Privacy Policy

Ⅰ Our Promise

This Privacy Policy describes how HGsmart collect, use, disclose, process, and protect the information you provide to us through the HGsmart app when using our products or services. If we ask you to provide certain information in order to verify your identity when using HONEYGUARDIAN products or services, we will use this information in strict accordance with this Privacy Policy and/or our User Terms and Conditions.

This Privacy Policy was developed with full consideration of your needs taken into HGsmart account. It is important that you fully understand our personal data collection and usage practices as well as full confidence that ultimately, you have control of any personal information provided to HGsmart.

In this Privacy Policy, "personal information" means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information HGsmart has access about that individual. Such personal information may include but not limit to the information you provide to us or upload, and device information.

By using HONEYGUARDIAN products and services or other acting permitted by the applicable laws, you are deemed to have read, acknowledged and accepted all the provisions stated here in this Privacy Policy, including any changes we make from time to time. In order to comply with applicable laws, e.g. General Data Protection Regulation in Europe Union, we will specifically seek prior explicit consent to the particular processing (e.g. automated individual decision-making) of special categories of personal data. Furthermore, we are committed to protecting the privacy, confidentiality and security of your personal information by complying with applicable laws, and we are equally committed to ensuring that all our employees and agents uphold these obligations.

We are well aware of the importance of your personal information so that we will take appropriate security measures to protect it in accordance with mature security standards of the industry. Ultimately, what we want is the best for all our users. If you have any questions about the data processing practices summarized in this Privacy Policy, please contact support@honeyguardian.com so that we can best see to your needs. We will be happy to address them directly.

ⅡInformation We Collect

1. Types of information collected

In order to provide our services to you we will ask you for personal information that is necessary for us to successfully provide those services. If you do not provide us with this personal information, we may not be able to provide our products or services to you.

We will only collect the information that is necessary for its specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. We may collect the following types of information (which may or may not be personal information):

• Information you provide to us or upload: HGsmart account information (e.g. your security related information, name, birthday, gender), or data you may sync with the device you use to access the HGsmart portal, information used to create your account or related to your account setup on the our portal, devices you add or information that you send, and feedback.
• Device and Usage Information: To ensure the basic functionality of our APP (including Bluetooth device pairing, device control, troubleshooting, and security protection), we may collect the following technical information from your handheld device: device model, manufacturer, operating system version, network status (e.g., Wi-Fi connection), IP address, application identifier, application version and distribution channel, session start/end timestamps, language and time zone settings. All collected information is used solely for improving user experience and ensuring service stability, and is not linked to your personal identity.
• Location information (only for specific services/functionalities): Only when you grant permission and enable device location will we collect precise location data to offer find device, and location‑based services. You can revoke this permission at any time in your system settings.
• Log information: information related to your use of certain functions, apps and websites. For example, cookies and other anonymous identifier technologies, IP address, network request information, temporary messaging history, standard system logs, and crash information.
• Other information: environmental characteristics value (ECV) (i.e. value generated from HGsmart Account ID, phone device ID, connected Wi-Fi ID and location value).
• HGsmart account credentials: information related to your account credentials. For example, password, associated mailbox.etc.
• Storage permission: Part of our services will generate some pictures or videos in the App, which need to be saved to your mobile phone(s), and meanwhile some services need to call the existing videos or pictures in your mobile phone(s) so we will ask you for storage permission.
• Permissions for Smart Visualization Devices
  • When you use a video-enabled device with such functions as video preview, live, and playback, to ensure the best possible experience of the functions and our services, the following information will be asked for collection: the serial number(s) of your device(s), the intranet and extranet IP of your device(s), network type(s), current network status, and the (cellular) operator(s) of your client terminal device(s), client type(s), client version number(s), operating system version(s), the type(s) of operating system, the model number(s) of your device(s), the screen width, height, orientation and density. All the information above is required for the functions mentioned before. In case that you deny the access to the information, we will not be able to provide corresponding services for you.
  • When you perform video preview and live, we will collect the screenshots of the videos played in your device(s). The screenshots are only used for display to facilitate you to identify the information of surveillance videos, and you can refuse us to collect them through setting private information permissions. If you do so, you will not be able to view the aforementioned screenshots on the home page of surveillance videos, but the preview and replay functions will not be affected. It shall be clear that we do not and are unable to view or use any of your video contents and/or screenshots of videos unless you additionally subscribe a value-added service of video-based analyses and authorize HGsmart App accordingly.
  • When you perform the function of two-way intercom on smart IoT video-type devices, we will ask you for microphone permission. You can also turn off it through system settings to refuse any collection, which will make you unable to use the function, but will not affect the operation of your hardware device or other functions of HGsmart App.
  • When you turn on notification function, we will collect the video screenshots taken by your camera as the contents of notifications and push them to you. As an optional feature, you can prevent us from pushing notifications to you by denying the permission, or you can deny this feature by turning off notification permission in device settings.

2. How We Use Your Personal Information

We collect your personal information primarily to provide our products and services to you and to fulfill our legal obligations.

We may use your personal information for the following purposes:

• Providing, processing, maintaining, improving, and developing our goods and/or services, including those delivered through your device or the HGsmart App;
• Communicating with you about device updates, firmware/software upgrades, customer support, and important notices;
• Marketing activities (only with your separate consent), such as sending promotional materials and product updates. Please refer to the "Direct Marketing" section below for further details;
• Statistical analysis to generate aggregate usage statistics that help us improve our services (such statistics do not identify any individual);
• Storage and record-keeping as required by law or for our business operations;
• Providing local services without communicating with our servers;
• Identity verification and security to verify your identity, prevent fraud, and investigate violations that may affect you or our legitimate interests;
• Other purposes with your separate consent.

More detailed explanations of certain use cases:

• Account creation — Information collected during account registration is used solely to set up your personal profile.
• Location-based services — When you use the App and connect devices, we use approximate location to determine the device time zone, ensuring correct time display and optimal timer experience. You may disable this at any time in your device settings.
• Device pairing and control — To verify device authenticity, we validate factory MAC and DID information. During network configuration, you enter your Wi-Fi name and password, which are used only for that connection, encrypted and stored locally (not uploaded to our servers). You may delete this information at any time. We also analyze IP and network signal strength to choose the best connection and maintain stability.
• Device status display — Allows you to remotely check whether your device is running.
• Automated tasks — Based on event information reported by your added devices (subject to your privacy authorization for each device), you may create customized automation rules.
• Push notifications — We use your account identifier (rather than IMEI or other permanent device IDs) to send device-related notifications to you.
• Identity verification — We use EVC mechanism to verify your identity and prevent unauthorized logins.
• Feedback collection — Your voluntary feedback is valuable; we use your contact information to respond and track resolution.
• Sending important notices — We may occasionally send you notifications about device malfunctions, customized device alerts (based on your purchased add-ons), or changes to our terms and policies.

3. With whom we share your information?

We do not sell any personal information to third parties.

We hereby commit that we will never sell your personal information to any third party.

To provide you with the products or services you have requested, we may share your information with the following external parties to the extent necessary:

• Our affiliates (whose businesses cover communications, social media, technology, and cloud services);
• Third-party service providers (e.g., data analytic, logistics, telecommunications, cloud storage, customer support, and promotional agencies).

Such third parties are permitted to process your information only for the purposes set out in this Privacy Policy, and are strictly bound by our data confidentiality and security requirements. We contractually require all such third parties to comply with the privacy standards applicable in your home jurisdiction, and they are prohibited from using your information for their own marketing or any other unauthorized purposes.

Third-Party Software Development Kits (SDKs)

To enable the HGsmart App to function properly on various mobile devices, and to provide identity authentication, security protection, push notifications, third-party platform login, and sharing features, we integrate third-party SDKs (provided by device manufacturers, social platforms, and telecommunications operators).

Some third-party SDKs may call your device permissions or access certain information, which may include: location, read/write access to external storage, phone status and identity, WLAN connection status, running applications list, and Bluetooth status. For details on each SDK's specific permissions and privacy practices, we encourage you to refer to their independent service agreements and privacy policies.

4. Information not requiring consent

We may share de-identified aggregate information (such as consumer trends or transaction statistics of user groups) with third parties, including advertising partners on our website, for commercial analysis or marketing purposes. Such information does not identify any specific individual.

In addition, HGsmart may collect, use, or disclose your personal information without your consent only to the extent explicitly permitted by applicable local data protection laws (e.g., in response to a legally valid subpoena or lawful government directive). Furthermore, if we have a good faith belief that disclosure is necessary for the following purposes, we may also disclose your information without your consent:

• To protect our legitimate rights or to ensure your safety and the safety of others;
• To investigate and prevent fraudulent activities; or
• To respond to lawful requests from competent government authorities.

Ⅲ Security Commitment

1. Security measures

(1) We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure, or other similar risks, we have put in place reasonable physical, electronic, and managerial procedures to protect the information We collect from you during your use of the HGsmart app. We will take all appropriate measures to protect your personal information. For example, When you send information to our home server from your HONEYGUARDIAN device or receive information through the same channel, we make sure that it is encrypted using a number of protocols including Secure Sockets Layer (SSL).

(2) All of your personal information is stored on secure servers and protected in controlled facilities. We classify your data based on importance and sensitivity, and we guarantee that your personal information is always protected by the highest level of security. We also guarantee that employees and third-party service providers who provide products and services to you by accessing this information will be held under strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet such obligations. Similarly, we have special access control measures for cloud-based data storage. In summary, we regularly review our information collection, storage, and processing practices, including physical security measures taken in order to prevent any unauthorized access and use.

(3) We will take all practicable steps to protect your personal information. You should, however, be aware that the use of the Internet is not entirely secure, and for this reason. Because of this, we cannot guarantee the security or integrity of any personal information which is transferred from you or to you via the Internet.

We will take upon the personal data breach, notifying the breach to relevant supervisory authority or under some circumstances, notifying the personal data breach to the data subjects by complying with applicable laws, including your local data protection legislation.

2. What you can do

(1) You can play your part in safeguarding your personal information by not disclosing your login password or account information to anybody unless such person is duly authorized by you. When you log into HGsmart App as a HGsmart account user, no matter when, and especially if you are using another person's computer or a public Internet portal, you should always log out at the end of the session.

(2) HG cannot be held responsible for lapses in security caused by third party accesses to your personal information as a result of your failure to keep your personal information private. Notwithstanding the foregoing, you must immediately notify us if any online users access your HGsmart account without permission or if any other security breaches occur.

(3) We encourage parents or guardians to instruct minors under the age of eighteen to use our Services. If you are under the age of 14, or under the age of majority under the laws and regulations of your jurisdiction, we recommend that you ask your parent or guardian to read this Policy and use our Services with your parent's or guardian's consent, but please avoid providing us with any personally identifiable information about yourself. If your guardian does not consent to your use of our services in accordance with this Policy, or if you actually provide us with information that identifies you personally, please terminate your use of our services immediately and notify us promptly so that we can take appropriate action in accordance with applicable law.

Your assistance will help us better protect your personal information.

3. Retention policy

We retain information we collect about you as long as it is still needed for the purposes we obtained it or as long as it is needed to comply with applicable legal requirements or permissions. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information. If further processing is for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to the applicable laws, the data can be further retained by HONEYGUARDIAN even if the further processing is incompatible with original purposes.

4. Accessing other features on your device

Our application may need to access certain features on your device, for example, Wi-Fi network status. This information is necessary for these applications to be able to run on your device and for you to be able to interact with them. You can close the application on your device at any time, or you can contact us at support@honeyguardian.com to revoke your consent.

5. Your Rights

• Turn on or turn off the user experience planning and location access features;
• Log into or log out of your HGsmart account;
• Access, update, correct, erase or restrict processing; If you previously agreed to let us use your personal information for the purposes described above, you can change your decision at any time by writing us a letter or sending an email to support@honeyguardian.com, update, correct, erase or restrict processing your personal information.
• If you are a Europe Union user under General Data Protection Regulation (GDPR):
  • you have the right to obtain from us the erasure of your personal information. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures, if the grounds apply to GDPR.
  • you have the right to obtain from us the restriction of processing your personal information. We shall consider the grounds regarding your restriction request. If the grounds apply to GDPR, we shall only process your personal information under applicable circumstances in GDPR and inform you before the restriction of processing is lifted.
  • you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
  • a structured, commonly used format and transmit the information to another data controller. HGsmart Account can be accessed or changed by using your device to log into your account.
• Withdrawal of consent: You can submit a request by sending an email to support@honeyguardian.com, in which you can request to withdraw your consent for us to collect, use and/or disclose any of your personal information that we hold or control. We will process your submission within a reasonable amount time, after which, we will abide by your request and no longer collect, use, and/or disclose your personal information. Please recognize that your withdrawal of consent may result in some legal consequences. Depending on the extent of your withdrawal of consent for us to process your personal information, it may mean that you will not be able to enjoy our products or services.

Ⅳ Miscellaneous

1. Privacy Policy updates

We periodically review our Privacy Policy, and we may update it to reflect changes in our information practices. If we make a substantial change to this Privacy Policy, We will notify you by email (using the email address specified in your HGsmart account), by releasing a notice in the HGsmart app, or by contacting you via your mobile device. This will allow you to understand what information we collect and how we use it. These kinds of changes to this Privacy Policy will be effective starting on the date specified in the notice or on the website. We recommend that you visit this page regularly for the latest information on our privacy practices. Your continued use of products and of website, cell phone and/or any other device-based services will be deemed as your acceptance of the updated Privacy Policy. If we collect additional personal information from you, or if We wish to use or reveal your personal information for a new purpose, We will once again seek your consent.

2. Do I have to agree to all terms and conditions of third parties?

Our Privacy Policy does not apply to products and services provided by third parties. HONEYGUARDIAN Products and services may include third party products and services, as well as links to third-party websites. When you use these products or services, they may also collect your information. Because of this, we strongly urge you to spend time reading the privacy policies of these third parties, just as you have read ours. We do not take any responsibility for the way in which third parties use the personal information they collect from you, nor do we have any control over how they use it. Our Privacy Policy does not apply to other websites whose links can be accessed through our services.

3. Social media (features) and gadgets

Our app contains some social media features, like "share" buttons. These features may record your IP address and the pages that you have browsed on our site. They may also set cookies that enable functionality and operation. Any interaction that you have with these features is subject to the individual company's Privacy Policy.

4. Contact us

If you have any comments or questions about this Privacy Policy, or if you have any questions about HG's collection, use or disclosure of your personal information, HG provides channels for you to provide feedback, hoping to provide you with satisfactory solutions:

• App Feedback: You can submit your feedback in the "HGsmart" mobile app "Me" > "Feedback"
• Email contact: support@honeyguardian.com

Thank you for taking the time to familiarize yourself with our Privacy Policy!

HONEYGUARDIAN