This Privacy Policy for YI Products and services (“Privacy Policy”) describes information that YI Technologies, Inc. and its subsidiaries and other group companies (collectively, “YI”, “we,” or, “us”) collect, use, share, or store, including personal information (i.e., information that directly or indirectly personally identifies you) or a combination of data that can be reasonably used to infer information about you (such as your email address or mobile phone IMEI).

This document focuses on information related to the operation of the following YI products and services: the YI Action Camera, YI Dash Camera, and YI Home Camera (collectively, “YI Products”). In this Privacy Policy, the expression “YI Products” also includes our Mobile App, PC App, and YI Cloud as defined in our Terms of Use.

This Privacy Policy should be read in conjunction with the Terms of Use of which it forms part and which also apply when you visit our website or use YI Products. If you do not agree with this Privacy Policy, you must not submit information to us through or in connection with the website or use YI Products.

How We Collect Data

We will collect and store your personal data when you interact with our website, when you contact us, request YI Products and services or when you use YI Products, as further detailed below. We collect personal information in writing, by telephone and by email.

International Transfers of Personal Data

Depending on your geographic location, your personal information may be collected, processed and stored by YI or its service providers in the United States and other countries. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country.

If you are using YI Products in the European Economic Area (“EEA”) please be aware that we may transfer your personal data to a third party in countries outside the EEA for further processing in accordance with the purposes set out in this Privacy Policy. In particular, your personal data may be transferred to the United States and other countries (including to Germany and Singapore) where YI operates and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact us for a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances. For transfers of data from the EEA to the United States or Singapore, YI (i.e., the controller) has entered into the European Commission’s Standard Contractual Clauses with its service providers (i.e., processors) to protect user’s privacy rights.

If you are using YI Products in other regions (outside of the EEA) with laws governing data collection and use that may differ from United States law, you consent to the transfer of your personal data to the United States and other countries (including to Germany and Singapore) where YI operates.

What information does YI generally collect?

Identity data – includes first name, last name, title, date of birth and gender.

Contact data – includes address, email address and telephone numbers.

Technical data – includes information about your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

If you are a customer of YI, personal data that we hold about you may include the same information listed in above, along with:

Business data – your function/job title within the company and your work email address, company’s name, postal address, VAT and/or company number.

Financial and transaction data – including bank account and payment card details as well as details about payments to and from you and other details of services you have purchased from us.

Marketing and communications data – where you have opted-in via your user preferences in your account settings, we hold details about your preferences for receiving marketing from YI and our third parties, your communication preference, your language and your social network accounts.

Specific YI Products collect specific additional data as further detailed below.

What information does the YI Action Camera and YI Dash Camera collect?

The YI Action Camera and YI Dash Camera collect:

• Setup information you provide

Information input during setup: When you set up a YI Action Camera or YI Dash Camera, you will be asked for certain basic information like your email address, your Facebook username, and your general location (e.g., city or country).

• Video and audio signals and data

Video and audio signals and data: When you use the recording feature of your YI Action Camera or YI Dash Camera, the recordings are stored on your camera and are not stored on a YI server without your intervention.

• Technical information from the device

Technical information from the device: In order to improve your experience over time, help troubleshoot problems you may encounter, and provide updates to YI Action Camera or YI Dash Camera, we store your device information, such as camera model and serial number, hardware and software versions, and mobile phone information like unique identifiers (including IMEI and MAC), operating system, crash logs, error logs, and language settings. In addition, we will collect your mobile phone’s IMEI and MAC numbers for logging you into and authenticating you to your YI Product or YI’s systems. Further, to improve your experience, we collect but do not associate your account or email with aggregated, non-identified, data on functions used and frequency of use.

• Shared content

Shared Content: YI Action Camera and YI Dash Camera users and authorized users tend to enjoy sharing certain content like video clips, images, captions, and comments with other people. Your content can be shared as directed by you or your authorized user through YI’s community website or third-party applications and services, such as Facebook or YouTube. Such third-party applications and services are not controlled by YI and have their own privacy and service policies. YI is not responsible for the privacy practices of any website or third-party applications and services that it does not own or otherwise control and you should read the privacy policies of websites, applications and services owned and controlled by others before deciding whether to proceed.

The content you share by placing it on YI Community is available for sharing for a limited time (e.g. 30 days or less) after which it is deleted from YI’s systems.

Data protection and privacy laws in your locality may impose certain responsibilities on you and your use of YI Products. You (not YI) are responsible for ensuring that you comply with any applicable laws when you use YI Products. Note that recording and sharing clips that involve other people may affect their privacy and data protection rights.

What information does YI Home Camera collect?

YI Home Camera collects:

• Setup information you provide

Information input during setup: When you setup a YI Home Camera, you will be asked for certain basic information like your email address, your Facebook username, and your general location (e.g. city or country).

• Video and audio signals and data

Video and audio signals and data: When you use the recording or streaming features of your YI Home Camera, we will record and process video and/or audio recordings received from your device, subject to your configuration and settings. If you have enabled motion sensing or sound detection, we will record and process video and/or audio recordings upon sensing motion or detecting sound and may send notifications to you regarding the sensed motion or sound. In addition, if you have the recording feature enabled, we will capture, process and retain video, photo, and audio data recordings received from your device for a limited time (for example, 7, 15, or 30 days, depending on your subscription) and you will be able to access, download, and delete those recordings using YI services during that time. After the subscription period, the recordings are deleted from YI’s systems.

• Technical information from the device

Technical information from the device: In order to improve your experience over time, help troubleshoot problems you may encounter, and provide updates to YI Home Camera, we store your device information, such as camera model and serial number, hardware and software versions, and mobile phone information like unique identifiers (including IMEI and MAC), operating system, crash logs, error logs, and language settings. In addition, we will collect your mobile phone’s IMEI and MAC numbers. This information is used to login and authenticate you to your YI Product. Further, to improve your experience, we collect but do not associate your account or email with aggregated, non-identified data on functions used and frequency of use.

• Saved and shared content

Saved and Shared Content: Your YI Home Camera can utilize the YI Cloud subscription service to store audio, camera, and video content during a selected subscription period (for example, 7, 15, or 30 days). After the subscription period, the content is deleted from YI’s systems. We have technical barriers to prevent unauthorized viewing or hearing your audio, camera, and video content, and we do not share your audio, camera, or video content. You may choose to download your content for sharing, including through a third-party application or service, such as Facebook or YouTube that is not controlled by YI and has its own privacy and service policies. YI is not responsible for the privacy practices of any website or third-party applications and services that it does not own or otherwise control and you should read the privacy policies of websites, applications and services owned and controlled by others before deciding whether to proceed.

Data protection and privacy laws in your locality may impose certain responsibilities on you and your use of YI Products. You (not YI) are responsible for ensuring that you comply with any applicable laws when you use YI Products. For example, you may need to display a notice that alerts visitors to your home that you are using a YI Product. Note that recording and sharing clips that involve other people may affect their privacy and data protection rights.

How does my YI Product or account interact with third parties?

Any YI data that you choose to share with a third party is governed by that third party’s privacy policy while in that party’s possession.

Any data that YI receives from third-parties (for example, information received from Facebook after you login to your Facebook account to share content) will be processed and stored by YI and will be treated in accordance with this Privacy Policy. This information may be processed in the same manner as any other data that is a part of your YI account or the YI logs.

What additional information does YI collect and store when a user connects a YI Product to the Internet or creates an account?

Wi-Fi Network Information: To connect your YI Product to YI services, including YI Cloud, or to access your YI Product over the Internet from a computer, a smartphone or a tablet, you may need to connect it to your Wi-Fi network. During setup, the YI Product will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with YI’s systems and download software updates.

Once connected to your Wi-Fi network, your YI Product regularly sends the data described in this Privacy Policy (excluding your Wi-Fi password) to YI to provide you with services.

Email Addresses: When you create a YI account, we collect and store your email address. From that point forward, your email address is used for communications from YI. In addition, YI may provide you with the ability to login with alternative credentials, such as a Facebook account.

Basic Profile Information: Your account allows you to provide certain basic profile information like a username of your choice and profile photo. Usernames and profile photos may be shown to others in connection with YI services. We routinely record log entries and technical information when your mobile device, tablet, PC, or YI Product contacts our systems.

How does YI use the information it collects?

We use this information to provide, develop and improve YI Products and services, including making assessments and recommendations about products or safety. We may use your contact details to send you this information, to ask you to participate in surveys about your YI use, and to send you other communications from YI.

We may also use this information in an aggregated, non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we use aggregated, non-identified information about the number of times users in a particular region use a particular function to help us determine if the function is desired by customers. We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

If you have agreed that we may do so, we may use your information to send you marketing via the communications methods you have selected via your user preferences in your account settings. Not all YI Products conduct direct marketing. Where this functionality is available, you can change your preferences at any time and switch this option on/off. We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our systems.

Depending on your location and type of data, YI may process your personal information on servers that are not in your home country. If you are in the United States, YI processes your personal information only in the United States. If you are outside of the United States, YI processes your personal information in Germany and/or Singapore.

Our legal bases for processing information

In order to store, hold and process your data lawfully where EU Data Protection Law (including the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016), read in conjunction with and subject to any consequential national data protection legislation) applies, we rely on one or more of the following legal grounds:

Where it is necessary for the performance of a contract - we process your data to provide and support a product or service you have asked for under a contract, including but not limited to delivering our Terms of Use.

When we are pursuing legitimate interests. We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:

- offering and improving YI Products and services
- developing new products and features
- understanding how people use our products and services
- performing research that improves our services for our users and benefits the public
- protecting against harm to the rights, property, and safety of YI, our users, and the public
- detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services
- maintaining and improving the integrity of our computing systems, and protecting our users’ data security
- enforcing legal claims, including investigation of potential violations of applicable Terms of Use
When we are complying with legal obligations. We process your data when we have a legal obligation to do so, for example, if we are responding to a legal process or an enforceable governmental request.

With your consent. Where necessary, we ask for your consent to process your information for certain specific purposes and give you the right to withdraw that consent at any time.

Individual Rights in the European Economic Area

If you are located in the EEA, you may seek confirmation regarding whether YI is processing personal information about you, request access to your personal information and ask that we correct, amend or delete your personal information. In addition, you may object to YI’s processing of your personal information at any time. However doing so may impact your use of the YI Products and services.

If applicable law provides you the right to request access to, (receive) port, object to or restrict processing, seek rectification or request erasure of personal information held about you by YI, you may do so, as applicable, through controls in the YI app or by contacting YI at support@YItechnology.com.

Further information on your rights in the EEA is set out below:

• Right to obtain a copy of your personal data – you have the right to obtain a copy of the personal information we hold about you. If you would like to make a SAR, i.e. a request for copies of the personal data we hold about you, you may do so by contacting us at the contact details above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity.

• Right to rectification – you may request that we rectify any inaccurate and/or complete any incomplete personal data.

• Right to withdraw consent – you may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your personal data is essential.

• Right to object to processing – including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your personal data. In relation to automated processing and profiling, you may object to the processing and you will have the right to obtain human intervention.

• Right to erasure – you may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.

• Right to data portability – in certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services.

• Your right to lodge a complaint with the supervisory authority – please contact us first about any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to contact the relevant EEA supervisory authority directly.

In what circumstances does YI share my information?

We do not share personal information for any commercial or marketing purpose unrelated to the activation and delivery of YI Products and services without asking you first.

The following are the limited situations where we may share personal information:

• For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers and systems for technical problems. These technicians (as well as YI employees) can access certain information about you or your account relating to this work, but these technicians are not allowed to use this data for non-YI purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video and audio recordings that you have not shared.

• As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request that a purchaser treat our data under the Privacy Policy.

• For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, we may disclose information in response to legal process and we may disclose information in response to lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security.

If you select an outside party for the purchase, installation, or service of your YI device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a YI Product from a retailer, the retailer may collect personal information as part of the transaction.

What choices do I have and how can I delete my personal information?

YI generally stores your personal information on YI’s systems until you delete or edit it, or for as long as you remain a YI customer, in order to provide you with YI Products, but your audio, photo, and video files are stored for a limited time (e.g., 7, 15, or 30 days). Your YI account allows you to delete audio, photo, and video files that you choose before the limited storage time has elapsed. In addition, should you wish to delete your entire account, including all recordings associated with it, contact support@YItechnology.com.

As described above, some information is processed and stored directly on the YI device. All personal information is encrypted as it is transmitted to YI and cannot easily be accessed.

You can access, amend or delete your personal information from YI’s systems through the controls in your YI account. Because of the way we maintain certain services, after your information is deleted, backup copies may linger for some time before they are deleted, and we may retain certain data for a longer period of time if we are required to do so for legal reasons.

Retention of Personal Data

Your personal data will be retained for as long as it is necessary to carry out the purposes set out in this Privacy Policy (unless longer retention is required by applicable law). However, we will not retain any of your personal data beyond this period and the retention of your personal information will be subject to periodic review. We may keep an anonymized form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

Cookies

The YI Action Camera website and app use cookies to distinguish you from other users of the website and app. This helps us to provide you with a good experience when you browse the service and also allows us to improve our website and/or app. If other YI Products use cookies we will inform you.

This section of the Privacy Policy explains what cookies are, why we use them and what you may do if you wish to restrict, remove or refuse to accept cookies. By continuing to use the YI Action Camera website and/or app, you agree to the use of cookies for the purposes set out in this Privacy Policy.

A cookie is a small file that a website, app or its service provider transfers to your computer’s hard drive, mobile phone or other device, through your web browser (if you agree) that enables the website’s, app’s or service provider’s systems to recognize your browser and capture and remember certain information. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:



Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the relevant website and/or app.

This website is following the UK Law terms and condition:

Under this agreement, the payment processing services for goods and/or services purchased on this website are provided by SUNLIGHT (UK) TRADING LIMITED & Old Street,167 City Road,London,EC1V 1AW,UK on behalf of YI Technology. In the event you choose to pay with credit card and the payment will be processed via an European Acquirer, these terms are an agreement between you and SUNLIGHT (UK) TRADING LIMITED & Old Street,167 City Road,London,EC1V 1AW,UK.

If there is any chargeback or reversal of any payment requested by a payment service partner, SUNLIGHT (UK) TRADING LIMITED has the right to refund the money so requested by the payment service partner without liability to YI Technology. SUNLIGHT (UK) TRADING LIMITED will use reasonable efforts to assist YI Technology in participating in the dispute resolution process of the relevant payment service partners.

For any enquiries if you choose DHpay for payment,you can contact:
SUNLIGHT(UK) TRADING LIMITED
Address: Old Street 167 City Road London, EC1V 1AW, UK

Can the Privacy Policy be changed?
Please note that this Privacy Policy may change from time to time. We will provide notice of any changes by contacting you through a notification in the YI mobile app or through the email contact information you provided when setting up your YI account.

How can I contact YI?
If you have any questions, please contact us at: support@yitechnology.com.