Tscloud Labs Inc. (“we”, “us”, “our” or “TSCloud”) is committed to protecting the users of its websites, mobile applications, products, and services (each a “TSCloud Service” and collectively the “TSCloud Services”). When you access, browse, or use the TSCloud Services, information will be collected, transferred, processed, stored, and disclosed in accordance with this privacy policy (“Policy”). This Policy governs the information collection and disclosure practices for the TSCloud Services. By accessing, browsing, or using the TSCloud Services, including registering an account with our TSCloud Services, you expressly consent to the collection, transfer, use, processing, and storage of your information (including personal information), as described in this Policy. IF YOU DO NOT AGREE WITH THIS POLICY OR THE INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES DESCRIBED IN THIS POLICY, DO NOT USE THE TSCLOUD SERVICES OR REGISTER AN ACCOUNT.

1. INFORMATION COLLECTION PRACTICES

1.1. General. When you visit TSCloud websites and use TSCloud mobile applications without registering, you can browse without submitting personal information about yourself. If you register for an account within or to access a TSCloud Services, we will collect some personally identifiable information from you, including your username, email address, and hashed version of the password you select. When you interact with the TSCloud Services, we also receive and store certain additional types of information which, in general, do not directly identify you. For example, we automatically receive and record information on our server logs from your browser or device including your IP address, browser type and language, referring/exit pages and URLs, device type, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time. This Section of the Policy outlines the various ways that information is collected from the TSCloud Services. Please fully review this Policy before you use the TSCloud Services or submit information to us.

1.2. Information that You Provide.

(a) Registration and Login. Certain TSCloud Services require you to register for an account and/or log in using credentials. You can register for an account from our account registration system or a third-party site or service such as Facebook (“Account”). When you register for an Account you may be asked to provide some personally identifiable information, such as your email address, phone number, camera SN code and a username and password that you select. When you are asked to create an Account using your credentials from a third-party site or service, you will be asked for your username, password, and other information to verify that you have an account with the third-party site or service. When you provide credentials for a third-party site or service, we may use those credentials to obtain information about you from that third party. See Section 1.4 (Information from Other Sources) and 3.5 (Social Sites) for more information. When you register an Account and log in to a TSCloud Services you must provide your current, complete, and accurate information. It is your responsibility to keep your information up to date. We are not responsible for any problems, interruptions in access, or liability that may arise if you do not give us complete and accurate information or if you fail to update your information so that it is current.

(b) Product Set Up. In order to use certain products such as our camera products, you will need to associate the product with your Account following the directions provided with the product. When you associate a product with your Account you will need to provide Wi-Fi network information (this may include username and password) to TSCloud mobile applications (“TSCloud App” or “TSCloud Apps”). The TSCloud App will send the information to the product by using QR code and the product will use the information to connect to the Wi-Fi network. Once a product is associated with your Account it will remain associated until you unbind the product from your Account or terminate your Account. The Wi-Fi network user name and password may be saved in your TSCloud Apps or your TSCloud products but it will not be sent to TSCloud services or TSCloud.

(c) Correspondence. If you send us personal correspondence, such as emails or letters, about your use of the TSCloud Services, we may save the information in a profile specific to you.

(d) Information You Provide to Others. You may choose to share information with third-parties such as social networking Sites like Facebook and WeChat (“Social Sites”) by “sharing” videos and photos. See Section 3.5 (Social Sites) for more information.

1.3. Automatically Collected Information. We will collect some information about you and any product or device you use to access or use the TSCloud Services automatically using a variety of technologies. In general, automatically collected information about the use of TSCloud Services does not directly identify you and the information may include your diagnostic log information, IP address, browser type and language, referring/exit pages and URLs, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, the actions performed in the TSCloud App, the info(OS type/version, network, etc.) of the phone which the TSCloud App was installed, and the date and time. We collect this information for the purposes described in this Policy, including to better understand our customer base and to improve the quality of our TSCloud Services. We do NOT collect information not related to the use of the TSCloud services.

(a) Video Transmission. The primary mode of transmission of video from our camera products to our TSCloud Apps is through a point-to-point direct connection. When encountering unreliable point-to-point network conditions, the camera product may opt to relay videos through our servers to the mobile app to achieve optimal viewing experience. In each scenario, both videos and the transmission channel are securely encrypted. The role of our servers is only to act as a relay agent, and they do not store video content transmitted to or through them in connection with our provision of TSCloud Services.

(b) Activity Alert Video/Picture. This is an optional feature, and off by default, and user needs to manually activate this feature in the TSCloud App before transmission happens. Turning this feature OFF will NOT affect the normal operations of Camera and its TSCloud App. If the user chooses to turn on this feature, a short video up to 10 seconds long and one or more pictures are encrypted individually and transferred to and stored on our servers when the camera has detected activity, provided that you have activated the “activity alerts” functionality within the TSCloud App for camera product. If you don’t delete the videos stored on our servers, they shall be automatically deleted on a regular basis (typically seven days). However, we cannot ensure that residual copies do not survive elsewhere (e.g., in a cache or backup).

(c) Cookies. A cookie is a small text file that is stored on a user’s computer or mobile device. We and our third-party analytics provider use cookies to record information about your activities on the TSCloud Services to “remember” you when you return to the TSCloud Services. Some cookies remain on your computer or device until you delete them. Others, like session ID cookies, expire when you close your browser. You may set your browser setting to attempt to reject cookies and you may still use the TSCloud Services. See the section “Do-Not-Track-Settings” below for more information on how the TSCloud Services may respond to your browser settings. We do not control the use of cookies by third parties. See Section 4 (THIRD-PARTY PROVIDERS) for more information and review the privacy policies of all third-party providers for more information on third-party cookies.

(d) Pixels (aka web beacons/web bugs/JavaScript). Pixels are tiny graphics with a unique identifier that are used to track how the web page is accessed. Unlike cookies, which are stored on a user’s computer hard drive, pixels are small graphics that are about the size of the period at the end of the sentence that are embedded invisibly on web pages or in HTML-based emails. Our third-party analytics provider uses information obtained from pixels to help us improve our TSCloud Services. We do not control the use of pixels by third parties. See Section 4 (THIRD-PARTY PROVIDERS) for more information and review the privacy policies of each of the third-party providers for more information on third-party pixels.

(e) Video/Picture Content. In general, TSCloud does not view, monitor or in any way see your video or picture content except with your permission and authorization and only in regard to technical support issues.

1.4. Information from Other Sources. With your permission, we may obtain both personal and non-personal information about you from business partners, Social Sites, and other third parties and add it to our account information or other information we have collected. We also collect information from Social Sites when you register or log in to use our TSCloud Services by using your Social Site log-in and password. For example, our Site allows you to create an account and log in using your Facebook account credentials and, in addition to allowing you to log in to the Site and share videos with Facebook, we also use your authorization to obtain the following information from Facebook: Facebook username, first name, last name, and profile picture. The information we collect may depend on the privacy settings you have with the Social Site, so please consult the Social Site’s privacy and data practices.

2. USE OF INFORMATION

2.1. General. We may use your personally identifiable information (including tracking information) to manage your Account. We may also use it to operate, maintain, and improve the TSCloud Services (including providing you a more personal experience); communicate with you; provide you information about products and TSCloud Services (including products and services of third parties); market; research purposes; resolve disputes; collect fees owed; detect and protect against errors, fraud, and criminal activity; assist law enforcement; enforce this Policy and any the terms related to our TSCloud Services; and any other purpose described in this Policy or that we describe to you at the time of collection.

2.2. Email Communications. We may use your personally identifiable information to send you emails or other communications related to your Account or the TSCloud Services, or in response to your inquiries or requests. You may not opt-out of receiving service-related messages that are not promotional. We may also send you marketing emails, surveys, or newsletters to notify you about products or services that may be of interest to you. If you would like to stop receiving marketing emails from us, please click on the unsubscribe link at the bottom of any marketing email you receive. [MO用1] You can opt out of marketing email in this way but you will continue to receive service related emails as they are a fundamental part of the services.

2.3. Non-identifying Information. We may use non-identifying information for any lawful purpose, including analyzing trends, research, TSCloud Services administration, tracking users’ movements around the TSCloud Services, and to improve our business and the TSCloud Services.

2.4. Retaining Your Information. In general, we will retain your information as long as legally required or allowed. If you cancel your Account or your Account is otherwise terminated, we may but are not obligated to, delete information we have collected or obtained from third parties and we may continue to use and disclose it in accordance with this Policy. But you can delete your account information manually, and it will be purged from our system.

2.5. Transfer of personal information outside of your jurisdiction. To the extent that we need to transfer personal information outside your jurisdiction, whether it is transferred to our affiliates (these may include communications, social media, technology, or cloud services) or to third-party service providers,we shall do so in accordance with the applicable laws. In particular, in order to ensure that all such transfers comply with applicable local data protection law, we will implement appropriate security safeguards. You will have the right to be informed of the appropriate safeguards taken by TSCloud for this transfer of your personal information. For example, if you choose to use other third-party services available for this product or service (such as Amazon, Google, etc.), those third parties may be able to read information about you, information about you may also be transferred to a third-party server outside of your jurisdiction, and you agree to this kind of transfer.

TSCloud is a China-headquartered company operating globally. As such, complying with applicable laws, we may transfer your personal data to any affiliates of the TSCloud group worldwide when processing that information for the purposes described in this Privacy Policy. We may also transfer your personal data to our third party service providers, who may be located in a country or area outside the area of the European Economic Area (EEA).

Whenever TSCloud shares personal data originating in the EEA with a third party which may or may not be a TSCloud entity outside the EEA, we will do so on the basis of EU standard contractual clauses or any other safeguards provided for in the GDPR.

TSCloud may use overseas facilities operated and controlled by TSCloud App to process or back up your personal information. TSCloud currently has data centers in the United States. These overseas jurisdictions may or may not have data protection laws similar to the data protection laws in your jurisdiction. You have understood that the risks under applicable data protection laws are different and wWe may transfer and store your personal information in one of our overseas facilities; however, this does not change our full commitment to protecting your personal information in compliance with this Privacy Policy.

For example, iIf you choose to use other third-party services available for this product or service (such as Amazon, Google, etc.), those third parties may be able to read information about you, information about you may also be transferred to a third-party server outside of your jurisdiction, and you agree to this kind of transfer.

3. INFORMATION SHARING

3.1. General. We will not sell or rent any of your personal information to third parties for marketing purposes. However, we may disclose your information to any affiliated entity or organization and to agents and service providers. We may also share non-identifying information with third parties for any lawful purpose, including analyzing trends, research, TSCloud Services administration, tracking users’ movements around the TSCloud Services, and to improve our business, products, and the TSCloud Services. Use of information by affiliated entities and organizations will be subject to this Policy or an agreement that is at least as restrictive as this Policy. For information on the use of information by agents and service providers see Section 4 (THIRD-PARTY PROVIDERS).

3.2. Legal Requirements. In some cases, we may disclose your personally identifiable information as required by law; if we believe that disclosure is needed to protect our rights; to government regulators; to law enforcement authorities; in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the TSCloud Services; and to respond to a physical threat to you or another person.

3.3. Insolvency and Business Transitions. If we ever file for bankruptcy or engage in a business transition such as a merger with another company or if purchase, sell, or reorganize all or a part of the TSCloud Services or our business or assets, we may disclose your personal information, including to prospective or actual purchasers in connection with one of these transactions.

3.4. Camera Sharing. Some of the TSCloud Services permit you to share access to our camera products that you own with others. If you share access to your camera by authorizing a third party on your Account, the third party will be permitted to access that camera and to record videos from that camera until you remove them from your Account. We encourage you to exercise discretion and caution with respect to enabling third party access your cameras because we do not control the actions of any third party and cannot stop them from sharing videos obtained from your camera with others.

3.5. Social Sites. In addition to using Facebook credentials to set up an Account, certain TSCloud Services may permit you to choose to share information and videos taken with our camera products with Social Sites. When you choose to share with a Social Site, we may share that video or information as well as additional personal information about you with the Social Site. Information shared with a Social Site is subject to that Social Site’s privacy policy and practices, you should familiarize yourself with the Social Site’s privacy policy and practices before sharing.

3.6. Disclaimer. We cannot ensure that all of your personal information will never be disclosed in ways not otherwise described in this Policy. For example, we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the TSCloud Services. No transmission of data over the internet can be 100% secure.

4. THIRD-PARTY PROVIDERS.

4.1. General. We use third parties to help us operate and improve the TSCloud Services. We may provide these third parties information we collect and they may collect information from you and about your use of the TSCloud Services. We may provide information we collect to third parties and it will, unless specifically noted otherwise in this Policy, be governed by this Policy and may only be used by those third parties to help us operate or improve our business or the TSCloud Services and provide services to us. We do not control information collected by third parties and are not responsible for their use of that information. Please review their privacy policies for more information on their information collection, use, and sharing practices.

4.2. Google Analytics. We use Google, a third-party analytics provider, to collect information about TSCloud Services usage and the users of the TSCloud Services, including demographic and interest-level information. Google uses cookies and pixels to collect demographic and interest-level information and usage information from users that visit the TSCloud Services, including information about the pages where users enter and exit the TSCloud Services and the pages users view on the TSCloud Services, time spent, browser, operating system, and IP address. Cookies and pixels allow Google to recognize a user when a user visits the TSCloud Services and when the user visits other websites. Google uses the information it collects from the TSCloud Services and other websites to share with us and other website operator’s information about users including age range, gender, geographic regions, general interests, and details about devices used to visit websites and purchase items. We do not link the information we receive from Google with any of your personally identifiable information. For more information regarding Google’s use of cookies, pixels, and collection and use of information, see the Google Privacy Policy.

5. ONLINE TRACKING AND YOUR CHOICES

As discussed above, because we and our third-party service providers automatically collect TSCloud Services usage information through the use of cookies, pixels and other tracking technologies (including as described in the “Automatically Collected Information” section above, and otherwise in this Policy), your selection of the “Do Not Track” option provided by your browser may not have any effect on our automatically collected information. One way to attempt to “opt out” of the collection of any information through cookies and some (but not all) other tracking technology is to actively manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult and may not be possible. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.

6. INFORMATION SECURITY MEASURES

Keeping secure personal information that we collect is of great concern to us. While we have mechanisms in place to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. When you provide information to the TSCloud Services, you do so at your own risk.

7. CHILDREN

The TSCloud Services are intended for general audiences and are not directed to children under 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information without parental consent, please contact us by using the contact information in the Privacy Questions section at the bottom of this Policy, and we will take steps to remove the information and terminate the child's Account.

8. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

If you would like to cancel your Account or update your personally identifiable information associated with your Account, you may make such changes by logging in TSCloud Apps. If you do not want your information accessed or stored as described in this Policy, you should not access, use, or register an Account with the TSCloud Services.

9. MODIFICATION OF THIS POLICY

We will occasionally update this Policy. We recommend that you check our TSCloud Services from time to time to inform yourself of any changes in this Policy or any of our other policies.

10. PRIVACY QUESTIONS

If you have questions or concerns about our privacy practices, please contact us.