmental or Judicial Requirements.
(3) In the case of mergers, acquisitions, or bankruptcy liquidations involving the transfer of personal information, we will require the new entity holding your personal information to continue to be bound by this policy. Otherwise, we will request that the company or organization obtain your authorization and consent anew. In such cases, you will receive clear notifications via email and/or our website regarding ownership changes, incompatible new uses of personal information, and related personal information choices.
We will only publicly disclose your personal information in the following circumstances:
(1) After obtaining your explicit consent
(2) Disclosure based on law: We may publicly disclose your personal information in accordance with laws, legal procedures, litigation, or mandatory requirements from government authorities.
Pursuant to laws and regulations, we are not required to obtain your prior authorization or consent for sharing, transferring, or publicly disclosing your personal information in the following circumstances:
(1) Related to our fulfillment of obligations stipulated by laws and regulations
(2) Directly related to national security and defense
(3) Directly related to public safety, public health, and significant public interests
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments
(5) Necessary to safeguard your or other individuals' vital legitimate rights and interests, such as life and property, but difficult to obtain authorization or consent from the individual
(6) Personal information that you have voluntarily disclosed to the public
(7) Collecting personal information from legally and publicly disclosed sources, such as legitimate news reports and government information disclosure channels
(8) Necessary for fulfilling contractual obligations upon the request of the personal information subject
(9) Necessary for maintaining the secure and stable operation of the products or services provided, including detecting and addressing faults in products or services
(10) Other circumstances stipulated by laws and regulations.
We attach great importance to the security of your personal information. We have adopted multi-layered protection measures, including security technology measures that meet industry standards, as well as corresponding organizational structures and management systems, to minimize the risk of your personal information being leaked, damaged, misused, accessed without authorization, disclosed or altered without permission. Specifically:
We implement commercially reasonable physical, administrative, and technical safeguards to maintain the integrity and security of your personal information. Qamsong provides various security assurance strategies to effectively ensure the information security of users and devices.
In terms of device access, we utilize Qamsong's proprietary algorithms to ensure data isolation, access authentication, and authorization requests.
In data communication, we support secure algorithms, transmission encryption protocols, and commercial-grade information encryption transmission based on dynamic keys.
In data processing, we adopt rigorous data filtering, validation, and a comprehensive data review process.
In data storage, all confidential information of users is securely encrypted for storage.
In addition to the aforementioned technical safeguards, Qamsong has also established a series of security measures at the institutional and management levels, such as designated roles and responsibilities, conducting safety and privacy protection training courses, enhancing employees' awareness of data protection, and controlling access permissions to prevent data loss, unauthorized use, unauthorized access, leakage, tampering, or destruction.
If a security incident occurs that affects your personal information security, we will promptly notify you through the email address, phone number, or message center push notification you have provided, and inform you of suggestions to reduce or prevent related risks. When necessary, we will follow our internal security incident emergency response plan, take timely remedial measures, and report to relevant authorities as required.
If, for any reason, you believe that your interactions with us are no longer secure (for example, you believe that the security of your Qamsong account has been compromised), please immediately notify us by sending an email to [ campal@163.com ] .
We store personal information collected within China's territory. If, due to business needs, personal information needs to be transmitted or stored outside China, we will first obtain your authorization and consent, and strictly comply with national laws and regulations related to cross-border transfer of personal information.
We will process your personal information for the shortest period necessary to achieve the purposes outlined in this policy, unless longer retention is required by specific legal requirements. We determine the appropriate retention period based on the quantity, nature, and sensitivity of the personal information. Upon expiration of the retention period, we will destroy your personal information. If we are unable to destroy the information due to technical reasons, we will take appropriate measures to prevent further use of your personal information.
In the following circumstances, we may change the storage time of personal information to comply with legal requirements:
(1) Compliance with applicable laws, regulations, and other relevant provisions
(2) Compliance with court judgments, rulings, or other legal procedures
(3) Compliance with requirements from relevant government agencies or legally authorized organizations
(4) Protection of the personal and property safety of ourselves, our customers, users, or employees
(5) Other legitimate interests that reasonably necessitate such retention.
In the event of cessation of operations due to business strategies or other reasons, unless otherwise required by laws and regulations, we will notify you of such circumstances, cease the collection of your personal information, and delete or anonymize the collected personal information.
We respect your rights and have access to your personal information. You can exercise any of the following rights:
• Through "My > Help & Feedback" in our application
• By sending an email to [ campal@163.com ] .
You do not need to pay any fees to exercise your personal rights. If your account service is in mainland China, we will respond to your request within 15 working days.
If you decide to send a request to us via email, please specify which information you wish to change, whether you wish to delete your personal information from our database, or any restrictions you wish to impose on the use of your personal information. Please note that, for security reasons, we may require you to verify your identity before further processing your request.
You can:
• Request to query and access the personal information we process related to you: You can access your personal information via "My > My Information"
• Request to correct inaccurate or incomplete personal information related to you: You can correct your personal information via "My > My Information > Avatar/Nickname/Password"
• *** Request to delete your personal information: You can email [ campal@163.com ], and we will delete your personal information within 15 working days
• *** Request temporary or permanent restrictions on our processing of some or all of your personal information
• *** Request that we process your information based on your consent or contracts signed with you, and that we transfer your personal information to yourself or a third party when we process it automatically
• Object to or refuse our use of your personal information when we use it based on your consent or our legitimate interests.
• Close your account: You can close your account via "My > Settings > Close Account". After clicking to destroy, we will destroy your user information within 15 working days on our server.
• *** Withdraw consent: You can withdraw your consent via "My > Settings > Privacy Policy Management > Withdraw Consent". After clicking to withdraw consent, we will withdraw the privacy agreement and user agreement you have agreed to within 15 working days on our server and destroy your personal information.
Within the bounds of the law, you may copy your personal information and request its transfer to a designated personal information processor. You may also request an explanation of our rules for handling your personal information. To exercise these rights, please contact us through the contact information published in this policy.
Under the following circumstances, in accordance with legal and regulatory requirements, we will be unable to respond to your request:
(1) Those related to our fulfillment of obligations stipulated by laws and regulations.
(2) Those directly related to national security and defense security.
(3) Those directly related to public safety, public health, and significant public interests.
(4) Those directly related to criminal investigation, prosecution, trial, and execution of judgments.
(5) Where there is sufficient evidence indicating subjective malice or abuse of rights on your part.
(6) Where it is necessary to safeguard the vital legitimate rights and interests of you or other individuals, but it is difficult to obtain your authorization.
(7) Your request exceeds the scope that can be covered by general technical means and commercial costs.
(8) Responding to your request would result in serious harm to the legitimate rights and interests of you or other individuals/organizations.
(9) Those involving trade secrets.
We strengthen the protection of deceased individuals' personal information in accordance with the relevant provisions of the Personal Information Protection Law of the People's Republic of China. After the death of a CamPal user (limited to natural persons), their close relatives may, for their own legitimate and just interests, contact us through the contact information published in Chapter X of this policy to exercise rights such as accessing, copying, correcting, and deleting the relevant personal information of the deceased user, unless the deceased user had made other arrangements before their death.
We may update or modify this policy from time to time, and such changes constitute a part of this policy. However, without your explicit consent, we will not diminish the rights you are entitled to under this policy.
Please carefully read the contents of the revised policy. If you disagree with this policy or have objections to the modifications or updates, you may choose to cancel your account and cease using CamPal products and/or services. However, please note that your actions and activities before your account cancellation or cessation of using our services are still subject to this policy.
We will publish any changes to this policy on this page or notify you in other ways. For significant changes, we will provide more prominent notifications. In such cases, if you choose to continue using our services, it indicates your agreement to be bound by the revised policy.
Significant changes referred to in this policy include but are not limited to:
(1) Significant changes to our service model, such as the purpose of handling personal information, the types of personal information processed, and the ways personal information is used
(2) Changes to the main objects of personal information sharing, transfer, or public disclosure
(3) Significant changes to your rights and the ways to exercise them in personal information processing
(4) Other changes that may have a significant impact on your personal information rights and interests
(5) Changes in the situation of personal information going abroad.
If you have any questions about our practices or this policy, please contact us through the following methods:
QAMSONG TECHNOLOGY (HK) LIMITED
Mailing Address: No. 475 Changhe Road, Changhe Street, Binjiang District, Hangzhou City
Customer Service: [ campal@163.com ]
If your account service is within Mainland China, we will respond to your inquiry within 15 working days.
This policy is subject to the current laws and regulations of the People's Republic of China. Any disputes related to this policy shall be resolved through mutual consultation between the parties. If the dispute cannot be resolved through negotiation, you agree to submit the dispute to the people's court with jurisdiction in the location where CamPal is actually operated.