Realsee's Privacy Policy

 

Latest Release Date: 21/10/2020

Effective Date: 21/10/2020

 

Reminders

This Privacy Policy is intended to describe how we collect, process, share and protect your personal information when you use Tianjin Xiaowu Information Technology Co., Ltd.and websites or mobile applications ("Realsee Service") of its associated entities ("Realsee" or "we"). When you are accessing or using and continuing to access or use Realsee Service after we have updated this Privacy Policy, it indicates that you are fully accepting this Privacy Policy (including updates). If you do not agree with any of the provisions of this Privacy Policy (including updates), please immediately stop accessing or using Realsee Service.

 

Contact us

If you have any questions or comments about this Privacy Policy, you may contact us by email realsee.mkt@ke.com.

 

This Privacy Policy will help you understand the following content:

i.            Information Collection and Use

ii.            How we use Cookies and similar technologies

iii.            How we share, transfer, and publicly disclose your personal information

iv.            How we protect and save your personal information

v.            Cross-border transmission of personal data

vi.            How you manage your personal information

vii.            Protection of personal information of minors

viii.            Notification and revision

 

i. Personal Information Collection and Use

This section describes the types of personal information we may collect about you. We use the personal information collected about you to provide Realsee Service that you request from us or to fulfill our obligations arising from a separate agreement that we have entered into with you.

You understand and agree that we are committed to creating a variety of products and services to meet your needs. We may provide you with a wide range of products and services, and specific products and services different users choose to use are different in scope; accordingly, there will be differences in functions and the types and scopes of personal information collected and used, and reference should be made to specific product/service functions. In order to provide you with better product and service experience, we are constantly striving to improve our technology; accordingly, we may from time to time introduce new or optimized functions, which may require collection and use of new personal information or change the purpose or way for which or in which such personal information is used. In this regard, we will separately explain to you the purpose, scope and use of the corresponding information by updating this Privacy Policy, by means of pop-ups, page prompts, or the like, and provide you with a means of voluntary consent, and then we will collect and use the information with your consent.

(i) Personal information directly provided by you

Contact and account information. When you create a Realsee account or try to contact us, we may ask you for personal information such as your name, contact address and email address. You can use our agency services provided that your agency has already created an agency account and added you as an employee. When you first use Realsee's agency services, you need to create a Realsee account according to the method described above and apply for binding the agency account of your agency. We will verify your identity and bind the corporate account of your agency according to the personal information you provided when you created the Realsee account. Or, we may, under a separate agreement with your agency, provide you with an agency employee account in which we set the user name and initial password. If you are the administrator of your agency, you can apply to Realsee to create an agency account on behalf of your agency. You may need to provide your agency name, country/region, organization scale, email address, position, and applicable laws and other information required by the separate agreement between us and your agency, so that we can review your application and create an agency account and administrator rights for you, allowing you to manage through the agency account, including creating rules of use of your agency, adding/reducing agency employees, and the like.

Online consultation and communication. You can submit consultation and communication to us by email. For example, when you request customer support services or other information about Realsee Service and any other general communication, we may request, from time to time, your name, contact address, email address, contact information, agency name, type of industry, and details of your current use of Realsee Service. You shall ensure that any online consultation or communication does not contain any personal information other than that requested by us.

Image information. When you are accessing or using some Realsee Service, for example, Realsee VR mobile application software, to generate panoramic images and a three-dimensional space model, we may request you to upload your images to our server for processing, and then return panoramic images and the link of the three-dimensional space model formed by panoramic image mosaic to you. You understand and agree that, unless you contact us to change the scope of your authorization or withdraw your authorization, your images will always be kept on our server, and that, unless otherwise approved by you, we will not commercialize your images. If you use Realsee's agency services, in addition to this Privacy Policy, your image information will also be used under the separate agreement between us and your agency.

(ii) Personal information possibly obtained by us automatically

IP address and device information. When you are accessing or using Realsee Service, to identify an account abnormal status, understand the product adaptability, provide consulting support to you, and meet the demand of business operations or storage and backup required by the applicable laws, as well as to improve and optimize the above functions, we may automatically collect your use and store it as web log information, including an IP address of your device, device hardware information, device system information, device network information, application software information, device unique identification information, system status information, device status information, device model, operating system version, device settings, device environment, and other device information.

Service log information. When you are accessing or using Realsee Service, we may automatically collect details about your use of our services, including browsing, clicking and viewing, searching and inquiring, favorites, following and sharing information, posting information, and the like, and save them as service log information.

Precise position information. When you are accessing or using some Realsee Service, for example, Realsee VR mobile application software, to accurately differentiate and correlate different shooting points and synthesize panoramic images, or in the mode of matching a specific-type camera (which may not be Realsee brand) for shooting, to be able to identify and obtain a wireless hotspot of the camera, we may need to obtain and process your current precise positioning information from position information provided by a built-in GPS sensor of your mobile device, but we will not bypass the licensing function set by the operating system of your mobile device for obtaining such information.

Please note that individual device information, log information, position information and the like are information that cannot identify a specific natural person. If we combine such non-personal information with other information to identify a specific natural person, or combine such non-personal information with personal information, such non-personal information will be treated as personal information during combined use. Unless authorized by you or otherwise specified by laws and regulations, such personal information will be anonymized and de-identified.

If your search keyword information cannot recognize your identity, it will not belong to your personal information, and we have the right to use it to the extent permitted by laws and regulations. We will regard your search keyword information as your personal information and process and protect it in accordance with this Privacy Policy together with your historical search records during alone use or combined use only when your search keyword information is used alone or in combination with your other information and can recognize your identity.

(iii) You are fully aware that we may collect and use personal information without your authorized consent in the following circumstances:

1. where it is necessary to perform the contract in which you participate, or to deal with the actions that have been taken as a result of your request prior to loging the contract;

2. where it is necessary to fulfill the legal obligations to which we are subject;

3. where it is necessary to protect the vital interests of you or another person;

4. where tasks in the field of public interest are carried out;

5. where the personal information collected is disclosed to the public by you;

6. where your personal information is collected from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;

7. where it is necessary to maintain the safe and stable operation of Realsee Service, such as detection and disposal of failures of products and/or services;

8. where it is necessary for legitimate news reporting;

9. where personal information contained in results shall be de-labeled when it is necessary for an academic research institution to carry out statistics or academic research based on the public interest and provide the results of academic research or description to the outside world; and

10. other circumstances prescribed by law.

(iv) Your personal information obtained by us from a third party

We may obtain account information (avatar, nickname) that you have authorized to share from a third party and bind your third party account to your Realsee account after you agree to this Privacy Policy, so that you can log in and use Realsee Service directly through your third party account. We will confirm the legality of the source of personal information as agreed with the third party and use your personal information in accordance with relevant laws and regulations.

(v) Rules for using your personal information

1. We will use the personal information collected to the extent necessary to implement the functions of Realsee Service as set forth in this Privacy Policy.

2. After collecting your personal information, we may anonymize part of the data through technical means, and the anonymized information will be unable to identify the subject. Please understand and agree that in this case we have the right to use the information that has been anonymized; and we have the right to analyze and commercialize user database without disclosing your personal information.

3. Please note that all personal information provided by you during use of Realsee Service will continue to be authorized for the duration of your use of Realsee Service unless you delete it and withdraw your consent through system settings or by contacting us. When you cancel your account, we will stop using and delete or anonymize your personal information. If you use the agency services provided by Realsee, we will apply the separate agreement between your agency and us to manage the binding of your Realsee account to your agency's agency account or your agency employee account. If you apply for or we take the initiative to remove your Realsee account from the corporate account of your agency, or if you stop or we take the initiative to close your employee account, we will anonymize your personal information. Unless otherwise specified by laws and regulations, we will no longer retain or collect your personal information, nor will you be able to continue to use our corporate services.

4. We will keep statistics on the use of Realsee Service and may share such statistics with the public or third parties to demonstrate the overall trend of the use of Realsee Service. However, these statistics do not contain any identification information about you.

5. When we display your personal information, we may desensitize your information by means of content replacement, de-identification processing or the like to protect your information security.

6. When we wish to use your personal information for other purposes not specified in this Privacy Policy, or when the information collected based on a specific purpose is used for other purposes, we will seek your prior consent by requiring you to actively check the box.

 

ii. How we use Cookies and similar technologies

(i) Use of Cookies

1. To personalize your online experience and make your access experience easier, we will send one or more small data files called Cookies on your device. Cookies designated for you are unique and can only be read by the Web server that publishes Cookies to your domain. With the Cookies, we can learn about your usage habits, remember your preferences, save you the step of entering duplicate information, provide you with more thoughtful personalized services, or help you determine the security of your account. Cookies can also help us count traffic information and analyze the effectiveness of page design and advertising.

2. We do not use Cookies for any purpose other than those specified in this Privacy Policy. Most web browsers may accept Cookies automatically, but you can often modify the settings of your browser to reject Cookies according to your own needs. You can also clear all Cookies saved in the software. However, if you do this, you may need to personally change user settings every time you access Realsee Service, and any information you previously recorded will be deleted, which may have some impact on the security of the services you use.

(ii) Use of network Beacons and similar technologies

In addition to Cookies, we may use web Beacons and other similar technologies on websites. Our web pages often contain electronic images (called "single-pixel" GIF files or "web beacons"). The ways we use web beacons are as follows:

1. The number of user access is calculated by using network beacons in Realsee Service, and registered users of Realsee Service are identified by accessing the cookies.

2. Personalized services are provided for you through the cookies information obtained.

 

iii. How we share, transfer and publicly disclose your personal information

(i) Share

1. We will not share your personal information with any company, organization or individual other than Realsee, except in the following cases:

(1) where your express consent or authorization is obtained in advance;

(2) where it is necessary to fulfill the legal obligations to which we are subject;

(3) where it is necessary to protect the vital interests of you or another person;

(4) where tasks in the field of public interest are carried out;

(5) where you disclose personal information to the public on your own;

(6) where your personal information is collected from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels.

2. We may share your personal information with our affiliates. We will only share necessary personal information and require the affiliates to protect your personal information in a manner that is not less than the level of this Privacy Policy. We shall not make any commitment or assume any responsibility for the nature and quality of the services provided to you by such affiliates, nor shall we make any commitment or assume any responsibility for the independent collection and processing of user information by such affiliates. You are requested to carefully refer to privacy policies provided by such affiliates regarding related privacy controls and options in your use of the services of such affiliates and privacy policies of service providers. If our affiliates do not have an independent legal statement or privacy policy, this policy also applies to such products or services.

3. We may share your order information, account information, device information and position information with third parties such as partners to ensure the smooth completion of the services provided for you. However, we will only share your personal information for legal, just, necessary, specific and definite purposes and will only share the personal information necessary to provide the services. Our partners have no right to use the shared personal information for any other purposes. Our partners include the following types:

(1) Suppliers of goods or technical services. We may share your personal information with third parties that support our functions. The support includes providing us with goods, infrastructure technical services, logistics and distribution services, payment services, data processing and so on. We share this information so that we can achieve our core functions, for example, we must share your order information with a logistics service provider before we can arrange delivery; or we need to share your order number and order amount with a third-party payment institution to realize its confirmation of your payment instruction and completion of payment, and the like.

(2) Partners who entrust us with promotion. Sometimes we may provide promotional services on behalf of other businesses to the user group that uses our products and/or services. We may share an indirect user portrait formed by a set of your personal information and your non-personal information with partners ("clients") who entrust us with promotion. However, we will only provide these clients with information on the coverage and effectiveness of the promotion, and will not provide your personally identifiable information, or we will aggregate such information so that it does not identify you personally. For example, we can tell the clients how many people have seen their promotions or bought their goods after seeing the information, or provide them with personally unidentifiable statistics to help them understand their audiences or customers.

4. We will enter into confidentiality agreements with companies, organizations, and individuals with whom we share personal information, requiring them to handle personal information in accordance with our instructions and any other relevant confidentiality and security measures. In the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technologies to better protect user data.

5. In order to comply with the law, perform, or apply to our terms of use and other agreements, or to protect our, your or other users' rights and their property or security, such as to prevent fraud and other illegal activities and reduce the credit risk, and exchange information with other companies and organizations, such as in order to confirm your compliance capabilities, we will provide your ID information to a third party credit reference agency to obtain your personal credit in the credit reference agency. The foregoing sharing does not include personal information that is sold, rented, shared or otherwise disclosed for profit in violation of the commitments made in this Privacy Policy.

(ii) Transfer and publicly disclose

Where a merger, acquisition, transfer of assets or similar transaction involving the transfer of personal information is involved, we may require a new company or organization holding your personal information to remain subject to this Privacy Policy; otherwise, we may require the company or organization to seek authorization from you again.

If we determine your violation of the laws and regulations or a serious breach of rules related to Realsee Service, or to protect personal and property security of users of Realsee Service and its affiliates from infringement, we may disclose your personal information in accordance with the laws and regulations or the rules related to Realsee Service, including related violations and actions taken against you by Realsee Service.

Except the circumstances as expressly set forth in this Privacy Policy, we will not transfer or publicly disclose your personal information to any company, organization or individual, except in the following cases:

(1) where your express consent or authorization is obtained in advance;

(2) where it is necessary to fulfill the legal obligations to which we are subject;

(3) where it is necessary to protect the vital interests of you or another person;

(4) where tasks in the field of public interest are carried out;

(5) where you disclose personal information to the public on your own;

(6) where your personal information is collected from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels. In accordance with the law, where personal information that has been de-identified is shared and transferred and it is ensured that a data receiver cannot recover and re-identify the subject of personal information, it shall not be regarded as external sharing, transfer or public disclosure of personal information. Storage and processing of such data do not require further notice to you and your consent.

(iii) Management of third-party plug-ins

In order to provide you with more professional and secure business functions, third-party plug-ins will be incorporated into our products. In general, third parties may use cookies, APIs (application programming interfaces) and SDKs (software development packages) in the services we provide. As for Realsee VR mobile application software, we will timely explain to you the third-party plug-ins that may be accessed according to the function update.

 

iv. How we protect and save your personal information

(i) Technologies and measures we use to protect your personal information

We take personal information security very seriously and take all reasonably practicable measures to protect your personal information:

1. Data security technical measures

Realsee Service will adopt security measures in line with industry standards, including establishing reasonable system specifications and security technologies to prevent unauthorized access, disclosure, use, modification to your personal information, to avoid data damage or losses, which includes, but is not limited to:

(1) Realsee Service adopts an encryption technology to encrypt and save users' personal information, and isolate it through an isolation technology. In the use of personal information, such as personal information display and personal information association calculation, we will use a variety of data desensitization technologies including content replacement to enhance the security of personal information in use;

(2) Realsee Service adopts strict data access rights control and multiple identity authentication technologies to protect personal information and prevent data from being used illegally;

(3) Realsee Service adopts a data access log analysis technology to conduct personal information security audit.

2. Other security measures taken by Realsee Service to protect personal information

Guarantee security system. We have issued Data Security Management System and Personal Information Protection Guidelines, through which Realsee Service will standardize the management measures taken by all departments on personal information.

We carry out complete security control over the data by loging confidentiality agreements with information contacts and through monitoring and audit mechanisms.

Enhance security awareness. We hold privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

3. We will do our best to ensure the security of any information you send to us. If our physical, technical or management protection facilities are damaged and information is accessed without authorization, publicly disclosed, tampered with, or destroyed, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal liability.

4. Handling of security incidents

When you transact online goods or services with a third party through Realsee Service, you will inevitably have to disclose your personal information, such as contact information or postal address, to the counterparty or potential counterparty. Please properly protect your personal information and only provide it to others if necessary.

To deal with risks of disclosure, damage and loss of personal information, Realsee Service has developed a number of policies and set up an emergency response team. According to handling standards of security incidents, we start security plans for different security incidents to conduct stop loss, analysis, positioning, formulate remedial measures, and cooperate with relevant departments to trace to the source and crack down.

After a personal Information security incident takes place, we will, in accordance with the requirements of the applicable laws, promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions that you can independently prevent and reduce the risk, the remedial measures for you, and so on. We will timely inform you of the relevant information by email, letter, phone call, push notification, and the like. If it is difficult to inform the subjects of personal information one by one, we will take a reasonable and effective way to publish the announcement. At the same time, we will also, in accordance with the requirements of regulatory authorities, take the initiative to report the handling of the personal information security incident.

5. We recommend that you use complex passwords when using communication tools such as email, instant messaging and social networking software, and take care to protect your personal information. If you find that your personal information is disclosed or we have a security vulnerability or a suspicious security event, especially the leakage of your account and password, please contact us immediately through the contact information specified in this Privacy Policy, so that we can take appropriate measures and unauthorized attempt or verification of vulnerabilities is prohibited.

(ii) Preservation of your personal information

1. If we collect and generate your personal information in Japan or the People's Republic of China, it will be stored separately in Japan or the People's Republic of China.

2. After you successfully apply for the cancellation of the Realsee account, we will complete the verification of your account cancellation within 48 hours after you submit the application. After the verification is approved, we will delete or anonymize your personal information. If you use the agency services provided by Realsee, we will apply a separate agreement entered into by the parties to manage the binding of your Realsee account to your agency account or your agency employee account. If you apply to or we take the initiative to unbind your Realsee account from your agency account or you apply to or we take the initiative to close/cancel the agency employee account, we will anonymize your personal information. Unless otherwise specified by the applicable laws, your personal information will no longer be retained or collected, nor will you be able to continue to use our corporate services.

3. If we terminate the services or operations, we will notify you at least 30 days in advance and delete or anonymize your personal information after the termination of the services or operations.

 

v. Cross-border transmission of personal data

You understand and agree that since we may provide products or services through resources and servers located in different countries or regions, we may transfer your personal information to countries other than the countries where the information was originally collected, which presently is Japan. Please note that the data protection laws of Japan may not be completely consistent with the data protection laws of the country/region where you use Realsee Service. When we transmit your personal information to Japan, we will take appropriate measures to protect your personal information in accordance with applicable laws and regulations.

 

vi. How you manage your personal information

Realsee Service protects your right to access, correct, delete and withdraw your consent to your personal information, so that you have sufficient ability to protect your privacy and security. When accessing, updating, correcting and deleting the above information, we may require you to authenticate to protect the account. Your right includes:

(i) Access and correct your personal information

Except as required by laws and regulations, you have the right to access and correct your personal information at any time. Please feel free to contact us if you need to access or correct any other personal information arising from your use of Realsee Service. We will respond to your request in the manner and by the time specified in this Privacy Policy.

Personal information that you are unable to access and correct: in addition to the information listed above, we are unable to provide you with access to and correction of some of your personal information due to the risk and damage that failure to respond to the request may cause to your legitimate rights and interests, technical feasibility and costs of implementing the request. Such information is mainly your device information collected to improve your user experience and ensure transaction security and personal information generated when you use additional functions. The above information will be used within the scope of your authorization. You may contact us for deletion or anonymization.

(ii) Delete your personal information

You may request us to delete your personal information: our handling of personal information violates laws and regulations; we collect and use your personal information without your consent; our handling of personal information is a breach of our agreement with you; you cancel the Realsee account; and we terminate services and operations.

If we decide to respond to your request for deletion, we will also notify the entities that obtain your personal information from Realsee Service to delete it promptly, unless otherwise specified by laws and regulations or authorized by you. When you remove information from our service, we may not immediately remove the information from the backup system, but do so when the backup is updated.

(iii) Change the scope of your authorization consent or withdraw your authorization

You may change the scope of your authorization for us to continue collecting personal information or withdraw your authorization by deleting information, turning off device functions, making privacy settings in mobile application software, or unbinding your account.

Please understand that each business function requires some basic personal information to complete, and after you withdraw your consent or authorization, we will not be able to continue to provide you with the corresponding service, nor will we process your corresponding personal information. However, your decision to withdraw your consent or authorization will not affect the processing of the personal information previously conducted based on your authorization.

(iv) If you do not want to accept promotion information we send to you, you can cancel at any time by the following means:

In order to protect your privacy, we will not in any way push to you promotion or goods information involving religion, sex, disease and other sensitive content. You can also use the mobile APP to set whether to accept the goods and promotion information we push to you. Moreover, we have set a shielding function in the recommendation window. You can choose to block the advertisements you dislike.

(v) Constrain an information system from making decisions automatically

In some business functions, we may only make decisions based on non-manual automatic decision mechanisms such as information systems and algorithms. If these decisions have a significant impact on your legitimate rights and interests, you have the right to ask us for an explanation, and we will also provide recourse methods without prejudice to the business secrets of Realsee Service or other user rights and interests and public interests.

(vi) Respond to your request

If you have any doubts or difficulties in using Realsee Service (if you are unable to access, correct or delete your personal information by the above means, or you need to access, correct or delete your real-name authentication information or other information generated during the use of our products and/or services, or if you believe that Realsee Service violates laws and regulations or agreements with you regarding your personal information), please feel free to contact us by email [*]. For security purposes, we may require you to provide a written request or otherwise prove your identity.

We will respond to your request within 15 days after receiving your feedback and verifying your identity. In principle, we do not charge you for reasonable requests, but for repeated requests beyond reasonable limits, we will charge a certain cost as the case may be. We may reject requests that are gratuitously repetitive, require too many technical means (for example, need to develop new systems or radically change existing practices), pose a risk to the legitimate rights and interests of others, or are highly impractical (for example, involve information stored on backup tapes).

We may not be able to respond to your requests in accordance with the requirements of laws and regulations in the following circumstances: where the requests are directly related to national security and national defense security; where the requests are directly related to public security, public health or major public interests; where the requests are directly related to criminal investigation, prosecution, trial and execution of judgment; where there is sufficient evidence to show that you have subjective malice or abuse of rights; where responding to your request will cause serious damage to your or other persons' and organizations' legitimate rights and interests; and where the requests involve trade secrets.

 

vii. Protection of personal information of minors

Realsee Service protects personal information of minors in accordance with applicable laws. We assume that you are an adult under the applicable laws. If you are a minor under the applicable laws, you should obtain the prior written consent of your parent or guardian before using Realsee Service. In cases where personal information of a minor is collected with the consent of a parent or legal guardian, we will only use or publicly disclose such information where it is permitted by the applicable laws, with the explicit consent of a parent or guardian, or where it is necessary to protect the minor. If we find that we have collected personal information of a minor without the prior consent of a verifiable parent or legal guardian, we will try to delete the data as soon as possible.

viii. Notification and revision

(i) This Privacy Policy will be updated as Realsee Service business develops. However, we will not reduce your rights under this Privacy Policy without your express consent. We will issue an updated version on our mobile APP and notify you of the related update in an appropriate manner before it takes effect. You are also requested to access Realsee Service to keep up to date with the latest privacy policy.

(ii) For major changes, we will provide more significant notice (including, but not limited to, explaining specific changes by email, text messages or special prompts on browsing page). Major changes referred to in this Privacy Policy include, but are not limited to:

(1) major changes in our service mode, such as the purpose of processing personal information, the type of personal information processed, and how personal information is used;

(2) major changes in our ownership structure, organizational structure and other aspects, such as the owner changes caused by business adjustment, bankruptcy and merger;

(3) changes in main objects of personal information sharing, transfer or public disclosure;

(4) major changes in your right to participate in the processing of personal information and how it is exercised;

(5) changes in our departments responsible for handling personal information security, contact information and complaint channels; and

(6) where personal information security impact assessment reports indicate that there is a high risk.

We would like to remind you once again to acknowledge the full content of this Privacy Policy. Regarding the provisions in this Privacy Policy are highlighted in bold, please read them carefully. You will be deemed to have known, understood and accepted this Privacy Policy by clicking the "Agree"/"Register"/"Login" buttons or checking the relevant meaning.