Introduction

We,Shenzhen Kandao Technology Co., Ltd., recognize the importance of your personal information and consider it an important social responsibility to safely and appropriately handle your personal information. We comply with applicable laws, regulations and guidelines on the protection of personal information, and as a business handling personal information, establish, implement, maintain and improve a personal information protection management system to properly protect your personal information.

This privacy policy (“Privacy Policy") applies to the websites operated by us, Kandao Technology Co., Ltd. (“Our Website”) and where we do not have a separate privacy policy for specific websites or services, etc. For the privacy policy of Kandao's meeting series products, please refer to "Privacy Policy for Kandao Meeting Series Products and Services".

1.Please carefully read and fully understand this Privacy Policy before using any products/services of Kandao Technology. Once you use or continue to use our products/services of Kandao Technology, you agree that we may use and process your information in accordance with this Privacy Policy.

2.We will post any revisions or modifications to this Privacy Policy on Kandao’s official website. We reserve the right to revise this Privacy Policy at any time, so we recommend that you review this Privacy Policy frequently. If we make a material change to this Privacy Policy, we will notify you in accordance with any applicable legal obligation by e-mail or via notice on the Kandao’s official website or via push notification in our mobile app before the alteration takes effect. If you continue to use our services, you will be regarded as accepting our revised privacy policy. We will regularly update our software applications, like our mobile and desktop applications, for improvements, including those able to better serve your privacy rights. To ensure this Privacy Policy accurately reflects your usage of Services, you will need to ensure that you are using the latest version of the Kandao’s software applications.

3.You shall understand that we will collect, use, process and store your personal information in accordance with the revised Kandao Privacy Policy only after you have confirmed and agreed to such revised version; you have the right to reject it, but please be aware that your such rejection may prevent you from continuously using part or all of the services and functions associated with Kandao Technology, or from enjoying the services we intend to offer.

4.Unless otherwise agreed, the terms used in this Policy have the same meanings as those in the Kandao User Service Agreement.

We will comply with the existing laws and regulations and handle your personal information appropriately based on legal and legitimate means and in good faith. If you have any questions about this Policy, you may contact us through information posted on our platforms.

I. Information we collect

We may collect and use your personal information in the following contexts:

1. Registering as a Kandao user

To create your account, you may need to provide the following information to Kandao Technology: cellphone number, email, user name and password.

During the registration or after the account is built, it helps us for better service and experience if you provide additional information, such as your name, birthday, gender, location, career field. If you refuse to do so, you will still be able to use the basic functions of our products and services.

2. Purchasing and delivering products or services

If you purchase our products or services, you need to provide the following information for successful transaction: your name, cellphone number, email, postal address, ID card number, bank card number and other information required for the order. If you refuse to do so, you cannot purchase our products and services.

3. Using products or services of Kandao Technology

• When using our products or services, you may need to provide the information, including the serial number of the Kandao products you purchased, the permission to access the videos and photos of your mobile phone, the geographical location information of your device, the hardware model of the device, the version number of the operating system , sensor information, device identifiers (for Android device, such as IMEI, AndroidID, OAID, IMSI, ICCID, GAID, MEID, for iOS device such as IDFV, IDFA, SN; Different identifiers vary in whether the validity period can be reset by the user and how it is obtained.), mobile phone application installation list, etc. We may also collect network device hardware address (MAC address), IP address, WLAN access point (such as SSID, BSSID), Bluetooth, software version number, network access method, type, status, network quality data, operation, usage, service logs, and SIM card serial number, etc.
• At the same time, we will also record the information you fill in when you receive our customer service or participate in our events, including your name, cellphone number, email, home address and questionnaire, so that we can provide you with our services.
• In order to trace and supervise the problems and services of our products, we may keep the information involved in your communication via email or our website, such as the records of conversations between both parties.
• Some hardware devices (such as cameras) of Kandao Technology have geolocation function that enables you to automatically associate your location with the contents you created on our hardware devices. On such devices, we will seek your consent before activating such geolocation function. If with your permission, that location of any content you create on our hardware device will be the same as the location where the content was created, which is embedded in the content file. If you no longer want to use such function, you can ban it in the settings of your hardware device of Kandao Technology.

How we use the personal information we collect

Kandao Technology will use the personal data collected for the following purposes:

1. Improvement of product experience

As discussed in this Policy, we will know how users take advantage of our functions and services or which types of advertisements they prefer via information we collect, so that we can offer personalized contents and advertisements, and we will also improve the overall product experience through research and analysis.

2. Business operation

We will use the collected information for various business operations, such as detection of security incidents, prevention of malicious, deceitful, fraudulent or illegal activities, and people responsible for the mentioned activities will be prosecuted. We will also use such information to maintain your account, and conduct the debugging to identify and fix errors that cause damage to the services.

3. Product information, social media marketing content, special preferences and updates

Once you subscribe to our information, we will occasionally send you emails about products, services, special promotions, competitions, customer satisfaction surveys, events, etc. But by clicking the "Unsubscribe" link in the received email, you can reject them.

4. Personalized service

We may combine personal information from a certain service with information from other services to provide you with more personalized services, such as using, sharing, or disclosing for allowing you to have a wider social circle.
We have the right to collect and use your personal information without your consent in the following circumstances:

• Circumstances involving national security, national defense security.
• Situations involving public safety, public health, and significant public interest.
• Cases involving crime investigation, prosecution, trial and execution of judgments.
• For the purpose of safeguarding the life, property and other significant legitimate rights and interests of you or other individuals but where it is difficult to obtain your consent.
• Where the personal information involved is disclosed to the public by the subject of the personal information or the guardian himself/herself.
• Personal information collected from legitimate public disclosures, such as legitimate news reports, government information disclosure and other channels.
• Necessary to enter into and perform a contract at your request.
• Necessary for maintaining the safe and stable operation of our products and/or services, such as the detection and disposal of product and/or service failures.
• Necessary for legitimate news reports.
• Necessary for academic research institutions to conduct statistical or academic research in the public interest and to de-identify the personal information contained in the results when providing the results of academic research or descriptions to the public.
• Circumstances where it is necessary for us to perform our statutory duties or legal obligations.
• For other circumstances specified by laws and administrative regulations.

Your personal information may contain sensitive privacy, such as your racial or ethnic origin, religious beliefs, personal health, sexual orientation, etc., and you may upload or publish such privacy through public channels when you use our products or services. Please handle this kind of privacy carefully.

For the above information provided by you, we are authorized to continue to use it when you use Kandao Technology’s products and services. We will stop using such information and delete it when you cancel your account. Regarding to storage time of the information, we shall comply with requirements otherwise prescribed by laws and regulations.

The above information will be stored within territory of the People's Republic of China. If cross-border transmission is required, we will conduct a safety assessment in accordance with the requirements of laws and regulations.

We will seek your prior express consent when we want to use your personal information for purposes other than those stated in this Policy, or when personal information collected for a specific purpose is used for other purposes.

Cookie and similar technologies

1. Cookie

To ensure that the website works properly, we will store small data files named Cookie on your computer or mobile device. Cookies typically contain identifiers, site names, and some numbers and characters. With the Cookie, the website can verify your identity information, secure your data and services, store data including your preferences or goods in your shopping basket, and provide you with better products and services.

We will not use Cookies for any purpose other than those stated in this Policy. You can manage or delete cookies based on your preferences. You may eliminate all cookies saved on your computer, while most of web browsers are set with the cookies-blocking function. However, if you do this, you need to change your settings personally every time you visit our website. For more information on how to change browser settings, please visit the introduction page of each browser's official website.

2. Similar technologies

In addition to Cookies, we may use other similar technologies such as website beacons and pixel tags on the website. For example, the email we send to you may contain a URL that links to the content of 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 website beacon is usually a transparent image embedded into a website or email. With the help of the pixel tags in the email, we can learn whether the email is open. If you do not want your activities to be tracked in this way, do not click on the picture or text link in your email or unsubscribe from our mailing list at any time.

How we use SDK

To provide and optimize our services, our Apps may be embedded with the third-party SDKs. These third-party SDKs can cooperate with us to provide you with more comprehensive services, and may collect your personal information at the same time. We will take the necessary measures to control the collection and use of your personal information by such third-party SDK to ensure that your personal information is effectively protected. For details of the identity of third parties, purpose of collection and links to third parties' privacy policies, please refer to the Third-party SDK Description in Annex I to this Policy.

II. How we deal with children's personal information

Our products, websites and services are mainly for adults. Children may not create their own user accounts without the consent of their parents or guardians.

In cases where personal information about children is collected with parental consent, we will only use or disclose this information as permitted by law, with express consent of parents or guardians or as necessary for the protection of children.

Although the definition of a child varies in line with local laws and customs, we regard anyone under the age of 14 as a child.

If we find that we have collected personal information from children without obtaining provable prior consent of the parents, we will seek to delete the relevant data as soon as possible.

III. How you manage your personal information

In accordance with relevant laws, regulations and standards of China, as well as the prevailing practices of other countries and regions, you are guaranteed to exercise the following rights with respect to your personal information:

1. Access to your personal information

You have the right to access your personal information in accordance with laws and regulations. You can access to the data in the following ways:

Account Information - If you want to access or edit profile information and payment information of your account, change your password, add security information, or close your account, you can do this by accessing the pages of profile, change password and other pages on our website or app. However, due to security and identity considerations or mandatory provisions of laws and regulations, you may not be able to modify the information that you provided when you initially registered as our user. If you are unable to access to the personal information in the manner described above, you can email us at: service@kandaovr.com or contact us in the manner provided on the website or app at any time.

2. Correct your personal information

You shall have the right to request us to make corrections when you find that there is an error in your personal information we processed. You can email us at: service@kandaovr.com or contact us in the manner provided on the website or app at any time.

3. Delete your personal information

You may make a request to us to delete personal information in the following cases:

• Our collection and use of personal information is in violation of laws and regulations.
• We have handled personal information in violation of the agreement with you.
• We will make a request to entities, which obtained your personal information from us, to delete such information immediately in case that we decide to delete it as you request, unless otherwise provided by laws and regulations, or these entities are authorized by you independently.
• After you or we help you delete relevant information, we may not be able to immediately delete the corresponding information from the backup system due to the applicable laws and security technologies. We will securely store your personal information and for further processing and isolation, until the backup information can be cleared or anonymized.

4. Cancel personal information account

You can cancel your registered account at any time by sending an email to service@kandaovr.com.

Upon cancellation of the account, we will cease to provide our products or services and, upon your request, delete your personal information unless otherwise provided by laws and regulations.

5. Constrain automatic decision-making of information system

In some business functions, we may only make decisions based on non-human automatic decision-making mechanisms such as information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you shall have the right to request us for an explanation, and we will provide appropriate remedies.

6. Respond to your aforesaid request

For security purposes, you may need to provide a written request or otherwise certify your identity. We may require you to verify your identity before processing your request.

If you are dissatisfied, you can also complain or report it to the regulatory authorities for cyberspace, telecom, public security and industry and commerce.

For your reasonable requests, we do not charge in principle, but we will charge a certain cost for repeated requests that exceed reasonable limits. We may refuse the requests that are unwarrantedly repetitive, require excessive technical means (the need to develop new systems or fundamentally change existing practices), pose a risk to legitimate interests of others, or are very impractical (involving information stored on backup tapes).

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

• Directly related to national security or national defense security.
• Directly related to public safety, public health, and significant public interests.
• Directly related to crime investigation, prosecution, trial and execution of judgments, etc.
• Where there is sufficient evidence that you have subjective malice or abuse of rights.
• Where responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations.
• For the purpose of safeguarding the life, property and other significant legitimate rights and interests of you or other individuals but where it is difficult to obtain your consent.
• Where trade secrets are involved.
• Circumstances where it is necessary for us to perform our statutory duties or legal obligations.

IV. How we protect your information

1. We attach importance to the security of your personal data. We have taken administrative, technical and personal security measures to prevent others from accessing, damaging or modifying your information without authorization. Despite our best efforts, there are no security measures that cannot be penetrated completely.

2. The Internet is not an absolutely safe environment, and emails, instant messaging, and communication with other users of Kandao Technology are not encrypted. We strongly recommend that you do not send personal information in such a way. Please use complex passwords to help us keep your account safe.

V. How we store your personal information

The information and data collected by us regarding you will be kept on the servers of our Company and/or our affiliates, which may be transmitted to and accessed, stored and displayed in your country, region or location where we collect the information and data.

We will store your personal information collected in the People's Republic of China (hereinafter referred to as "China") in accordance with the laws and regulations.

Due to that we provide products or services through global resources and servers, this means that, with your consent, your personal information may be transferred to, or accessed from, the jurisdictions outside the country/region where you use the products or services.

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

We will only store your personal information in the shortest time necessary for the purposes stated in this Policy throughout the period of providing you with our platform service, unless otherwise provided by law or with your consent. Your personal information will be deleted or anonymized beyond the aforementioned personal information storage period. In addition, personal information derived from cancelled accounts will be retained in accordance with the provisions of law or for the purpose of resolving disputes, troubleshooting, supporting any investigation, and for the purposes of implementing this clause and other agreements and other actions permitted by law.

VI. Intellectual property rights license and declaration

You have rights to your personal information in accordance with the law. In order to provide you with the services you use, and to maintain and improve those services and optimize the quality of our services, and in regard to texts, pictures, videos and other contents (excluding personal information) protected by the intellectual property rights, which you provide on our platform, you agree to grant a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license for us and for our affiliated companies to use, reproduce, modify, adapt, publish, translate, distribute, perform and display your submitted data, or to create derivative works on our platform.

Unless otherwise agreed or stated by Kandao, all intellectual property rights (including but not limited to copyrights, trademarks, patents, trade secrets, etc.) and relevant rights in all contents (except contents copyrighted by users in accordance with law), technologies, software, programs, data and other information (including but not limited to texts, images, pictures, photographs, audio, video, graphics, color, layout, electronic files) on our platform shall be owned by Kandao or its affiliates. No one shall use the aforesaid rights without Kandao’s permission (including but not limited to reproduction, distribution, display, mirroring, upload, download, modification or renting).

The Logo, "Kandao", "QooCam" and other words, graphics and combinations thereof, as well as other logos, symbols, product and service names of our platform are trademarks of Kandao or its affiliates in China or other countries. Without written authorization from Kandao, anyone shall not display, use or otherwise deal with them in any way, or indicate to others that you have the right to display, use or otherwise deal with them.

Kandao has full intellectual property rights to the proprietary contents, original contents and other proprietary or exclusive contents obtained through licensing. Without permission from Kandao, no unit or individual shall reprint or distribute our contents, or provide viewing services, or otherwise infringe upon Kandao 's intellectual property rights, or else such unit or individual shall bear all relevant legal liabilities. Please contact us immediately in the event of finding any infringement, and we will handle it promptly.

VII. How to report a security vulnerability:

If you discover a security vulnerability while using our products, please report the vulnerability details to us as soon as possible at service@kandaovr.com.Please include the following information in your report to help us better understand the nature and scope of the reported issue:

• The names and version numbers of the products you believe are impacted by the vulnerability.
• Environment or system information used to reappear the problem (e.g. product model, OS version, and other relevant information).
• Step-by-step instructions to reappear the vulnerability.

VIII.How to deal with the vulnerability report:

We will process your feedback as soon as possible. After investigating and verifying the reported vulnerability,we will strive to formulate corresponding solutions for the product and release it within 90 days.

IX. How to contact us

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

• 1. For specific questions relating to the software or user's personal account (including obtaining your own personal information), please send an email to service@kandaovr.com.
• 2. For general enquiries or complaints on privacy issues, please send an email to service@kandaovr.com or write to the following address: 2nd Floor, West Building, Building M7, Sino Steel Building, Zhonger Avenue, Science Park, Yuehai Sub-district, Nanshan District, Shenzhen, Guangdong Province, China.

If you are dissatisfied with our reply, especially if our handling of your personal information has damaged your legitimate rights and interests, you can also complain or report it to the regulatory authorities for NetInfo, telecommunications, public security as well as industry and commerce.

Disclaimer:

All of Kandao app's use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

We strictly adhere to the principle of protecting user privacy and do not collect, store, or share any user data with artificial intelligence models or algorithms. We also do not use any AI models or algorithms to process user data.

Last updated: February 18, 2024