Last modified: 30 June, 2022
1. This Privacy Policy (the “Policy”) applies only to [DSS Agile] in mobile devices and/or tablets (the “App”). The APP is operated by the Operator (see the definition “Operator” below), and all data (including but not limited to “Personal Information”) the APP may collect, generate and upload or that you may provide to Operator when you use the APP, including but not limited to download, install, register, login in, are stored on your mobile devices or on the Operator's server. Such Personal Information shall not be transferred to the Developer (see the definition “Developer” below).
You’re highly recommended to use the APP with duty of care and ensure that Personal Information related to any other Data Subject you collect, provide and upload has been granted explicit consent in compliance with applicable laws.
In the event that the Operator breach the relevant laws and regulations when processing your Personal Information, the Operator shall be solely responsible for all disputes and liabilities arising therefrom at its own cost. The Operator shall reimburse in case any or all losses incurred to the Developer, including but not limited to the fines, compensations to the stakeholders, attorney fees and litigation fees.
2. Since the APP is deployed on a server controlled by the Operator, Developer has no access to your account information (e.g. account and passwords). You understand and acknowledge that you shall maintain your account information for safekeeping and Developer shall not be responsible for damages incurred due to loss of your account information. The Operator or you are responsible for the security of account information, and NOT to disclose account information to any third party, or to share the same account with multiple users, or to install illegal or unknown programs. You or the Operator is responsible for all acts of using the account, whether you authorize or not.
3. If you have any questions, comments or suggestions about processing of your Personal Information, you may contact the Operator who provides you with the login account.
4. If the Operator separately explains how to collect your Personal Information through other versions of the privacy policy, privacy statement or any other documents formulated by the Operator, such documents provided by the Operator shall prevail.
In order to explain how Operator collect, use and store your Personal Information and what rights you have through the APP, you can learn about relevant matters through this Policy, and this Policy helps you understand the following indexes:
1. Definitions
2. How Operator Collect Your Personal Information
3. How Operator Use Your Personal Information
4. How Operator Share, Transfer and Disclose Your Personal Information
5. How Operator Protect and Store of Your Personal Information
6. Your Rights
7. How Operator Protect Children’s Personal Information
8. Updates to Policy
9. SDK and Similar Technologies
10. How to Contact Operator
1) Developer: it refers to Hangzhou CE-soft Technology Co., Ltd (“CE-soft”). The App is developed by CE-soft with registered address A6, No.1181 Bin’an Road, Hangzhou, Zhejiang Province, the People’s Republic of China. CE-soft and its affiliated companies reserve the intellectual property rights to the APP and product or service embedded therein, and reserves all rights not expressly granted to you.
2) Operator: it refers to the company or legal entity that actually operates the App, that is, the company or legal entity who provides you with an account for using the APP.
3) Account: the account you login to the APP is registered and opened for you by the Operator on its own platform.
4) Personal Information: shall have the same meaning as “personal data” and shall include any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity. Examples of personal information include your name, telephone number, email address, physical address, and payment information.
5) Personal Sensitive Information: it refers to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, etc., depending on the definition provided by applicable laws.
6) Mobile Device(s): it refers to mobile phone, tablet, etc.
7) Equipment: it refers to cameras, alarm apparatus and door locks and so on so forth, you or Operator configure and deploy in APP.
8) SDK: Software Development Kit (SDK) is a set of software tools and programs provided by hardware and software vendors for building applications for specific platforms, software package, software framework and operating system, etc.
2. How Operator Collect Your Personal Information
1) Information collected during your use of the APP
The Operator may collect the Personal Information you voluntarily provide when using the APP or that is generated due to the use of the APP in the following ways:
When you use the intercom function of equipment, the Operator may need to collect your audio information, for the purpose of sending the audio collected by the APP to the equipment to realize the intercommunication between equipment. Refusal to provide such information make you unable to use the intercom function of the equipment normally, but will not affect your normal use of other functions of the equipment and APP.
In order to ensure your normal use of the APP, maintain the security of operation and your account, the Operator may collect the information of your mobile device(s), i.e. unique device identifier (IMEI/Android ID), MAC address, IP address, operation logs, service logs information (such as service failure information, mobile device failure information, etc.) and other log information. Such information is the basic information that must be collected during the operation and function of the APP.
2) Permission to mobile device
When you use the APP, you may need to enable the corresponding permissions. The Operator will inform you through a pop-up window and obtain your consent. If you disagree to enable the corresponding permissions, you will be unable to use the corresponding services or functions, but it will not affect your normal use of other services or functions. These permissions include the following:
(1) Location information permission: after you enable the location permission, you may use the map function in order to locate your current location and enable you to obtain the location information of peripheral equipment. Refusal to enable this permission will only make you unable to use the map location function normally, so that you cannot quickly obtain the location of peripheral equipment. However, it will not affect your normal use of other functions of the APP and equipment.
(2) Microphone permission: after you enable the microphone permission, you can use the audio and video intercom functions of equipment. The Operator may collect your audio information after you enable the microphone permission for the purpose of sending the audio collected by the APP to the equipment to realize the intercommunication between equipment. Refusal to enable this permission will only make you unable to use the audio and video intercom functions normally, but it will not affect your normal use of other functions of the APP and equipment.
(3) Album/storage permission: you can use the local file export function after enabling the storage/album permission. When you use the local file export function, the Operator may collect your picture and video information after enabling the storage/album permission, in order to export the picture and video in the APP to system album of your mobile device or SD card. Refusal to enable this permission will only make you unable to use the local file export function normally, so that your pictures and video cannot be exported to the system album or SD card, but it will not affect your normal use of other functions of the APP and equipment.
(4) Phone state permission: you can use the video intercom function after enabling the mobile phone state permission. The purpose is to interrupt the video intercom for you in time when there is an ongoing phone call so as not to affect your normal phone call. Refusal to enable this permission will only make you unable to use the video intercom function normally, but will not affect your normal use of other functions of the App and equipment.
(5) Camera/album permission: you can use the function of face image capture and adding personnel after enabling the camera/album permission. When you use such functions with enabling camera/album permission, the Operator may collect the pictures you take or upload. The purpose is to search the person from the data base you upload and add he/her to your data base. Refusal to enable such permission will only make you unable to use the functions of face image capture and adding new personnel normally, but it will not affect your normal use of other functions of the APP and equipment.
As the end user of equipment or data controller, you or the Operator might collect the Personal Information of others such as their face images and other biometrics data. You or the Operator is advised to collect, store, process and transfer data in accordance with the applicable data protection laws and regulations to protect the legitimate rights and interests of third party by implementing necessary measures which include but are not limited to obtaining the explicit consent, carrying out administrative and physical security controls, providing clear and visible identification and notification, making periodic assessments and so on so forth.
You may check the status of the above permissions item by item in the settings of your mobile device, and decide whether to enable or disable at any time. Please note that when you install the APP in your mobile device, the above permissions will not be enabled by default. The Operators should obtain your explicit permission before they provide you with specific functions or services by using your Personal Information. You can withdraw such permission at any time, which may affect your use of specific functions or services provided by the Operator. Such withdrawal shall not affect the previous processing of your Personal Information by the Operator based on your permission.
In addition, Personal Information may be processed without your consent if necessary for the purposes of:
(1) processing is necessary for the performance of a contract or in order to take steps at your request prior to entering into a contract;
(2) processing is necessary for compliance with a legal obligation;
(3) processing is necessary in order to protect the vital interests of data subject or of another natural person;
(4) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested;
(5) processing is necessary for the purposes of the legitimate interests pursued by the Operator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of data subject which require protection of personal data, in particular where the data subject is a child.
(6) Other lawfulness of processing as specified in applicable laws.
Please understand that the functions and services provided by the Operator to you are constantly updated and developed. If one function or service is not listed in the foregoing description and your Personal Information is collected, the Operator may notify you the content, scope and purpose for the processing Personal Information via pop-up window, announcement, notification release or any other feasible ways separately and obtain your consent.
3. How Operator Use Your Personal Information
If the Operator uses your Personal Information beyond the scope that is directly or reasonably related to the stated purpose herein at the time of collection, the Operator shall inform you and obtain your express consent before using your Personal Information. You and the Operator should inform and obtain explicit consent of the data subject if Personal Information you collected, provided and uploaded is associated to other data subject.
The Operator processes your Personal Information only for specific purposes. Based on your interaction with the Operator, and the products and services the Operator provides, it may process your Personal Information for the following purposes:
(1) for the purpose to realize and ensure the functions and security of equipment or service;
(2) communication with you
The Operator may send important notices or messages via the information collected, such as changes to the Operator's relevant terms and conditions, as well as policies. As such notices are critical to your communication with the Operator, you are advised to receive and read such notices.
(3) Protection of legitimate rights and interests
The Operator may use your Personal Information for identity verification and security prevention, etc., to prevent any illegal behaviors or protect the legitimate rights, property or safety of the Operator, its customers or other third parties.
4. How Operator Share, Transfer and Disclose Your Personal Information
1) Personal Information Sharing
The Operator may share your Personal Information with other companies, organizations and individuals in the following situations:
(1) Sharing upon explicit consent: the Operator may share your Personal Information with other third parties after obtaining the explicit consent of you or other data subject corresponding to or associated with the Personal Information you collect, provide and upload.
(2) Sharing based on mandatory legal requirements: the Operators may share your Personal Information externally according to laws and regulations or the mandatory requirements of government authorities.
(3) Sharing with affiliated companies or other group companies of Operator: the Operator may share your Personal Information with its affiliated companies. The Operator should only share your necessary Personal Information and be bound by the stated purpose of the Personal Information it collects. If group companies of the Operator intend to change the purpose of processing Personal Information, it shall obtain the explicit authorization and consent of you or other involved data subject.
(4) Sharing with SDK vendor: to provide you with a better, faster and safer user experience and ensure the stable operation, the APP may be embedded in third parties SDK or similar technologies. Third party SDKs may collect your Personal Information for provision of specific service. You can find detailed information about the use of SDK and similar technologies in the Section 10 SDK and Similar Technologies hereinafter.
2) Transfer of Personal Information
The Operator may transfer your personal Information to other companies, organizations and individuals in the following circumstances:
(1) Transfer upon explicit consent;
(2) When there is a merger, acquisition or bankruptcy liquidation, if transfer of your Personal Information is necessary, the Operator should require the successor who holds your Personal Information to continue to perform the obligations herein. Otherwise, the Operator shall require the successor to obtain authorization and consent from you or other data subject separately.
3) Disclosure of Personal Information
Pursuant to relevant laws and regulations, the Operator may disclose your Personal Information without obtaining prior consent in the following situations:
(1) disclosure based on law: to comply with any court order, law or legal process, including to respond to any government or regulatory authority’s request or for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation);
(2) to deal with public health emergencies, or, in case of emergency, to protect the health of natural persons and the safety of their property;
(3) personal Information is publicly disclosed by you or other personal data that is already legally and publicly disclosed within a reasonable scope in accordance with the laws;
(4) other situations in which data processing is required by the applicable laws and regulations.
5. How Operator Protect and Store of Your Personal Information
1) Data Security Measures
(1) The Operator shall take all appropriate physical, electronic and management security measures to prevent your Personal Information from accidental losses and from unauthorized access, use, alteration and disclosure. For instance, the Operators shall use encryption technology to improve the security of Personal Information and trusted protection mechanisms to prevent Personal Information from being maliciously attacked.
(2) The Developer highly recommends you to use comprehensive and complex password in protecting the security of your account. The Operator shall ensure the security and confidentiality of Personal Information you provide.
(3) In the case of a personal information leakage and other personal information security incidents, the Operator shall without undue delay and, where feasible, after having become aware of it, notify the personal data breach to you and/or the supervisory authority competent in accordance with the applicable laws and regulations via email, phone, push notification, announcement or any other feasible methods in a reasonable and effective way. The Operator shall inform you including the basic situation and possible impact, the disposal measures that the Operator has taken or will take and recommendations for risk mitigation, etc.
The Developer has implemented and will continue to improve appropriate technical and organizational measures designed to secure and strengthen the data security of APP. For instance, partial information can be encrypted directly in your mobile device for the purpose of secure transmission. In addition, the Developer will release the updated version of the APP from time to time, and you can download and install the updated version through the application market in your mobile device.
2) The retention of Personal Information
(1) Storage location
All data, including but not limited to “Personal Information”, the APP may collect, generate and upload or that you may provide to the Operator when you download, install, register, login in or use the APP are stored on your mobile device(s) or on the Operator's server.
Your Personal Information may be stored by the Operator at the country or the region where the Operator provide you equipment or service, or the server where you input. The Developer will not store your Personal Information in any event.
(2) Retention period
The Operator will retain your Personal Information for no longer than it is necessary for the purposes stated by tehe Operator, unless otherwise extending the retention period is required or permitted by law. To determine the appropriate retention period for Personal Information, the Operator may consider the amount, nature and sensitivity of the Personal Information, the potential risk from unauthorised use or disclosure of your Personal Information, the purposes for which the Operator process your Personal Information and whether the Operator can achieve those purposes through other means, and the applicable legal requirements
If you want to learn more about the retention period of your Personal Information, you may directly contact the Operator who provides you with the login account.
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6. Your Rights
You can review and change your Personal Information by logging into the App and visiting your account profile page. If you are not able to find your Personal Information, you may also contact the Operator to request access to, correct, or delete any Personal Information that you have provided to the Operator. You may also object to or request the Operator to restrict the processing of your Personal Information. If the Operator process your Personal Information based on consent, you may withdraw your consent at any time by contacting the Operator. A summary of your legal rights is set out below:
· Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information the Operator hold about you and to check that the Operator is lawfully processing it.
· Request correction of the Personal Information that the Operator hold about you. This enables you to have any incomplete or inaccurate data the Operator hold about you corrected, although the Operator may need to verify the accuracy of the new data you provide to the Operator.
· Request erasure of your Personal Information. This enables you to ask the Operator to delete or remove Personal Information if there is no good reason for us continuing to process it. You also have the right to ask the Operator to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where the Operator may have processed your information unlawfully, or where the Operator is required to erase your Personal Information to comply with local law. Note, however, that the Operator may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
· Object to processing of your Personal Information where the Operator is relying on our legitimate interest (or that of a third party), and there is something about your particular situation that makes you want to object to processing on this ground as you believe it affects your fundamental rights and freedoms. You also have the right to object where the Operator is processing your Personal Information for direct marketing purposes. In some cases, the Operator may demonstrate that the Operator has compelling legitimate grounds to process your information that override your rights and freedoms.
· Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want the Operator to establish the data's accuracy; (b) where our use of the data is unlawful, but you do not want the Operator to erase it; (c) where you need the Operator to hold the data even if the Operator no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to the Operator’s use of your data, but the Operator need to verify whether the Operator have overriding legitimate grounds to use it.
· Request the transfer of your Personal Information to you or to a third party. The Operator will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for the Operator to use or where the Operator used the information to perform a contract with you.
· Withdraw consent at any time where the Operator is relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, the Operator may not be able to provide certain products or services to you. The Operator will advise you if this is the case at the time you withdraw your consent.
For security reasons, the Operator will take steps to authenticate your identity before providing access to your Personal Information. You also have the right to lodge a complaint with the relevant Data Protection Authority.
7. How Operator Protect Children’s Personal Information
The App is not intended for children under 18 years of age, or equivalent minimum age in the relevant jurisdiction (refer to“Child” or “Children” below), and the Operator does not knowingly collect Personal Information from Children.
Children shall obtain the consent of your parents or legal guardians (“Consent of Guardian”) before using this APP and its related equipment or services embedded hereof, and complete the registration process under the help of your parents or legal guardians, so that you may use the APP and equipment or services provided by the Operator.
If the Operator learns it has collected or received Personal Information from a Child, without verification of Consent of Guardian, the Operator will delete that Personal Information. If you believe the Operator might have any Personal Information from or about a Child, please contact the Operator.
The Developer reserves the right to modify this Policy from time to time in its sole discretion. If the Developer made material modifications to the Policy, it will notify you sending you an in-App alert the first time you use the App after making the changes. The date this Policy was last revised is identified at the top of the page. All changes are effective immediately when the Developer post them and apply to all access to and use of the App thereafter; provided, to the extent required by law, the Developer will seek your affirmative consent prior to applying material modifications to this Policy on how the Developer use or disclose Personal Information that the Developer collected or received prior to the date of the modification. You are expected to check this Policy frequently, so you are aware of any modifications, as they are binding on you once you providing affirmative consent.
9. SDK and Similar Technologies
To provide you with a better, faster and safer user experience and ensure the stable operation, the APP may be embedded in third parties SDK or similar technologies. SDKs are a collection of software development tools in one installable package, which allow third party developers to integrate with the APP for specific purposes (e.g., authentication, location). Third party SDKs may collect your Personal Information for provision of specific service.
The Operators shall evaluate the legality, legitimacy and necessity of the information collected by such third party, and requires third party to take protective measures for your Personal Information strictly abide by relevant laws and regulations. The Operator shall timely explain to you the latest situation of the third-party SDK that collects your personal information on this page:
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1) Baidu Map SDK |
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Host: |
Baidu Online Network Technology (Beijing) Co., Ltd. |
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Purpose: |
to provide third-party mapping service and location functions |
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Permissions involved: |
ACCESS_NETWORK_STATE, READ_EXTERNAL_STORAGE, WRITE_EXTERNAL_STORAGE, READ_SETTINGS, GET_TASKS, ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION |
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Personal Information Collected |
(1) Information related to Mobile device: Android ID, operating system version, brand and model number of mobile device, configuration, APP information (APP name), network operator; (2) Information related to network: Wi-Fi connection information (incl. Wi-Fi status, parameters and list), connection status (e.g. mobile network, Wi-Fi network or no network); (3) Location related information: Wi-Fi address and signal intensity, base station ID data information, sensor information, signal intensity of mobile device and IP address. |
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SDK Privacy Policy |
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2) Google Map SDK |
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Host: |
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Purpose: |
to provide third-party mapping service and location functions |
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Permissions involved: |
ACCESS_NETWORK_STATE, READ_EXTERNAL_STORAGE, WRITE_EXTERNAL_STORAGE, READ_SETTINGS, ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION |
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Personal Information Collected |
(1) Information related to Mobile device: Android ID, operating system version, brand and model number of mobile device, configuration, APP information (APP name), network operator; (2) Information related to network: Wi-Fi connection information (incl. Wi-Fi status, parameters and list), connection status (e.g. mobile network, Wi-Fi network or no network); (3) Location related information: Wi-Fi address and signal intensity, base station ID data information, sensor information, signal intensity of mobile device and IP address. |
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SDK Privacy Policy |
https://policies.google.com/privacy?hl=en-US |
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3) Firebase Cloud Messaging (“FCM”) |
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Host: |
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Purpose: |
Send notification messages in APP via FCM |
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Permissions involved: |
ACCESS_NETWORK_STATE, READ_SETTINGS |
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Personal Information Collected |
(1) Information related to Mobile device: Android ID, operating system version, brand and model number of mobile device, configuration, APP information (APP name); (2) Information related to network: Wi-Fi connection information (incl. Wi-Fi status, parameters and list), connection status (e.g. mobile network, Wi-Fi network or no network); |
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SDK Privacy Policy |
https://policies.google.com/privacy?hl=en-US |
10. How to Contact Operator
If you have any questions, comments or suggestions about this Policy, you may directly contact the Operator who provides you with your login account.
If any queries with regards to the Developer for any technical support, you may contact the Developer by email at:
Email: support@cce-soft.com
Postal Address: 8F, No.6, Yinhu innovation center, No.9, Fuxian Road, Yinhu Street, Fuyang District Hangzhou, Zhejiang Province, P.R. China