Last Updated: July 15, 2024
Effective date: July 15, 2024
Version: V1.0
Jiangsu Niu Electric Technology Co., Ltd. (hereinafter referred to as
“Havion”, "we”, “us”, “our”) is the service provider and operator of the
Havion Security Camera product line and services (including all devices,
linked mobile devices and our mobile applications, hereinafter referred to
as "the Products and Services").. We fully respect your privacy and will
do our utmost to protect the security of your personal information. We may
collect, use or otherwise process your personal information based on your
consent or in accordance with the relevant provisions of applicable laws
and regulations during your use of the Products and Services. This Privacy
Policy (hereinafter referred to as “Policy”) is meant to help you
understand how we collect, use, disclose, process and protect your
personal information with regard to your use of the Products and Services,
your rights regarding the personal information provided to us, and how we
safeguard your rights. This Policy applies to all the Products and
Services that refer or link to this Policy, including applications,
mini-programs, websites, SDK for third-party websites or applications,
APIs and other forms that may be available in the future whether you
access our products and services using a computer, mobile phone, tablet or
television.
Before using our products or services, providing your personal information
to us or allowing us to collect your personal information, please read
this Policy carefully to understand our practices regarding your personal
information and access it frequently to understand the updates to this
Policy. If we update this Policy, we will notify you by announcements in
the product or website to let you know about the changes we made. By
accessing or using our Services after we have placed such a notice, you
are deemed to have accepted the updated Privacy Policy. You can check the
“Effective Date” posted at the top of the Privacy Policy for the latest
update time.
If you have any questions, please feel free to contact us by the following
means:
[https://www.havion.com]
You can access this Privacy Policy by the following means:
Webpage:https://www.havion.com ->
Bottom -> Privacy Policy
App: Havion Security APP > Account > About havion Security> Privacy Policy
I. How We Collect and Use Your Personal Information
II. How We Store and Protect Your Personal Information
III. How We Share, Transfer and Disclose Your Personal Information and
Data
IV. How Your Personal Information is Transferred Across Borders
V. Your Rights to Your Personal Information
VI. How We Handle the Personal Information of Children
VII. Third-Party Service Providers and Services
VIII. Supplement and Update of the Policy
IX. How to Contact Us
Havion firmly believes that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by us, regardless of where such natural person lives. We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. If we intent to use your personal information for other purposes not specified in this Policy, we will obtain your consent at that time.
When using our products and services, please be aware that privacy and
video surveillance laws in your area may apply. It is your responsibility
to ensure that you comply with all relevant laws. For instance, you may
need to post a notice informing visitors to your home that our products or
services are in use. Recording or sharing video or audio content that
includes other individuals, or capturing their facial features, may impact
their privacy rights.
You have the right to choose whether or not to provide the personal
information when you use the Products and Services or when we have
requested. You are not required to provide your personal information to
Havion , but in some cases, if you choose not to do so, we will not be
able to provide you with related products or services, nor will we be able
to respond or resolve the problems you've encountered. We will collect and
use your personal information only for the purposes described in this
Policy. The following describes your personal information that we collect:
| Scenarios and Purposes | Types of Personal Information | Legal Basis for Processing Personal Data |
| To provide the right version of the application for your mobile device. | Device information: model (e.g. CPU), brand, app package name, OS version. | Performance of a contract with you. |
| Provide you with account registration and login services to identify and verify your identity. | Login information (email and password); and choose your country. When you use the Havion Security APP, you can add your nickname and avatar for us, but if you don’t provide these information, it does not affect your use of the basic business functions of the App |
Performance of a contract with you and Base on your consent. |
| To help you connect your devices and control your devices settings. | Device technical data: device name, device model, serial number, IP address, MAC address, OS version number, sensor data, status and security mode, software version, battery level, CPU data, SD card data, storage and mobile device information. Network information: Wi-Fi, Internet and Bluetooth connection information. | Performance of a contract with you. |
| To help you operate your devices. | Device technical data: device specifications,operating system, device name, device model, serial number,
sensor information, status and mode, software version, battery level, CPU data, SD card data, storage and mobile
device data. Network information: Wi-Fi, Internet and Bluetooth connection information. Location information,;camera and photos. Operation logging: device and app log files, settings (including settings history), usage history, device and service settings, and device status |
Performance of a contract with you. |
| To communicate with you and respond to your feedback and requests. You can give us feedback on your questions and comments through our Service Center or App Feekback channel. | Contact information(your name,email); Content of communications(including the problems and requests you describe and the pictures and videos you provide); Account data; Purchase data; Device data; Usage data. |
Performance of a contract with you and necessary for our legitimate interest (to respond to your requests, customers' reviews, and update our products/services). |
| Device Sharing | When you share the devices you have added in the Havion Security APP with other users, they may gain access
to your personal information, such as 【account/user name/e-mail address/device information】. Additionally, we
may collect and process the personal information of these users , such as 【account/user name/e-mail address】.
Therefore, please inform and obtain consent from others before sharing.
When you share the devices you have added in the Havion Security APP with other users, they may gain access to your personal information, such as 【account/user name/e-mail address/device information】. Additionally, we may collect and process the personal information of these users , such as 【account/user name/e-mail address】. |
Performance of a contract with you and Base on your consent. |
| To troubleshoot and resolve the crash, improve product stability. And for the network security, specifically for the prevention, detection, and protection against fraud, abuse, criminal activities, and other abnormal activities. | Android users: Device technical data: phone model, phone brand, Android system version, Android system api level, vendor system version, cpu architecture type, whether the device is rooted or not, amount of disk space taken up, amount of sdcard space taken up, amount of memory space taken up, network type, name and PID of the process that the app is currently running. iOS User: Device technical data: device model, OS version, OS internal version number, wifi status, cpu attributes, memory space remaining, disk space/disk space remaining, state of the phone at runtime (memory occupied by processes, virtual memory, etc.), idfv, whether jailbroken or not, region code. Other: network information and usage data. |
Performance of a contract with you and necessary for our legitimate interest. |
Our App may request your permission to access your mobile device's
connection information, storage capabilities, sensors or other features.
We only require access when it is necessary or useful for the provision of
our Services:
Wi-Fi, Internet and Bluetooth -- The App requires Wi-Fi, Internet, and
Bluetooth permissions to link the App to the device, and to connect your
system to our server. Blocking these permissions would impair the
functions of our devices.
Camera and photos -- The App may require access to your mobile device's
camera or photo gallery to enable certain functions, such as saving the
video or picture that you record or capture, uploading a picture as your
avatar, or providing.videos or pictures for us through App Feedback
channel.
Microphone -- The App may seek permission to access your mobile device's
microphone to enable certain features. You may refuse to give permission
or withdraw your permission at any time through the privacy settings of
your mobile device.
Location -- The App requires location permission to automatically fill in
your Wi-Fi network during the setup of the device.
Push notification -- The App seeks your permission for push notification
on your mobile device, which will be used to notify you about the status
of your device.
Storage-- The APP seeks your permission for accessing photos, media and
files on your devices.
Where permitted by law, we may obtain your personal information from other
individuals, business entities, public channels or other third parties
acting at your direction, our partners who work with us to provide our
products and services and assist us in information security and fraud
prevention, and from other lawful sources. We will explain it to you at
the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your
device or your use of services, which will be explained to you at the time
of collection and we will obtain your consent.
In order to better improve our product layout and provide you with great
services, we may conduct research, statistical analysis and prediction on
the collected information in an anonymized manner (including machine
learning or model algorithm training by using anonymous data). We will
take technical measures and other necessary measures to process such data,
so that the data cannot be re-identified to specific individuals, nor can
it be recovered. In accordance with the applicable laws and regulations,
such processed data can be used without separately notifying you or
obtaining your consent.
1. How we store your personal information
The personal information collected with your consent will be stored in
accordance with the laws and regulations on the personal privacy data
protection of the countries concerned. To the extent not prohibited by
local laws and regulations, we may also store the collected personal
information in countries or regions outside the country where the business
is located.
Currently Havion may store your personal information in America, Australia
and Germany.
In particular:
The personal information collected and generated during our operations
in North American Area will be stored on servers located in America
.
The personal information collected and generated during our operations in
Australasia will be stored on servers located in Australia.
The personal information collected and generated in business outside the
North American Area and Australasia will be stored in the servers in
Germany.
According to business conditions, we may use servers in other regions or
countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the business is
located, or in other countries or regions to the extent that doing so does
not violate laws and regulations, we will retain it in accordance with the
relevant laws and regulations on data storage. At the same time, we will
consider the characteristics, scope and purpose of personal information
processing, the risks that may be encountered in the processing, and the
serious consequences caused by the damage, etc., and implement the
necessary security measures. For example, we will use encryption and
de-identification methods to store the personal information collected. We
will also keep the information for the shortest storage period specified
by law. For those not specified by law, we will retain the information
according to the shortest storage period required for business. For data
that exceeds the storage period, or data that you request us to delete, we
will delete said data accordingly or take other appropriate measures
without violating the relevant laws and regulations.
When sharing, transferring, and disclosing your personal information, we
uphold the principles and requirements of minimization, necessity, and
legality. Under normal circumstances, we do not share, transfer or
disclose your personal information externally. However, to the extent
permitted by applicable laws and regulations, we may share, transfer and
disclose your personal information in the following situations:
1. How we share your personal information
We do not sell any personal information to third parties. In order to
provide you with timely services, your personal information may be shared
with our affiliated companies. We will only share your information within
our affiliated companies for legitimate and explicit purposes, and only
share the information necessary to provide the services, and are bound by
the purposes stated in this Privacy Policy. If a purpose concerned is not
included in this Policy, we will state it in the corresponding privacy
policy or notice of the specific product or service.
We may share the necessary personal information with authorized
third-party partners (including technical service providers, data storage
service providers, after-sales service providers, third-party SDK service
providers, etc.) for the performance of certain features or to provide you
with better service and a better user experience. For example, in order to
roubleshoot and resolve the crash, improve product stability, we embed
third party SDK, which is called Bugly SDK and is developed by Shenzhen
Tencent Computer System Co. or other similar applications of authorized
partners in this Application. How Bugly SDK collects and protects your
personal information is detailed in the . Before using our products or
services or allowing us to collect your personal information, we also
suggest you reading carefully to understand our practices regarding your
personal information. We uphold the principles of minimization, necessity,
and legality to carry out such sharing. Before sharing information, we
will sign strict confidentiality agreements with authorized partners and
require them to take relevant confidentiality and security measures to
process personal information in accordance with this Policy and applicable
laws in your jurisdiction. In addition, we will also require them to
provide data security capabilities and information security qualifications
(e.g., grade protection assessment, information security management
system). When we embed the third party SDK or other similar applications
of authorized partners in this Application, we will notify you promptly
and request the SDK service provider that obtains the information to
protect your data security.
In order to provide evaluation, analysis or other business services, we
may also share your non-personal information with third parties. For
example, we may use aggregated data to help partners (e.g., advertising
service providers) understand the effectiveness, feedback and usage trends
of their services.
In the event of a merger, acquisition or bankruptcy liquidation, asset
transfer and other related transaction, if a personal information transfer
is involved, we will require the new entity or organization holding your
personal information to continue to be bound by this Policy through an
agreement or other appropriate measures, and we will require such subject
to take confidentiality and security measures of a degree no less than the
requirements of this Policy to process personal information.
2. How we transfer your personal information
Havion will not transfer your information to any other parties, except in
the following circumstances:
(1) Obtain your explicit consent.
(2) If Havion is involved in a merger, acquisition or sale of all or part
of its assets, which may affect your personal information, we will issue a
prominent notice via email and/or on our website or other appropriate
methods to inform you of any changes in the ownership and your rights of
your personal information, and any choices you may have about your
personal information.
(3) In the case that has been explained in this privacy policy or notified
you by other means.
3. How we disclose your personal information
According to the legal requirements, legal procedures, litigation and/or
requests from government departments and authorities, Havion may need to
disclose your personal information. If the disclosure is necessary or
appropriate for national security, law enforcement, or other matters of
public importance, we may also disclose information about you.
Additionally, we may share your personal information with:
(1) Our attorneys, lawyers, accountants, auditors, or similar consultants,
when we request them to provide professional advice.
(2) Investors and other relevant third parties, if actual or potential
sales or other company transactions occur and are related to entities
within our group.
(3) Other third parties, for example, the disclosure of specific
information with your authorization.
For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and
with your authorized consent, we may transfer your personal information to the resources or servers stipulated in
section III of this Policy for storage or processing, we may also transfer your personal information to third-party
service providers and business partners and your data may therefore also be transmitted to other countries or
regions. The privacy protection laws of these countries or regions may be different, and the jurisdiction in which
these global resources or servers are located may or may not protect personal information to the same standards as
in your jurisdiction. However, we will still strive to comply with our Privacy Policy to protect your personal
information, and we will follow the legal requirements of the country or region where the personal information is
located to carry out the corresponding cross-border transfer and other processing of personal information.
In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to
our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take
appropriate security measures and safeguards to make sure that all such transfers meet the requirements of
applicable local data protection laws.
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.
We inform you how we collect and process personal information through this Policy or in the form of a privacy policy or notice of the specific product or service. You have the right to confirm or reject such collection and processing via a check box or other methods. However, after you reject, some features that require your explicit authorization and consent to use may no longer be available. You can directly access the personal information you have provided to us in the interface of our products or services. For those that you are unable to access, you can send an email to [Service@havion.com]. We will handle it promptly after receiving your email.
When your personal information is changed, or when you find that your personal information collected and processed
by us is inaccurate or incomplete, you have the right to ask us to make corrections or additions. You can directly
correct or modify some of your personal information on the relevant product/service function pages. When your
personal information collected by us has fulfilled the purpose of collection or is no longer required, or when you
find that our collection and processing of your personal information violates the provisions of laws and regulations
or this Privacy Policy, you have the right to ask us to delete the relevant personal information. For personal
information that we have not provided you with a channel for correction or deletion, you can request that it be
corrected or deleted by contacting [Service@havion.com].
However, we may not grant your deleting request in some situations, for example, if you ask us to delete your
transaction data when we are legally obligated to keep a record of that transaction to comply with the applicable
local law. Please also kindly note that if you request to delete your information from our products and services, we
may not remove the corresponding information from the backup system immediately due to some applicable local laws
and technological limitations, however, we will securely store your personal information and isolate it from any
further processing until the backup is updating or can be deleted or be made anonymous.
To achieve the respective features of our various products or services, we will require necessary personal
information in accordance with the applicable local laws. This is described in the "How We Collect and Use Your
Personal Information" part of this Policy. You can withdraw your consent previously granted to us for a specific
purpose by deleting information, turning off device features, and requesting to withdraw consent, including the
collection, use and/or disclosure of your personal information that we manage or control. You can email us at [Service@havion.com] for above operations. We will process your request within
a reasonable time after you send the request, and thereafter will not collect, use and/or disclose your personal
information in accordance with your request.
If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of Havion
Security Doorbell serial products and its Service. The withdrawal of your consent or authorization will not affect
the validity of our previous processing activities based on your consent.
You have the right to lodge a complaint by sending us an email at [Service@havion.com]. We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information violates your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.
You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings. For example, you can prefer turn on or turn off the permissions of “Location Access”, “Camera”, “Text Message”; you can also obtain detailed information regarding the device security status in “Settings”. If you have agreed to such permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can turn it off via “Permission Management” > “App Permissions”(Depends on your device and app version) or contact us via [Service@havion.com] to change your decision.
You can request to cancel through the “Logout” settings provided in the service or by contacting us via [Service@havion.com]. We hereby kindly remind you that, if you wish to cancel a certain service or account, such cancellation may prevent you from using some of Havion Security Doorbell serial products features and its services, and such act of account cancellation is irreversible. Once you cancel your account, we will delete or de-identification your relevant information. You also can apply for the cancellation of your account directly in the APP.
Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects
rights:
(1) Right to restriction processing. You have the right to request our restriction on the processing of your
personal information. We shall consider the grounds regarding your restriction request. If the grounds are in the
compliance with applicable data protection laws, we will process your personal information under applicable
circumstances in such laws and notify you before the restriction of processing is lifted.
(2) Right to automated decision-making. You have the right to refuse the processing based on automated
decision-making, including profiling and other automated processing which may have legal or similar effects on you.
(3) Right to data portability. You have the right to apply for your personal information to be transmitted to
another data controller in a structured and commonly used format.
We have the right to refuse to process your requests or only respond to some of your requests where an
exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are
manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.
We do not provide our products or services to children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children’s personal data or use children’s personal information for the purposes of marketing and our device does not actively ask for children's information. However, we are aware that the microphone and camera on our device may incidentally include footage of children. Please review the Children's Data Protection section, which describes how we collect and handle data which may contain children's information.If you find that a child’s information has been collected to us, please send an email to [Service@havion.com] to contact us. We will remove the relevant information as soon as possible. If we become aware that a child has provided us with personal information, we will take steps to delete their personal information from Havion as soon as possible.
With the upgrades of this Application, you may receive links to third-party websites or content and services provided by third parties other than us during your use of the Products and Services, and some third parties’ products or services can be accessed in the form of SDKs and others. You can choose whether to visit or accept the third-party websites, products, and services at your sole discretion. Our Privacy Policy does not apply to products and services provided by any third party. Since we are not able to substantially control a third party, we are not responsible for the third party’s collection and processing of your personal information. Therefore, when you submit any information to a third party, please carefully review the third party’s privacy policy and take care of your personal information.
We reserve the right to update or modify this Policy from time to time in order to reflect the changes in our
business, technology and applicable law and practice. In case of any modification of this Policy, we will notify you
of the latest Policy here (this webpage), or by posting it on our official website or sending you separate
notifications. Please pay attention to this website and the notifications we send to you for the latest updates of
this Privacy Policy. Although this Privacy Policy may be modified, your rights under this Policy will not be
diminished without your explicit consent.
We will ask for your explicit consent again in accordance with applicable laws before we collect additional
personal information from you or when we use or disclose your personal information for new purposes. Your continued
use of the products and services on the website, mobile and/or any other device constitutes your agreement to the
updated Privacy Policy.
The content of the Products and Services described herein may vary according to the type of product you use,
your system version, or requirements of local laws and regulations.
If you have any comments, questions or concerns with respect to our Privacy Policy or practices
of personal information protection, please contact us via:
Email: Service@havion.com.
We will review your privacy or personal information requests as soon as possible and respond to you in 15-30
days after verifying your user identity. If your request itself involves any complicated or significant issue, we
may ask you for more information.
If you are not satisfied with our response, especially when you believe that your legitimate rights and
interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your
jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be
applicable based on your circumstance.
Thank you for your time to read our Privacy Policy!