General

Thank you for your interest in Shenzhen Zhencheng Technology Co., Ltd. and its affiliated companies (“SJCAM”, “we”, or “us”) and in the various hardware, firmware, software, websites, applications, and services provided by us and on which a link to this Privacy Policy (this “Policy”) is displayed (each, a “Product” or “Service” and, collectively, the “SJCAM Products and Services”).  This Policy describes:

The information that we gather from you

How we use and share this information

The rights and choices you have regarding this information

The steps we take to protect this information

The limitations of this Policy regarding third party websites and content

How we transfer your information

How we may change this Policy, and how you may contact us

By using SJCAM Products and Services, you consent to the privacy practices described in this Policy. This Policy is incorporated into and is subject to the Terms of Use for the SJCAM Products and Services you use.

Information Collected

Information We Collect on the SJCAM Products and Services

User-provided Information. When you use SJCAM Products and Services, you may provide us with information about you, including your name, email address, mailing address, mobile phone number, and payment information (if you use SJCAM Products and Services to engage in purchases or financial transactions). You may provide us with information in various ways when using SJCAM Products and Services. For example, you provide us with information when you register for a SJCAM account, use SJCAM Products and Services, submit credentials or other information for account verification, or send us customer service-related requests using SJCAM Products and Services or other means of communication.

Cookies and Automatically Collected Information. When you use certain SJCAM Products and Services, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device.  We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies, you may not be able to utilize the features of SJCAM Products and Services to their fullest potential. We may use third party cookies as well. SJCAM does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use SJCAM Products and Services.

We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons.” This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use a Product or Service, the pages or other content you view or otherwise interact with on a Product or Service, and the dates and times that you visit, access, or use SJCAM Products and Services. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you. Our use of cookies and other automatically collected information is explained further in our Cookie Policy.

Device-Related and Use-Related Information.  When you use SJCAM Products and Services, you will provide us with information relating to (i) your SJCAM Product or Service, your non-SJCAM device on which the SJCAM Product or Service is used (including computers, phones, or other devices where you install or access SJCAM Products and Services), and your photos or videos that you upload using SJCAM Products and Services.  This information may include: (i) information about your non-SJCAM device (including your device ID, hardware version, and operating system); (ii) information about your SJCAM device (including the model and serial number of your device); (iii) geolocation data relating to your non-SJCAM device and SJCAM device and any photo or video you submitted using SJCAM Products and Services; (iv) information about any photo or video recorded, including the name of the video file, the length of the video, EXIF data relating to the photo or video, and the photo or video data itself; (v) other technical information, including the IP address used by your non-SJCAM device and use record data; and (vi) data associated with your SJCAM account.

Third Party Web Beacons and Third Party Buttons. We may display third-party content on or through SJCAM Products and Services, including third-party advertising. We also may enable you to connect your SJCAM account to, or otherwise interface with, third party services, including third party social networks and communications services.  In addition, we may implement third party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by SJCAM. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies.

For further information, please review our Cookie Policy.

Information from Other Sources. We may obtain information from third parties and sources other than SJCAM Products and Services, such as our business partners, contractors, advertisers, and other third parties.

Uses of Collected Information

How We Use the Information We Collect We use information we collect through SJCAM Products and Services in a variety of ways in providing the SJCAM Products and Services and operating our business, including the following:

We use the information that we collect through SJCAM Products and Services to operate, maintain, enhance and provide features of the SJCAM Products and Services, to verify and manage SJCAM user accounts, to provide services and information that you request, to respond to comments and questions and otherwise to provide support to users, and to process and deliver entries and rewards in connection with promotions that may be offered from time to by SJCAM.

We use the information that we collect through SJCAM Products and Services to understand and analyze the usage trends and preferences of our users, to improve the SJCAM Products and Services, and to develop new products, services, features, and functionality.

We may use your information to contact you for administrative, informational, and marketing (where you have consented) purposes.  This may include providing customer service or sending communications, including updates on promotions and events, relating to products and services offered by us and by third parties we work with.  We will ask for your consent to send you marketing communications. You may withdraw your consent at any time and we will no longer send you marketing communications.

We may use information we collect to: (i) personalize SJCAM Products and Services; (ii) provide customized advertisements, content, and information (where you have consented); (iii) monitor and analyze the effectiveness of SJCAM Products and Services and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) review your entries, submissions, and status in any promotions or other activities involving SJCAM Products and Services (where you have consented).

Why We Are Entitled To Use Your Information We are entitled to use your information in these ways because:

we have legal and regulatory obligations that we have to discharge;

we may need to in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or

the use of your personal data as described is necessary for our legitimate business interests (or the legitimate interests of one or more of our affiliates).

When We Disclose Information We will not disclose your information that we collect through SJCAM Products and Services to third parties except as described in this Policy or as we disclose to you at the time the information is collected. We may disclose information to third parties in the following circumstances:

We may share your information with our parent company, affiliates and subsidiaries globally in order to provide you with SJCAM product and services.

Any information that you voluntarily choose to upload to a publicly accessible site or venue using SJCAM Products and Services, or that you elect to make public, will be available to anyone who has access to that content, including other users.

We work with third party service providers to provide payment facilitation, parcel transportation, application development, hosting, maintenance, environment data, account verification, and other services for us. We require these service providers to use or disclose the information they process on our behalf only as necessary to perform services on our behalf or comply with legal requirements.

We may preserve and disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena, warrant or request, or to otherwise cooperate with law enforcement or other governmental agencies.

We also reserve the right to preserve and disclose your information that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the SJCAM Products and Services and any facilities or equipment used to make the SJCAM Products and Services available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

SJCAM uses a third party verification service provider to verify certain users of SJCAM Products and Services and SJCAM may disclose information to this service provider. The service provider may retain credential information provided as part of account verification for compliance and other purposes and may provide such information, as well as your user login ID or email address, to government authorities, law enforcement agencies, regulatory agencies and other duly authorized parties as may be required by or permitted under applicable laws. We require this service provider by contract to use or disclose the information they process on our behalf only as necessary to perform services on our behalf or comply with legal requirements.

If you consent to our disclosure of information to a third party, such as business partners, or as otherwise authorized under applicable law.

Information about our users, including information you provided and any information collected through SJCAM Products and Services, may be disclosed and otherwise communicated to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

We may make certain aggregated, de-identified, or non-identifying information about users of SJCAM Products and Services available to third parties for various purposes, including (i) compliance with various reporting obligations; (ii) for business or marketing purposes; (iii) product safety analysis; or (iii) to assist such parties in understanding our users’ interests, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality of SJCAM Products and Services.

When We May Transfers Your Information Outside The European Economic Area The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside of the EEA who work for our affiliates or for one of our suppliers. Where we transfer your information outside the EEA, we will ensure that it is protected in a manner that is consistent with how your information will be protected by us in the EEA. This can be done in a number of ways, for instance:

the country that we send the information to might be approved by the European Commission;

the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your information; or

where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme.

In other circumstances the law may permit us to otherwise transfer your information outside the EEA. In all cases, however, we will ensure that any transfer of your personal data is compliant with data protection law.  You can obtain more details of the protection given to your information when it is transferred outside the EEA (including a copy of the standard data protection clauses which we have entered into with recipients of your personal data) by contacting us in accordance with the “Our Contact Information” section below.

Rights Regarding Collected Information

Your Rights and Choices you have regarding this information Subject to applicable law, you may have the right to request access to and receive information about the information we maintain about you, update or correct inaccuracies in the information we maintain about you, and have the information blocked or deleted, as appropriate. Your right to access information we maintain about you may be limited under local law. You also have the right to object to the processing of your information or to withdraw your consent to our processing of information about you, including to the transfer of information to other countries. Note, however, that if you exercise your right to object or your rights of blocking or deletion, if you decline to share certain information with us, or if you withdraw your consent to our processing of information about you, we may not be able to provide to you some, or any, of the features and functionality of SJCAM Products and Services. Please note, however, that even if you have withdrawn your consent to our processing of your information, we may still be entitled to process your information if we have another legitimate reason (other than consent) for doing so and that there may be circumstances where you ask us to erase your information but we are legally entitled to retain it. You may also have a right to the right to request that we restrict our processing of your information in certain circumstances. Again, there may be circumstances where you ask us to restrict our processing of your information but we are legally entitled to refuse that request. In some circumstances, you may have the right to receive some of your information in a structured, commonly used and machine-readable format and/or request that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to information which you have provided to us. You also have the right to lodge a complaint with the data protection regulator if you think that any of your rights have been infringed by us.  You may update, correct, or delete certain SJCAM account information and preferences by accessing your account preferences page, available through certain SJCAM Products and Services, including the sjcam.com and certain SJCAM mobile applications (including the “SJCAM Zone” App). If you wish to access or amend any other information we hold about you, you may contact us at support@sjcam.com. Likewise, if you close your SJCAM account, you will not be able to sign in to SJCAM Products or Services or access any of your information. However, you can open a new account at any time. Please note that while any changes you make will be reflected in active user databases within a reasonable period of time, we may retain all information you submit, as authorized under applicable law, for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies. If you receive commercial email or text messages from us, you may unsubscribe at any time by following the instructions contained within the email or text message. You may also opt out from receiving commercial email or text messages from us by sending your request to us by email at support@sjcam.com. Retention of Your Information How long we hold your information for will vary. The retention period will be determined by various criteria including:

the purpose for which we are using it – we will need to keep the information for as long as is necessary for that purpose; and

legal obligations – laws or regulation may set a minimum period for which we have to keep your information.

Third-Party Services SJCAM Products and Services may contain features or links to websites and services provided by third parties. Any information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through SJCAM Products and Services. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through SJCAM Products and Services.  Children’s Privacy SJCAM Products and Services are not directed to children under the age of 15. We do not knowingly collect information from children under the age of 15 without obtaining parental consent.

Data Security

We use certain physical, organizational, and technical safeguards that are designed to improve the integrity and security of information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable and thus we cannot and do not guarantee that your information will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards. International Visitors and Users SJCAM Products and Services may connect to servers hosted in the United States, China, and Hong Kong, where applicable. If you choose to use SJCAM Products and Services from the European Union or other regions of the world, then please note that you may be transferring your information outside of those regions for storage and processing. Also, we may transfer your data from the U.S., China, and Hong Kong to other countries or regions in connection with storage and processing of data, fulfilling your requests, and providing the services associated with SJCAM Products and Services. By providing your information on or through SJCAM Products or Services, you consent to such transfer, storage, and processing.

Policy Changes and Updates

Changes and Updates to this Policy Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available on or through the SJCAM Products and Services, and indicate the date of the latest revision. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. Your continued use of SJCAM Products and Services after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.  Our Contact Information Please contact us with any questions or comments about this Policy or our data practices by email at support@sjcam.com.  Shenzhen Zhencheng Technology Co., Ltd. Address: 3/F, Building C, NO.2 ,Road 1, Shangxue Industrial Area, Bantian Street, Longgang District, Shenzhen, China (Post Code: 518129).

Cookie Policy

What are Cookies? When you use certain SJCAM Products and Services, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Service. Please review your web browser

“Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies, you may not be able to utilize the features of SJCAM Products and Services to their fullest potential. We may use third party cookies as well. For instance, we use Google Analytics to collect and process certain analytics data. SJCAM does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use SJCAM Products and Services. We may also automatically record certain information from your device by using various types of technology, including “clear gifs” or “web beacons” (together with cookies, “cookies and similar technologies”). This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use a Product or Service, the pages or other content you view or otherwise interact with on a Product or Service, and the dates and times that you visit, access, or use SJCAM Products and Services. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information is gathered from all users, and may be connected with other information about you. Cookies Used by SJCAM We use different types of cookies as listed below. They help us to provide and improve our service, such as showing you the most relevant information and your customized web page. Some or all of the cookies listed may be stored in your browser or devices. Authentication These cookies and similar technologies will tell us when you log into our website, and allow us to show you appropriate and relevant information and features. For example, these cookies and similar technologies will enable us to show you relevant social information when you are logged in and visiting other websites adopting SJCAM advertising plugin. We also use this information to understand how you use SJCAM Products and Services. Security These cookies and similar technologies help keep SJCAM Products and Services secure and reliable. They enable security features and detect activities violating the Terms of Use and policies, such as unauthorized login and fraudulent use of our Products and Services. For example, when someone logs into your account from a browser or IP address different from the cookies record, you will get notified and will be able to deny such person’s access to your account. Also, these cookies and similar technologies will record requests for information from the Internet and block attacks such as attempts to steal your user content uploaded to SJCAM websites. Localization These cookies and similar technologies help us provide localized experiences, such as showing the website content in your preferred language. Features, Services These cookies and similar technologies help us deliver Products and Services. For example, these cookies and similar technologies could pre-fill your user ID when you logging in, show your friends who are online, and store your preferences to provide you customized content and experiences, such as personalized suggestions. Performance These cookies and similar technologies help us improve user experience. For example, these cookies and similar technologies help us reallocate work load among our servers. Also, they store some information on your browser or device to enable our web page to respond faster. Analytics, Research These cookies and similar technologies help us understand your use of our Products and Services to improve them. For example, we may use these cookies and similar technologies to understand how you engage with SJCAM Apps and websites to improve their features. Cookies Use when You Use Mobile Devices Some mobile devices share the same features with computers, such as the support of full-featured browsers. When you are using this type of devices such as smart phones, we use cookies in a similar way to when you are using computers. Other devices may use different technologies, such as local storage, Software Development Kits (SDKs), or Advanced Programming Interfaces (APIs) to facilitate aforementioned processes effectuated by cookies.  We may obtain or receive information about your device, our apps, or other apps. We may also use these technologies to store information on your device. For example, we may receive information about the make and model of your mobile device when you are asking others for help through our app.  Read of Particular Cookies Browsers will send cookies for a particular domain (such as sjcam.com) to the website each time a device with those cookies accesses content from that domain. This means if your device stores cookies for sjcam.com, it will send those cookies to SJCAM when it accesses a webpage at sjcam.com.  Cookie Use Without an SJCAM Account or After Your Logout We still use cookie if you do not have a SJCAM account or have logged out your account. After your logout, we will use cookie to:

Identify and terminate accounts in violation of Terms of Use or SJCAM policies;

Recover your lost account;

Recognize use of public computers and notify to reduce your risk of data theft;

Understand your interaction with our Products and Services, and those of our partners.

If you do not have SJCAM account and have visited sjcam.com, we will use cookie to protect SJCAM Products and Services, and SJCAM customers from malicious activity such as denial-of-service attacks and mass creation of fake accounts.