Cloud Storage Privacy Policy

Overview

Cloud Storage is a product and/or service (hereinafter referred to as the “Service”) provided by Shenzhen Zhencheng Technology Co., Ltd. (hereinafter referred to as “SJCAM”, “we” or “our party”) through the SJCAMX App, official website, and new forms emerging with technological development (hereinafter referred to as “Our Platform”), which offers data storage, synchronization, management, and sharing for your camera videos and photos (hereinafter referred to as “Material Data”).

This Privacy Policy (hereinafter referred to as the “Policy”) is a statement and commitment on privacy and personal information protection for the cloud storage service provided by SJCAM in the SJCAM X App. This policy is formulated with full consideration of your needs. It is crucial that you fully understand our practices for collecting and using personal information and ultimately retain control over the personal information you provide to us. This policy stipulates how we collect, use, disclose, process, and store the information you provide when using our cloud storage. If you have any questions about this policy, you may contact us via our official email address: app@sjcamhd.com.

Before using the cloud storage service, please carefully read and fully understand this policy and make the choices you deem appropriate. We will comply with the current laws and regulations and handle your personal information in a legal, legitimate manner and in accordance with the principle of good faith. Clauses in this policy that (may) have a significant bearing on your rights and interests are highlighted in bold for your focused review. If you do not agree with any content of this policy, you shall immediately cease using the cloud storage service.

This privacy policy is an integral part of the SJCAM Privacy Policy. In the event of any inconsistency between the special provisions relating to the Cloud Storage Service and the specific terms stipulated in the SJCAM Privacy Policy, this Privacy Policy shall prevail; matters not stipulated in this Privacy Policy shall be governed by the SJCAM Privacy Policy. In addition, we recommend that you read the SJCAM User Service Agreement in detail, especially in cases where specific provisions are not set forth in this Privacy Policy.

This policy will help you understand the following:

I. Scope of Application of this Policy and Basis for Personal Information Processing

II. How We Collect and Use Your Personal Information

III. How We Use Cookies and Similar Technologies

IV. How We Store Your Personal Information

V. How We Entrust the Processing, Sharing, Transfer, and Publicly Disclose Your Personal Information

VI. How We Protect Your Personal Information

VII. Your Rights

VIII. How This Policy Is Updated

IX. How to Contact Us

X. Dispute Resolution

Relevant Terms and Definitions

User/You: Refers to a natural person who uses or subscribes to Cloud Storage.
We/Our Party/SJCAM: Individually or collectively refers to each legal entity operating Our Platform, including Shenzhen Zhencheng Technology Co., Ltd. and its affiliated companies.
Our Platform: Includes the SJCAM mobile internet application (SJCAMX App), official website (https://www.sjcam.com/), and other clients.
Our Platform Service/Cloud Storage Service: Refers to the storage, synchronization, management, and sharing services provided by us based on the internet through various forms of Our Platform (including new service forms emerging with future technological development) for your camera videos and photos (i.e., “Material Data”).
Affiliated Companies: Refers to entities with an affiliated relationship with each other. An affiliated relationship means the relationship between SJCAM’s shareholders, actual controllers, directors, supervisors, senior management personnel, and the enterprises directly or indirectly controlled by them, as well as other relationships that may result in the transfer of SJCAM’s interests.
Personal Information: Refers to various types of information recorded by electronic or other means that relate to an identified or identifiable natural person, excluding information that has undergone anonymization processing.
Sensitive Personal Information: Refers to personal information that, if leaked or illegally used, is likely to infringe upon the personal dignity of natural persons or endanger their personal and property safety, including biometric identification, religious beliefs, specific identities, medical and health information, financial account details, travel tracks, and other such information, as well as personal information of minors under the age of fourteen.
Processing of Personal Information: Includes the collection, storage, use, processing, transmission, provision, public disclosure, deletion, and other activities respecting personal information.

I. Scope of Application of this Policy and Basis for Personal Information Processing

1. Scope of Application

This policy applies to the services provided by SJCAM on the SJCAMX APP and official website. Your login and use of the Cloud Storage Service, or the use of the Cloud Storage Service through affiliated parties or third-party platforms, shall all be subject to this Policy.

Please note that this policy only applies to the personal information processed by us and does not apply to personal information processed by third-party products and/or services (including any third-party websites, apps, mini-programs, etc.) accessed via the cloud storage service. Such third-party services are provided by independent third-party entities, whose personal information processing activities are governed by their own privacy policies, and we shall bear no liability in this regard.

2. Basis for Personal Information Processing

Except for the following circumstances, our processing of your personal information shall obtain your explicit consent (including separate consent or written consent that is required in accordance with the provisions of relevant laws and administrative regulations):

(1) Necessary for the conclusion and performance of a contract in which the individual is a party, or for the implementation of human resources management in accordance with legally formulated labor rules and regulations and legally signed collective contracts;

(2) Necessary for the performance of statutory duties or obligations;

(3) Necessary for responding to sudden public health incidents or for protecting the life, health, and property safety of natural persons in emergency situations;

(4) Necessary for conducting news reports and public opinion supervision for the public interest and processing personal information within a reasonable scope;

(5) Processing personal information voluntarily disclosed by an individual or other legally publicly disclosed personal information within a reasonable scope in accordance with the provisions of this Law;

(6) Other circumstances stipulated by laws and administrative regulations.

For the processing of sensitive personal information, in addition to the above statutory circumstances, we shall obtain your separate consent in all cases.

II. How We Collect and Use Your Personal Information

(I) Select Account Location and Subscribe to Cloud Storage Service

After you register via the SJCAMX App, if the country or region where your account is located has officially launched the Cloud Storage Service and your account is in normal status, you may view the relevant content of the Cloud Storage membership service and select your subscription plan. When subscribing for the first time, you shall confirm your account location (used to determine the regional data center where your data is stored), then confirm and complete the payment to purchase the corresponding subscription plan. When subscribing to or purchasing the Cloud Storage Service, we will collect and use your account information (user ID, login IP address, account location, regional data center), current membership plan and its validity period, order information (type of membership purchased, purchase duration, purchase date, order amount, payment method, order number), and automatic renewal information (activation status, renewal amount, renewal date, and payment method). Such information is used for legitimate and necessary purposes such as determining the data storage location, completing transactions, querying orders, and resolving disputes. To provide you with the core Cloud Storage Service, we will collect the aforementioned information in accordance with the principle of minimum necessity. If you refuse to provide the aforementioned information to us, you will be unable to use the Cloud Storage Service.

Upload and Download Services: After you choose to subscribe to or purchase the Cloud Storage Service, you may directly add your device to Cloud Storage via the SJCAMX App to upload photos, videos, and other material data directly from your device. You may also choose to download stored files from cloud storage and set the network conditions for upload & download at your discretion. For this purpose, we will collect your data from the SJCAMX app-bound camera device (if enabled, including your user ID, device type, device serial number, and storage path of video/photo data in the camera), and the collection is only triggered when you perform upload/download operations. Upload and download are basic functions of the Cloud Storage Service; if you refuse to provide the aforementioned information to us, we will be unable to provide you with the Cloud Storage Service.
Automatic Upload Service: When your camera device is idle, connected to Wi-Fi, and charging, it will automatically upload photos, videos, and other material data to cloud storage for data backup. You may independently choose whether to enable the Automatic Upload Service.
Cloud Space Management and Material Data Editing Services: After you upload Material Data to Cloud Storage, you may manage the cloud space and the Material Data therein via the SJCAMX App, including the following operations:

(1) View and confirm details of cloud storage usage: For this purpose, we need to collect and use your user ID, total storage space of the cloud space, used and remaining storage space, material data ID, cloud storage path, type, name, shooting time, status, file size, width, and height. If you refuse to provide the aforementioned information to us, you will be unable to use the Cloud Storage Service.

(2) Download: If you wish to download Material Data from Cloud Storage to the system’s local album, we need to access your system album to directly download part of the Material Data to your system album. If you refuse to provide the aforementioned information to us, you will be unable to use the above function of Cloud Storage, but it will not affect your normal use of other functions of Cloud Storage.

(3) Synchronize edited data across different devices: We need to synchronize your edited data to the cloud, so that when you log in to your account on different devices to view videos, you can directly see the videos with editing effects applied.

Subscription Service Expiration Notification: After your subscribed Cloud Storage Service expires, we will provide you with a 60-day Material Data retention period. If you choose not to renew the subscription, your Material Data stored in Cloud Storage will be permanently deleted upon the expiration of the retention period. We will notify you of the expiration of the subscription service via the SJCAMX App and the mobile phone number or email address reserved in your SJCAMX App account.
For the purpose of ensuring service security, optimizing and improving the Service: When you use Cloud Storage, to ensure your normal use of the Cloud Storage Service, accurately locate and resolve problems you encounter when using the Cloud Storage Service, improve and optimize the service experience of Cloud Storage, safeguard the security of your account, prevent, detect and investigate fraud, security hazards, illegal acts or acts in violation of our agreements, policies or rules, and protect the legitimate rights and interests of you, us, our affiliated companies, partners and the public, we will collect and use your user ID, user order information, user transaction information, transaction currency, cloud space usage, subscription period, subscription status, subscription region and storage location selected at the time of first subscription. Such data is only used internally by the SJCAMX App and will not be provided or disclosed to third parties.
Sending Marketing and Promotional Information: When you use our services, we will not send or provide third-party advertisements to you. However, we may process your personal information (such as email address) and other data collected during the provision of services or obtained from third parties to send you marketing information via email. Prior to sending such marketing information, we will seek your separate and explicit consent. You may click the unsubscribe link in the email at any time and choose to no longer receive our marketing information. Please note that if you choose not to receive marketing information, we may still contact you regarding your use of our services, including but not limited to replying to your questions or requests.
Please note that in accordance with relevant laws and regulations, anonymous data is not deemed as personal information, and we do not need to obtain your consent to process such data. If it is necessary to train and apply generative artificial intelligence large models, we will comply with transparency requirements and disclose relevant information to the public.

(II) Reminder on Sensitive Personal Information

When you use our services, the material data you upload to the cloud storage space may involve your sensitive personal information, including but not limited to facial information. Please exercise caution when uploading material data containing sensitive personal information about yourself or others. Please be aware that we will ensure the security of the material data you upload to the cloud storage space through technical means, and we cannot and will not access, view, or use the material data you upload.

(III) Explanation of Device Permission Requests

When you use our products and/or services, we may need to request the following device permissions related to personal information from the device you use:

Confirm your data storage location: When you define the cloud storage service for the first time, you need to specify your data storage location. If the data storage location is not specified, you will be unable to complete the subscription and purchase of Cloud Storage.
Camera auto-start-related permissions: When you use the automatic backup service of Cloud Storage, we need you to grant auto-start-related permissions for the camera device to enable Cloud Storage to provide you with a more timely automatic backup service. After the above permissions are enabled, Cloud Storage will provide you with timely and effective automatic upload services at a reasonable frequency when running in the background, in accordance with the automatic backup conditions, network preferences, and data types you set. If you do not enable the above permissions, you will be unable to use the more timely online automatic backup service, but it will not affect your normal use of other functions and services of Cloud Storage.
Local album permissions: When you use Cloud Storage to add background music to your Material Data or download Material Data to the local album of your mobile phone, we need you to grant read/write/read permissions for the local album to upload videos/photos in your local album or folder for use as stickers for Material Data editing, or to extract background music from videos in the local album as background music for Material Data. If you do not enable the above permissions, you will be unable to use the perspective editing and background music adding services, but it will not affect your normal use of other functions and services of Cloud Storage.

III. How We Use Cookies and Similar Technologies

Cookies and similar technologies such as device information identifiers are commonly used technologies on the internet. We may collect your device model, operating system, unique device identifier, and login IP address information via cookies or similar technologies, and cache your browsing information and click information. We send cookies to you to ensure the safe and efficient operation of our products and services. We may set cookies or anonymous identifiers for authentication and security purposes to confirm whether you have logged in to the service safely, or whether you have encountered account theft, fraud, or other illegal acts. These technologies also help us improve service efficiency and increase login and response speeds. In addition, they can simplify your repeated login steps, enabling you to log in without re-entering your username and password, and help determine your login status as well as account or data security. We promise not to use cookies for any purposes other than those stated in this policy.

IV. How We Entrust the Processing, Sharing, Transfer, and Public Disclosure of Your Personal Information

We are fully aware of the legal liabilities we shall bear for illegally sharing, transferring, or publicly disclosing personal information that causes damage to users. We assume the obligation of keeping your personal information confidential and will not sell your personal information. All sharing, transfer, and public disclosure of your personal information by us shall be strictly conducted in accordance with the following clauses:

(I) Sharing

We attach great importance to the protection of your personal information. Except for the following circumstances, we will not share your personal information with any third-party other than SJCAM without your separate consent:

With service providers: We may share your personal information with service providers to realize the functions of our products and/or services and enable you to use the services you need normally, including: (1) sharing the corresponding transaction order information and payment amount information with third-party payment institutions that provide payment services; (2) sharing the information required for real-name authentication with real-name authentication service providers; (3) necessary sharing with other suppliers, service providers and business partners related to our services/functions.
With certain business partners: For the purposes of conducting business smoothly, meeting your requirements, performing our obligations and exercising our rights under the relevant user agreement or this Policy, or complying with legal provisions, we may need to share your information with certain partners, including: (1) sharing log information and device information with partners that provide data analysis services (such as online advertising monitoring, data statistics, data analysis, etc.); (2) sharing statistical data on your product usage (such as crashes, app freezes and crashes) with partners that provide stability optimization services (such as application crash analysis, network performance analysis, domain name resolution optimization); (3) sharing your relevant information (such as device information) with partners that provide marketing services (including advertising delivery, marketing).
Necessary sharing with our affiliated companies: To facilitate us in providing you with consistent services based on a unified account system, enable your unified management and personalized recommendation, and safeguard system and account security, your personal information, such as mobile phone account/email account, may be shared between us and our affiliated companies as necessary.
With government agencies: We may be required by public authorities, auditors, or institutions with the right to inspect us to provide personal information to government authorities in accordance with their legal obligations, and such institutions may request us to provide information.
In response to your legitimate needs or with your consent.

If there is any sharing beyond the above circumstances, we will obtain your separate consent in accordance with the provisions of laws and regulations. For third parties with whom we share information, we will require them to provide proof of their data security capabilities and information security qualifications (such as level protection assessment, information security management system, etc.). If the shared information involves the processing of sensitive personal information, we will require the third parties to adopt technologies such as de-identification and encryption to better protect the security of personal information. If you have any objection to the third party’s processing of personal information or find that the third party’s personal information processing activities are risky, please contact us in accordance with the contact information set forth in this policy.

(II) Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

After obtaining your separate consent;
Disclosure based on laws and regulations: Under the circumstances of mandatory provisions of laws and regulations or mandatory requirements of government departments and judicial organs, we may publicly disclose your personal information. When we receive a request for the disclosure of personal information, we will require the requesting party to provide the corresponding legal documents, such as a subpoena or investigation letter. We firmly believe that the personal information we are required to disclose should be as transparent as possible within the scope permitted by laws and regulations. We will conduct a careful review of all requests to ensure that the disclosure of personal information has a legal basis;
Based on the need for our normal management and maintenance of Cloud Storage orders, we will issue penalty announcements for illegal acts such as account violations and fraud that seriously damage the legitimate rights and interests of SJCAM and other users. The announcement information mainly includes the user account and the user’s illegal acts.

(III) Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following cases:

With your consent, we will transfer your personal information to other parties;
Transfer is necessary in accordance with the mandatory provisions of applicable laws and regulations or the mandatory requirements of government departments and judicial organs;
In the event of merger, acquisition, or bankruptcy liquidation, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to be bound by this Policy; otherwise, we will require the company or organization to obtain your consent again.

(IV) Exceptions to the Requirement of Prior Consent for the Sharing, Transfer, and Public Disclosure of Personal Information

In accordance with the provisions of laws and regulations, the sharing, transfer, and public disclosure of personal information do not require prior user consent in the following cases:

Related to our performance of obligations stipulated by laws and regulations;
Directly related to national security and national defense security;
Directly related to public security, public health, and major public interests;
Directly related to criminal investigation, prosecution, trial, and the execution of judgments;
For the purpose of safeguarding the major legitimate rights and interests of you or other individuals where it is difficult to obtain your consent;
Personal information voluntarily disclosed by you to the public;
Collecting personal information from legally publicly disclosed information, such as legitimate news reports, government information disclosure and other channels;
In accordance with the provisions of laws and regulations, the sharing, transfer and public disclosure of personal information that has undergone de-identification processing, and where it is ensured that the information cannot be restored and re-identified to a specific natural person, shall not be deemed as an act of sharing, transferring or publicly disclosing personal information, and the processing of such data shall not require separate notification to users and obtaining user consent.

V. How We Protect and Store Your Personal Information

(I) Storage Period

We will only store your personal information for the period necessary for the purposes stated in this policy and the time limit stipulated by laws, regulations, and regulatory requirements, unless the law has mandatory retention requirements. If you stop subscribing to the Cloud Storage Service, we will provide you with a 60-day material data retention period, and upon the expiration of the retention period, we will permanently delete the material data files you store in cloud storage. If we terminate the Service or our operations, we will immediately stop continuing to collect your personal information, and at the same time, we will comply with the requirements of relevant laws and regulations to notify you in advance, and delete or anonymize your personal information after terminating the Service or our operations, unless otherwise stipulated by laws, regulations, or regulatory authorities.

(II) Storage Location

The material data you upload to cloud storage will be securely stored on servers located in the Chinese mainland.

(III) Storage Security

We have adopted security protection measures that meet industry standards and are reasonably feasible to protect your information and prevent personal information from being accessed without authorization, publicly disclosed, used, modified, damaged, or lost. We will take the following measures to ensure the security of your data:

Use encryption technology to enhance the security of personal information; data exchanged between your browser and the server is protected by TLS protocol encryption, and we provide the HTTPS protocol for secure browsing.
Use trusted protection mechanisms to prevent personal information from being maliciously attacked;
Deploy access control mechanisms to make every effort to ensure that only authorized personnel can access personal information;
Organize security and privacy protection training courses to enhance employees’ awareness of the importance of protecting personal information;
Establish a special data compliance management system, processes, and organization to safeguard information security. For example, we strictly limit the scope of personnel who can access information, require them to comply with confidentiality obligations, and conduct audits.

We will take all reasonably feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for the shortest period necessary to achieve the purposes stated in this policy, unless otherwise stipulated by the laws and regulations of your place of residence.

The internet environment is not 100% secure, and we will make every effort to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are compromised, resulting in the unauthorized access, public disclosure, tampering, or destruction of information and damage to your legitimate rights and interests, we will bear the corresponding legal liabilities. In the unfortunate event of a personal information security incident, we will strictly notify you in a timely manner in accordance with the requirements of the laws and regulations of your place of residence of the basic facts and possible impacts of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly notify you of the relevant circumstances of the incident via email, letter, telephone, push notification, and other means; if it is difficult to notify each individual information subject one by one, we will take reasonable and effective measures to issue an announcement. At the same time, we will also take the initiative to report the disposal of the personal information security incident and perform other obligations stipulated by laws and regulations in accordance with the requirements of regulatory authorities.

VI. How We Protect Your Personal Information

We attach great importance to the security of personal information and take all reasonably feasible measures to protect your personal information:

We will adopt security protection measures that meet industry standards, including establishing reasonable institutional norms and security technologies to prevent your personal information from being accessed, used, or modified without authorization, and avoid data damage or loss.
If we stop operating Cloud Storage, we will immediately stop processing your personal information, notify you of the termination of operations by individual delivery or announcement, and delete or anonymize the personal information we hold about you.
We adopt physical, technical, and management security measures to reduce the risk of loss, misuse, unauthorized access, disclosure, and alteration of personal information, including but not limited to transmission layer data encryption, firewalls and encrypted storage, physical access control, and data access authorization control.
We will regularly conduct personal information protection training to enhance employees’ awareness of the importance of protecting personal information.
We have formulated relevant emergency plans for personal information security incidents, and regularly organize relevant internal personnel to conduct emergency response training and drills to enable them to master their job responsibilities and emergency disposal strategies and procedures.
We strongly recommend that you assist us in ensuring the security of your account by using secure methods and complex passwords. If you find that your personal information has been leaked, especially if your account or password has been compromised, please contact us immediately in accordance with the contact information set forth in this Policy so that we can take corresponding measures. However, we shall not bear any liability for such leaks until we become aware of the situation and take action within a reasonable time.
The internet environment is not 100% secure, and we will make every effort to ensure the security of the personal information we process. In the unfortunate event of a personal information security incident, we will notify you in a timely manner in accordance with the requirements of laws and regulations of: the basic facts and possible impacts of the incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly notify you of the relevant circumstances of the incident via Cloud Storage push notifications, email/short message, telephone and other means; if it is difficult to notify each user one by one, we will take reasonable and effective measures to issue an announcement. At the same time, we will also take the initiative to report the disposal of the personal information security incident in accordance with the requirements of regulatory authorities. If your legitimate rights and interests are damaged, we will bear the corresponding legal liabilities.

VII. Your Rights

In accordance with relevant laws, regulations, standards, and the common practices of other countries and regions, we guarantee that you may exercise the following rights in respect of your own personal information. Please note, however, that if the relevant personal information you apply for has exceeded the shortest period necessary to achieve the purposes stated in this policy or has been deleted, we may be unable to respond to your request for the exercise of personal information rights. The personal information rights you may exercise include:

(I) Right to Know of Personal Information

You have the right to understand the processing of your personal information. You may send an email to app@sjcamhd.com to inquire about the processing of your personal information.

(II) Right to Access Personal Information

If you wish to copy and export the information we have collected from you, you have the right to submit your application by sending an email to app@sjcamhd.com. We will review your application as soon as possible and reply within fifteen working days after verifying your user identity.

(III) Right to Correct Personal Information

If you find that our processing of your personal information contains errors, you have the right to request us to make corrections. You may contact us at any time through the contact information provided on the website or app or send an email to app@sjcamhd.com at any time.

(IV) Right to Delete Personal Information

You may request us to delete your personal information in the following circumstances, unless otherwise stipulated by laws and regulations:

Our collection and use of personal information violates laws and regulations;
Our processing of personal information violates the agreement with you;
Our collection and processing of your personal information is conducted without your consent;
You no longer use our products or services, or you have cancelled your account;
We no longer provide products or services to you.

Your right to request the deletion of personal information shall not apply in the following cases: otherwise stipulated by applicable laws; processing is necessary for the exercise of the right to freedom of speech and information; processing is necessary for the performance of legal obligations; within the scope permitted by applicable laws, processing is necessary for archiving purposes for the public interest, scientific or historical research or statistical purposes, and deletion would seriously damage or prevent the achievement of such processing objectives; or processing is necessary for the establishment, exercise or defense of legal claims and rights.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us (if any) to delete such information in a timely manner, unless otherwise stipulated by laws and regulations or such entities have obtained your independent authorization. When you delete information from our services, we may not delete the corresponding information in the backup system immediately, but we will delete such information when the backup is updated.

(V) Right to Cancel Account

You may cancel your previously registered account through the method specified on our platform or by contacting customer service. When you contact our customer service to cancel your account, we will complete your request within 15 working days; after the account is cancelled, we will stop providing you with products or services and delete your personal information in accordance with your request, unless otherwise stipulated by laws and regulations.

(VI) Right to Transfer Personal Information

You have the right to obtain a copy of your personal information. You may contact our customer service at any time, and we will reply to your request within 15 working days. If technically feasible for our company (e.g., matching data interfaces), we may also transmit a copy of your personal information directly to a third party designated by you in accordance with your request.

It should be noted that if we conduct necessary processing for the public interest or for the exercise of authorized official authority, your right to data portability of personal information will be restricted. In addition, the exercise of the right to data portability of personal information shall not have a negative impact on the rights or freedoms of others.

(VII) Right to Restrict Automated Decision-Making of Information Systems

In certain business functions, we may make decisions solely based on non-manual automated decision-making mechanisms, including information systems and algorithms. If such decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will also provide appropriate remedies.

(VIII) Right to Restrict the Processing of Personal Information

You may restrict our processing of your personal information in the following circumstances, and we will adjust our collection and processing activities in accordance with your request for restricted processing:

You question the accuracy of the personal information we have collected from you, or we are verifying the accuracy of the relevant personal information;
You believe that our processing of your personal information is illegal;
We no longer need your relevant personal information for the processing purposes set forth in this policy, but you need such personal information for legal claims;
When the legal basis for processing your personal information is for the public interest or the legitimate interests of us and third parties.

(IX) Right to Object to and Withdraw Consent to the Processing of Personal Information

You have the right to object to our processing of your personal information for direct marketing purposes at any time, as well as the right to object to automated decision-making, including the analysis of you that has legal effect or a significant impact on you personally.

You have the right to adjust the scope of our continued collection of personal information or withdraw your authorization at any time. After you withdraw the relevant consent or authorization, we will no longer process the corresponding personal information and will be unable to continue providing you with the services corresponding to the withdrawn consent or authorization. Your adjustment of the scope of authorized consent shall not affect our processing of your personal information based on your consent or authorization prior to the adjustment.

You may exercise your right to object or withdraw your consent or authorization by contacting app@sjcamhd.com.

If you wish to withdraw your consent to receiving “product promotion information push”, you may also withdraw your consent or authorization through [App – Settings – Notification Settings], or submit a request to unsubscribe from promotion information emails through the unsubscribe method we provide in the push emails.

(X) Response to the Above Requests

If you are unable to exercise the above rights, or you believe that we have violated the provisions of any laws or administrative regulations or the agreement with you regarding the processing of your personal information, you may contact us through the channels set forth in this policy. To ensure security, you may need to submit a written request or prove your identity by other means. We may first require you to verify your identity and make an appropriate response within 30 natural days in accordance with applicable laws. We will retain your requests and our responses (including any supporting documents) in accordance with the requirements of applicable laws.

We will not charge any fees for your reasonable requests in principle, but we may charge a certain cost fee for repeated requests or requests that exceed a reasonable limit, as appropriate. We may refuse requests that are frivolously repetitive, require excessive technical means (e.g., the need to develop new systems or fundamentally change current practices), pose risks to the legitimate rights and interests of others, or are impractical (e.g., involving information stored on backup tapes).

In the following circumstances, we will be unable to respond to your request in accordance with laws and regulations:

Directly related to national security and national defense security;
Directly related to public security, public health, and major public interests;
Directly related to criminal investigation, prosecution, trial, and the execution of judgments;
There is sufficient evidence to show that you have subjective malice or abuse of rights;
Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
Involving trade secrets.

If we respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete the corresponding information in a timely manner, unless otherwise stipulated by laws and regulations or such entities have obtained your independent authorization.

VIII. Protection of Minors’ Personal Information

The cloud storage service is intended for adults and not for minors under the age of 14. We will not actively collect, or collect with knowledge, the personal information of minors. If we find that we have collected the personal information of minors without the consent of their guardians, we will delete the relevant data as soon as possible after becoming aware of it. If you believe that we may improperly hold personal information from or about minors, please contact us.

IX. Notices and Revisions

To provide you with better services and with the development of our business, this policy will be updated accordingly. However, without your consent, we will not reduce the rights you are entitled to in accordance with this policy. We will release updated versions on our website and mobile terminals and remind you of the updated content through appropriate means before the effective date. Please also visit our platform to keep abreast of the latest privacy policy in a timely manner.

For major changes, we will also provide a more prominent notice (such as pop-up windows and push notifications via the SJCAMX App) explaining the specific changes to the Privacy Policy.

Major changes referred to in this policy include but are not limited to:

Significant changes in our service model, such as the purpose of processing personal information, the type of personal information processed, the method of using personal information, etc.;
Significant changes in our ownership structure, organizational structure, etc., such as changes in ownership caused by business adjustments, bankruptcy, mergers and acquisitions, etc.;
Major changes in the main objects of the sharing, transfer, or public disclosure of personal information;
Significant changes in your rights to participate in the processing of personal information and the methods of exercising such rights;
Changes in our department responsible for the security processing of personal information, contact information, and complaint channels.

We will also archive the old versions of this policy, and you may request to review them from us.

X. How to Contact Us

If you have any questions, comments or complaints about our Privacy Policy, or wish to contact us, please do so in the following ways:

For specific questions related to the software or your personal account (including obtaining your own personal information), please send an email to app@sjcamhd.com;
For general consultations or complaints about privacy issues, please send an email to app@sjcamhd.com, or write to the following address: 3/F, Building C, No.2 Building, 1st Road, Shangxue Industrial Zone, Bantian Street, Longgang District, Shenzhen City, Guangdong Province, China.

If you are not satisfied with our reply, especially if our personal information processing activities have damaged your legitimate rights and interests, you may also file a complaint or report with the regulatory authority in your place of residence.