Kami Vision Privacy Policy

This Privacy Policy explains how information is collected, used, and disclosed by Kami Vision, Inc. (“Kami Vision”) in order to provide its customers smart security solutions (“Services”). This Privacy Policy applies to the personal information collected when you use or access our online websites (“Site(s)”), our mobile apps (collectively “Mobile Apps”), purchase products (“Goods”), or subscribe to paid services. These Sites include: www.kamihome.com; www.kamistore.eu; www.yitechnology.com; www.forum.yitechnology.com; www.store.yitechnology.com. The Mobile Apps include: Kami Home, Yi Home, Yi IoT, Kami Vision, Yi Smart, and Yi Life. Our provisioning of the Site(s), the Mobile Apps, and the Goods are collectively referred to herein as the Services.

What Information & Why

We collect and use the following information to provide, improve, and protect our Services as described below:

Kami Home Store & Yi Home Store

Account Information for purchase of Goods. When you set up an account to purchase our Goods, you will be required to provide us with personal information such as your name, email address, password and shipping address. Your payment information such as credit card information and billing address will be collected by our trusted third-party payment provider(s). You will also agree to the terms of service that govern your purchase of Goods (“Terms of Service”). We use this information to process and fulfill orders, and to send emails to confirm your order status, shipment, and sales refunds.

Guest Check-Out for purchase of Goods. If you order Goods as a guest (without creating an account), we will use your information such as name, email address, and shipping address to process and fulfill orders, and to send emails to confirm your order status and shipment. Your payment information such as credit card information and billing address will be collected by our trusted third-party payment provider. You will also agree to the terms of service that govern your purchase of Goods (“Terms of Service”). We use this information to process and fulfill orders, and to send emails to confirm your order status, shipment, and sales refunds.

Marketing. We may collect your personal information in order to provide you with free of charge marketing related materials and/or opportunities to participate in contests or promotions. If you do not wish to receive such marketing materials from Kami Vision via email, then click the “unsubscribe” button on the bottom of the email, for communication via postal mail, contact us at customersupport@kamivision.com.

Product Reviews. We post product reviews of our customers on our Site who voluntarily agree to participate.

Usage, Device and Log Information. We collect information about you when you access and use the Site or purchase Goods, including your Internet Protocol (“IP”) address, access times, browser type and language, Web pages you visit, device information, and other actions you take, in order to provide and improve our Services, as well as to develop new Services.

Cookies and other tracking technologies. We may use various technologies to collect information, which includes cookies. Cookies are small data files stored on your hard drive or in device memory that help us to improve the Services and your experience. You can set your browser to not accept cookies, but this may limit your ability to use the full functionality of this Site. Learn more about the Site’s and Apps cookies here.

Collection and Use of Aggregate Information. We may use aggregate information (not containing personal information) to analyze trends, administer the Site, track users’ movements, and gather broad demographic information on aggregate use.

Kami Home & Yi Home Community Forum (“Forum Sites”)

Personal information that also may be collected and processed on the community Forum Sites includes name, email, IP addresses, and any User Content that the customer chooses to upload. We use this information to provide the Forum Sites’ Services.

Kami Home, Yi Home, Yi IoT, Kami Vision, Yi Smart, & Yi Life Mobile Apps

Account Set up. When you set up your account to access the Services, you will be required to provide us with personal information such as your name, email address, phone number, and physical address (for certain services). We use this information to provide you our Services.

Kami Home & Yi Home Camera Setup

When you use the Kami Home and/or Yi Home Cameras to access the Services, you provide Kami Vision with user recorded video (“User Content”) which may contain personal information. Kami Vision processes this personal information (including User Content) in order to provide you the Services. We may process User Content for research and development purposes including algorithmic training and development in order to improve our Services. Where required by the GDPR or UK GDPR, we rely on our legitimate interests (Art. 6(1)(f)) in improving the security and performance of our Services for such research and development processing; we limit it to what is necessary and, where feasible, use de-identified or aggregated data. You may opt out at any time via [Settings > Privacy > Product Improvement]. We have conducted a data protection impact assessment for this processing. Because cameras may capture images of family members, visitors, or other third parties, you should position and operate your camera in a manner that respects the privacy of others and, where required by applicable law, inform or obtain the consent of individuals who may be recorded.

Biometric Data. If you choose to use feature(s) that process biometric data (e.g. facial recognition), we will process such data only with your explicit consent (Art. 9(2)(a) GDPR) and in accordance with the terms found here. You may withdraw your consent and delete stored biometric templates at any time through the applicable feature settings. Biometric data is not used for advertising.

AI Image Optimization Feature

When you use our AI image optimization feature, we require you to upload an image. We will analyze and process the photo data using machine learning models and artificial intelligence technology to achieve optimization effects such as image sharpening and detail enhancement. We process your image to provide you with the service you requested. The legal basis for this processing is the performance of the contract entered into with you (i.e., our Terms of Service). The uploaded image is processed only to generate the optimization result you requested and is not used for advertising.

Third-Party Advertising Services

We work with third-party advertising partners to provide and display advertisements in our Mobile Apps. These partners may collect or receive certain information from your device and your interactions with our Mobile Apps to deliver advertisements, personalize advertising where permitted, measure advertising performance, manage ad frequency, detect and prevent fraud, and maintain or improve their services.

Depending on the advertising services enabled, the information processed may include:

• Device and Advertising Identifiers: Such as your device’s advertising ID and other identifiers permitted by your device settings and applicable law.
• Device and App Information: Such as your device model, operating system, app version, language, and other technical information about your device or use of our Mobile Apps.
• Network and Approximate Location Information: Such as your IP address, network information, and information that may be used to estimate your general location.
• Advertising and Interaction Data: Such as ad impressions, clicks, engagement, and other information used to measure advertising performance and manage ad frequency.

Our advertising partners may use this information to deliver and display advertisements, select relevant advertisements where permitted, limit repeated ad exposure, measure advertising effectiveness, detect invalid activity and fraud, and maintain or improve their services.

The information collected and the purposes of processing may vary depending on the advertising partner, the advertising services enabled in the relevant Mobile App, your device settings, your location, your privacy choices, and applicable law.

Roles of the Parties. When we collect information through advertising software development kits (SDKs) integrated into our Mobile Apps and transmit that information to the relevant advertising partner, Kami Vision acts as a data controller for such collection and transmission, where applicable under relevant data protection laws. Once the information is received, each advertising partner may process it as an independent data controller in accordance with its own privacy policy and applicable legal requirements.

Legal Bases for Advertising (EEA and UK). If you are located in the European Economic Area (EEA) or the United Kingdom (UK), we process your information for advertising purposes on the following legal bases, as applicable:

• Consent (Article 6(1)(a) GDPR / UK GDPR): We rely on your consent for storing or accessing information on your device, including advertising identifiers, and for processing personal data for personalized advertising where consent is required. Where required by applicable law, we request your consent through an in-app consent interface before the relevant advertising SDKs store or access information on your device or process information for personalized advertising. You may withdraw or modify your consent at any time through the privacy or consent settings available in the relevant Mobile App, where provided, or through your device settings where applicable. For example, you may reset your advertising identifier or adjust the “Allow Apps to Request to Track” setting on iOS. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal. Where applicable, you may continue to receive non-personalized advertisements after withdrawing consent.
• Legitimate Interests (Article 6(1)(f) GDPR / UK GDPR): Where permitted by applicable law, we may rely on legitimate interests to process information for fraud detection and prevention, security, advertising frequency management, and aggregated advertising measurement. These interests include maintaining the security, integrity, and sustainability of our services. You may object to processing based on legitimate interests as described in the “Your Right to Control and Access Your Personal Information” section of this Privacy Policy.

Profiling. We and our advertising partners may use the information described to infer your likely interests (profiling) and select or display more relevant advertisements where permitted by applicable law. Such profiling is not intended to produce legal effects concerning you or similarly significantly affect you. We do not engage in automated decision-making that produces legal or similarly significant effects within the meaning of Article 22 GDPR in connection with these advertising activities.

Retention of Advertising Data. We process advertising identifiers and related advertising interaction data only for as long as reasonably necessary for the purposes described in this section and in accordance with applicable law. Where we retain such information in identifiable form, our retention period will not exceed [12] months, subject to applicable legal requirements and any earlier deletion or anonymization where appropriate. Withdrawal of consent or resetting your advertising identifier does not necessarily result in the deletion of information previously collected. The retention periods applicable to information processed by our advertising partners are described in their respective privacy policies.

International Transfers. Our advertising partners and service providers may process your personal data outside the EEA and the UK, including in the United States and China. Where such transfers are subject to the GDPR or UK GDPR, we and/or the relevant recipients rely on an applicable transfer mechanism, as required by law. Such mechanisms may include an applicable adequacy decision, including the EU–US Data Privacy Framework or its UK Extension where the recipient is appropriately certified, or the European Commission’s Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), together with the UK International Data Transfer Addendum or other applicable UK transfer mechanism. Where required, appropriate supplementary technical and organizational measures are implemented in light of the relevant transfer risk assessment. You may request further information about applicable transfer safeguards by contacting customersupport@kamivision.com.

Your Advertising Choices. You may have choices regarding personalized advertising and the use of advertising identifiers through your device settings and, where available, the privacy or consent settings in the relevant Mobile App. In the EEA and the UK, we obtain consent before processing information for personalized advertising where required by applicable law. We and our advertising partners handle applicable consent signals and privacy choices in accordance with relevant legal requirements.

Advertising Partners

We work with third-party advertising partners to support advertising services across our Mobile Apps. Depending on the advertising services enabled in a particular Mobile App, these partners may process information as described in this section and in their respective privacy policies.

Our advertising partners may include:

• Google AdMob: https://policies.google.com/privacy
• Pangle: https://www.pangleglobal.com/privacy/enduser-en
• Liftoff Monetize: https://liftoff.ai/privacy-policy/
• Mintegral: https://www.mintegral.com/en/privacy/
• BIGO Ads: https://www.adsbigo.com/privacy.html
• AppLovin: https://legal.applovin.com/privacy/
• Digital Turbine (Fyber): https://www.digitalturbine.com/privacy-policy/
• Moloco: https://www.moloco.com/privacy-policy
• MentaMob: https://www.mentamob.com/en/policy.html

The advertising partners used may vary by Mobile App, platform, region, and advertising configuration. We may update this list from time to time to reflect changes to the advertising partners supporting our Mobile Apps.

With Whom?

Service Providers

Kami Vision uses certain trusted third parties to provide certain services for our business purposes including website hosting, data analytics, email marketing, processing payments for the purchase of goods, IT services, order fulfillment, customer support, sales refunds, professional security monitoring, emergency service monitoring and reporting, and customer service. These third parties will access your personal information only to provide the Services on our behalf.

Our use of third-party advertising partners in Yi IoT is described in the “Third-Party Advertising Services” section of this Privacy Policy. As described in that section, Kami Vision acts as a data controller for the collection of information through advertising SDKs and its transmission to the relevant advertising partner, and each advertising partner thereafter acts as an independent controller.

Compliance with Laws

We may disclose your personal information to a third party if (a) we believe that such disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements or policies, (c) to protect the security or integrity of the Services from harm or illegal activities; (d) to respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person; or (e) to any other third party with your prior written consent.

Business Transfers

We may share or transfer your personal information in connection with, or during the negotiations of, any merger, sale of Kami Vision assets, financing, or acquisition of all or a portion of the business to another company or entity.

Your Right to Control and Access Your Personal Information

Your Account

You may update, correct or delete information about you at any time by logging into your online account and modifying your information or by emailing us at customersupport@kamivision.com.

Retention Policy

We will retain your Personal Information as long as necessary to fulfill the purposes described in this Privacy Policy unless a longer period is required for legal or compliance purposes. Please note that in many situations we must retain all, or a portion, of your personal information to comply with our legal obligations; resolve disputes; enforce our agreements; protect against fraudulent, deceptive, or illegal activity; or for another one of our business purposes.

Do Not Track

Some browsers offer a “do not track” (“DNT”) option. We do not respond to DNT signals. Where required by applicable law (for example, the California Consumer Privacy Act), we honor valid Global Privacy Control (GPC) signals as a request to opt out of the sale or sharing of personal information.

EU & UK Users

EU and UK users have several rights with respect to their personal data including the following: (i) the right to be informed (ii) the right of access; (iii) the right of rectification; (iv) the right of erasure; (v) the right to restrict processing; (vi) the right to data portability; (vii) the right to object to processing; and (viii) the rights in relation to automated decision making and profiling. EU users also have the right to lodge a complaint about the collection or use of their personal information by notifying their EU (or UK) supervisory authority. Kami Vision’s legal bases for collecting and processing EU or UK users’ personal data are performance of a contract, consent, and our legitimate interests, as described in the relevant sections of this Privacy Policy (including the “Third-Party Advertising Services” section for advertising). Your personal data may be collected, transferred to and stored by us in the United States and in other countries. Therefore, your personal data may be processed outside your country or jurisdiction, including in places that may not provide the same level of protection. We have implemented safeguards to ensure an adequate level of protection where your personal data is transferred. Please feel free to contact us regarding this or any other EU or UK data subject right at customersupport@kamivision.com if you have any questions about these rights.

EU/UK Representative. Kami Vision, Inc. is established in the United States. Our appointed representative in the European Union under Art. 27 GDPR is [name, EU address, contact email]. Our appointed representative in the United Kingdom under Art. 27 UK GDPR is [name, UK address, contact email].

California Consumers

California consumers have certain additional rights, which are described here.

Nevada Consumers

We do not sell your covered information, as defined by Section 1.6 of Chapter 603A of the Nevada Revised Statutes.

Device YYS.62121

To protect your security and personal data, this product meets the following mandatory security requirements:

1. Passwords: The product does not use universal default passwords.

2. Security Updates: We are committed to providing free security updates for this product for 3 years from the date of first purchase or UK market release (whichever is earlier). Important security updates will be notified and pushed via the device.

3. Security Issues Reporting: We operate a dedicated process for security issues reports for Device YYS.62121. If you discover a potential security issue, please contact us at home_subscription@kamivision.com. We will acknowledge your report within 5 working days and provide weekly status updates until the issue is fully resolved.

Security

We employ industry standard technological measures that are reasonably designed to help protect your personal information from loss, unauthorized access, disclosure, alteration or destruction. While we take reasonable efforts to guard personal information, no security system is impenetrable.

Policy On Information Collected From Children

This Site and our Services are not directed at children under the age of 18. Kami Vision does not knowingly collect personal information from children under the age of 18. If you become aware that a child has provided us with personal information, please contact us at customersupport@kamivision.com.

Changes

Kami Vision may need to update this Privacy Policy from time to time to reflect changes in our Services and the laws applicable to our provision of the Services to you. If we do change this Privacy Policy, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy on the Site. If there are material changes to this Privacy Policy, Kami Vision will notify registered users of our Services. Kami Vision encourages you to review this Privacy Policy regularly for any changes. Your continued use of this Site or the Services and/or continued provision of personal information to us after the posting of such notice will be subject to the terms of the then-current Privacy Policy. If you disagree with any applicable change, you will need to close your account and stop using the Site and the Services.

Contact

If you have any questions regarding this Privacy Policy, please contact us via email at customersupport@kamivision.com.