Privacy Policy for Kalay App

This Privacy Policy describes how ThroughTek Co., Ltd. and its subsidiaries (“TUTK”) may collect, use, disclose and otherwise process “Personal Information” if you install our apps and use VSaaS subscription services via our web or mobile applications. By using TUTK’s apps and services, you agree to allow us to collect and process information as described in this Privacy Policy.

We may update the Privacy Policy from time to time. If we modify the Privacy Policy, we will post the revised version here with the updated revision date. We recommend that you visit our websites periodically to be aware of and review any such revisions. We may also notify you by other means, such as posting notices on our websites or sending notifications to you. As a user, you will have the chance to accept or reject the updated Privacy Policy.

What information about you we may collect

We may obtain your Personal Information from various sources:

a. Personal Information directly from you

When you install our apps, you’ll be asked to provide some basic information about you for registration purposes. As a result of the use of our apps, we may collect Personal Information that you provide voluntarily such as videos recorded by TUTK-enabled camera products. This may include capturing and emailing to you portions of the videos as part of a notification or analyzing the data to identify motion or other events. For the purpose of customer support, we may collect information through your communications with us.

b. Personal Information from your Interactions with our Apps and services

We use automatic data collection tools like cookies, web beacons, and other tracking technologies in our products and services to collect service-enabling data, including IP addresses, device identifiers and other information about your device, system and application software, and peripherals. We collect information related to the use our apps and statistics about the performance of your TUTK-enabled devices. This information includes internet speed, voltage information, storage information, and error rates.

c. Personal Information from a third-party

It is possible for cameras owned and operated by you to capture photos or videos of a third party.

Information collection of individual TUTK app or service is described in detail below:

Kalay

 IP address

 device password

 device firmware version

 video recordings and the first image of video clips

KalayAli

 IP address

 device password

 device firmware version

 VSaaS invoice list

 mobile phone numbers

 e-mail address and password

 video recordings and the first image of video clips

Media SDK

 mobile phone numbers

 e-mail address and password

 video recordings and the first image of video clips

Kalay Cam/ Kalay Light Cam/ P2PCamLive

 IP address

 device password

 device firmware version

 the last live view image

 the last video recording

Kalay Home-Diffuser

 IP address

 device password

 device firmware version

Hausetopia

 IP address of the application and device

 User account e-mail and password

 Credentials for connecting to the devices

 Cloud event clips from the devices

 Thumbnails from cloud event clips

How we may use your Personal Information

We may use your Personal Information to provide our services, which you’ve requested for under a contract, including but not limited to delivering our Terms of Service, and to communicate with you directly for the purpose of customer support.

We may process your information for our legitimate interests and those of third-parties while applying appropriate safeguards to protect your privacy:

 to use your Personal Information in a non-identifiable form for research purposes to understand how our services are used

 to improve our app products and related services in order to develop new features

 to protect against harms to the rights, property and safety of TUTK and our customers

 to detect or prevent fraud, abuse, security or technical issues with our services

 to be in compliance with the laws and regulations

 to enforce legal claims, including investigation of potential violations of applicable Terms of Service

How we may share your Personal Information

We may share your Personal Information within TUTK subsidiaries and affiliates. We may also share Personal Information with our service providers, who perform services on our behalf based on our instructions and in compliance with appropriate confidentiality and security measures.

For legal reasons, we may share your Personal Information with third-party companies, organizations or individuals as necessary to meet any legal process or enforceable governmental request.

Your rights and choices

TUTK will store your Personal Information on TUTK’s servers for as long as you remain a customer in order to provide you with the services. In addition, TUTK may store Personal Information about your interactions with our services in order to resolve disputes, enforce our agreements and comply with applicable laws.

If applicable law provides you the right to request access to, object to or restrict processing, seek rectification or request erasure of Personal Information retained by TUTK, you may do so at any time through your account settings or delete your account. However, doing so may impact your use of our apps and services. Please contact us if you have any questions or concerns about your Personal Information. To protect your privacy, TUTK may take commercially reasonable steps to verify your identity before granting access to or allowing changes to be made to your Personal Information.

Data transfers

TUTK is a global company with operations in several countries. The laws, regulations, and standards of the country in which your information is collected, stored or processed may be different from the other countries. In the European Union/China/U.S., for instance, your Personal Information is processed and stored in the same region or country where it is collected. In certain circumstances, TUTK in Taiwan may access the data in servers located in the European Union/China/U.S. including your Personal Information to provide technical support services.

How we protect your Personal Information

We maintain administrative, technical and physical safeguards to protect your Personal Information against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. We also contractually require that our suppliers protect such information from unauthorized access, use, and disclosure. However, the Internet is not 100% secure. We cannot promise that your use of our apps and services will be completely safe.

We take measures to delete your Personal Information or keep your identity anonymous when the information is no longer necessary for the purposes for which we process it or when you request its deletion, unless we are allowed or required by law to keep the information for a longer period. We conduct periodic reviews of our databases, and have established time limits for certain data deletion, taking into consideration the type of services provided in the context of the app products and services, the length of our relationship with you, mandatory retention periods, and the statute of limitations.

Minors

Only individuals 18 years of age or older are permitted to act as owners of TUTK accounts. Our app products and services are meant for adults. We do not knowingly allow children under 18 years of age to set up accounts. If you are a parent or guardian and believe your child has disclosed Personal Information to us, please contact us. We will take such notices seriously and address the issue properly.

How to contact TUTK?

If you have any questions or complaints about our privacy practices, you can contact our Data Protection Office by emailing privacy@tutk.com or writing us at 9F, No. 364, Nangang Rd. Sec. 1, Nangang Dist., Taipei City, Taiwan.

*Revised on 2019/4/2

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