IC Home Privacy Policy

Last modified: October 14, 2019

Introduction

This IC Home Privacy Policy describes the types of information, including but not limited to personal data, we may collect from you or that you may provide when you interact with us, use our application, and/or products or services in relation to IC Home or when you visit our website https://valorusa.com/ ("website"), including any subdomains and any content, functionality and services offered on, by or through it or them, or any other websites, e-mails, applications that link to this Privacy Policy (collectively referred to as "Services"), all of them provided by Valor USA, LLC ("Valor USA, LLC", "IC Home", "we", "us", or "our"), acting as a data controller. This Privacy Policy also describes how we collect, use, maintain, share, protect, disclose or otherwise process that information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

"Personal Data" as in this IC Home Privacy Policy shall mean any information that identifies you or can identify you, directly or indirectly, in particular, if in combination with another identifier of you.

This Privacy Policy includes the following contents:
1.  Information We Collect About You, Purposes of Processing and Legal Grounds
2.  Children under the Age of 16
3.  How long do we store your personal data for
4.  Information Sharing
5.  Data Security Measures
6.  third-party Suppliers and Their Services
7.   International Transfers
8.   Your Rights
9.   Changes to Our Privacy Policy
10. Contact Information

1. Information We Collect About You, Purposes of Processing and Legal Grounds

We collect several types of information from and about users of our Services, including information that you directly provide to us and it identifies you personally, such as, without limitation, name, postal address, e-mail address, and telephone number.

We may also automatically collect certain information as you navigate through the website or use our Services, such as usage details, equipment profiles, and IP addresses, by means of cookies, web beacons, and other tracking technologies.
"Personal Data" as in this IC Home Privacy Policy shall mean any information that identifies you or can identify you, directly or indirectly, in particular, if in combination with another identifier of you.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Activity	Type of data process	Processing purposes and lawful basis	Lawful basis for processing
A. Purchase of IC Home Devices
When you purchase IC Home devices through third-parties platform	Buyer's name; recipient's name; shipping address; source of order; details on the products you ordered	To process and deliver your order and communicate with you if needed	Performance of contract
B. Use of IC Home App, Devices and Cloud
1a. When you sign up with IC Home App for the first time	Email address; country or region you choose; nickname you use; password (encrypted); profile photo (if uploaded); your nickname and profile photo on a third-party platform when you choose to log in to IC Home App with other app account, such as Facebook	To allow us to complete your registration, communicate with you and administer your account.	Performance of contract for IC Home Registration Agreement and legitimate interests to maintain our contractual relationship with you, provide you with services of adequate quality, allow you to enjoy the service's features, keep our products updated and relevant, develop our business, and ensure security of products and that your use of our products are in compliance with the accepted terms and conditions
1b. When you change the details you used for registration	If you choose to change any of the above information, the new entries will be collected in replacement of the old ones.	To allow the changes you have requested for
2. When you log in and use our services	Apart from the information mentioned under item 1, we process data related to the terminal (such as your smartphone) you use to log in, like GPS, terminal's operating system, model and its unique identifier	To offer our services to you, maintain our services' normal operations, optimize our services and secure the safety of your account
3. When you add a device (on the Device interface, you can view and add devices like IP cameras, storage devices, and doorbells, to IC Home App)	Device SN; Device model; wifi info; Device Name; Device password (encrypted); device time zone and DST status on/off	To process your request to add a device to your account and allow configuration of your device
4. When you use Live View function which provides you a real-time video display	Device SN; Device IP; Device Port Information; Video Stream	To provide you with the basic services of video display through IC Home App
5. When you use Playback and Video Recording functions	Device SN, Device's Channel ID, Record Files Path	To store your history record and allow you view it
6. When you activate and configure the settings of the added device such as IP camera, doorbell and storage device	Mac address; IP address; Device SN; Device model; Device firmware version; Country information (via IP address); Device location (via IP); Date of device register; Device channel information; Device offline/online status; Device configuration information	To allow activation of your IC Home device and its registration with our server
7. When you set a device name and cover image	Cover image; Device name; Channel information; Device model; Device SN	You can set a device name, change cover image, and view a channel name, device model and/or SN. The processing of such information is needed for us to allow the changes you have required for and to inform you about the details of the device added on your IC Home account
8. When you enter device password or use the reset function	Device SN; password (encrypted)	To allow you enhance the security of your device by adding a password or reset your password
9. When you use Device Share function	Device SN; Email of the other user you share your device with	To allow you the sharing of your device with another user of IC Home App as requested by you
10. When you use Delete Device function	Device SN; Email	To allow the removal of the device from your account on the IC Home App and matched accessory as you requested us for
11. When you receive notification	Device SN; Push notice ID/alarm snapshot	To send you alarm notifications and provide you the services you have requested us for
12. When you use IC Home App's cloud services to extend your storage capability	Device SN; messages and video record; Device channel information	To allow you use of the cloud storage service (either free or added value version)
13. When you buy cloud storage plan or redeem a gift card	Details of the purchased cloud storage plan; payment method; order date; email	To process your order and invoice you for the purposes of cloud storage plan
14. When you transfer your cloud storage plan	Device name the plan is transferred from; device name the plan is transferred to; plan information	To transfer the activated cloud service to a specific device added to your account)
15. When you use the User Experience Plan function	Browsing history & clicking behavior	When you enable user experience plan, you give us consent to collect such information and help us improve our products and services and analyze your usage of different functions	Consent
16. When you communicate with us through email or Feedback function	Content of your communication with us	To communicate with you, provide you with information you request about us, answer your questions or handle your complaints	Our legitimate interests to communicate with you and reply to your inquiries/comments
C. When you take part in our marketing activities
When you take part in our marketing activities happening either offline or online, including but not limited to exhibitions, prize draws, competition or surveys	Name; email; telephone; location; your feedback and replies to a survey (if applicable); profile details on a third-party platform (if you choose this way for registration)	To register your interest to our products and services	Consent
		To communicate with you and inform you about the progress and result (if applicable) of the marketing activity you have opted-in for	Performance of contract , i.e. let you enjoy the services you have opted-in for.
		To ask you to leave a review or take a survey	Legitimate interests to improve our services and understand better customers' needs
		To inform you about similar events if you have opted-in for this	Consent
When you take part in our marketing activities happening offline, including but not limited to exhibitions, prize draws, competition or surveys	Photographs or videos taken during the event	To promote our activity and event	Legitimate interests to promote our business products and services
D. When you request after-sales services
1. When you register with our RMA platform	Name; Email or third-party account that you use for registration; country; password (encrypted); language	Assist you completing IC Home registration and protect your IC Home account security	Performance of contract for the provision of after-sales services; Legitimate interests to provide you better services and facilitate the exercise of your rights to after-sales services.
2. When you submit an RMA request through the APP, website or our third-party hotline	Device model; SN of the device; MAC address, IP address; details indicated on the evidence of purchase; Telephone; address for return of the device after repair and details of recipient; details for the return of devices and tracking number	Receive and deal with your request for after-sales services;	Performance of contract for the provision of after-sales services or adherence to legal obligation we might have in regard to consumers' guarantee.
		Recommend you the nearest repair center (if applicable);
		Send the device after repair to the recipient and address indicated by you
		Communicate with you for any clarifications we or you might need	Legitimate interests to clarify your request and improve our services
		Ask you for feedback and the degree of your satisfaction for our services
3. When you reset your password	SN of the device; MAC address; email	To assist you with resetting your password and proceed with the modifications you have requested for	Legitimate interests to provide adequate services
E. When you use our website
1. When you subscribe for newsletter	Email address	To send you newsletters, promotions or other marketing communications, including invitations to our exhibitions.	Consent
2. When you use our website	Technical details Usage behavior (More info on Cookies statement)	To use analytics to improve our website, products/services, marketing, customer relationships and experiences, and to administer and protect our websites	Legitimate interests to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and ensure the security of our website.
F. Other uses of your information
We use the information we collect to provide or improve services provided by us, our partners, or other trusted third-party vendors, such as providing, evaluating, improving, or upgrading services; participating in market research activities related to our services, developing new services, providing customer support, etc. To improve the services, we may also analyze product usage, but these statistics will not include any of your identifiable personal information			Performance of contract and legitimate interests to keep our services updated and improve them
We use your contact details to communicate with you, provide you with information you request about us, answer your questions or when we handle your complaints. We might use these details to send important notifications to you, such as changes in our relevant terms, conditions, and policies. Since this information is very important for you to communicate with us, it is suggested that you receive and read such information			Performance of contract and legitimate interests to administer the contractual relationship with you
We may be required by law to collect and share your identifying information and personal data with public or governmental organizations for the purpose of compliance with the law, a court order, or to respond to any government or regulatory request.			Compliance with a legal obligation

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of our website, or transmitted to other users of our services or third-parties (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of other users of our services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies
Our website and apps use cookies and similar technologies. We use functional cookies to ensure that our website and services operate properly and analytical cookies to make your user experience optimal. Third-party cookies may collect data outside our websites as well. As you navigate through and interact with the website and our services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, traffic data, logs and other communication data. .
Our Privacy Policy does not cover the use of cookies by others, including, without limitation, our partners, affiliates, tracking utility company and service providers. We do not have access or control over these cookies.

2. Children under the Age of 16

Our websites are not generally targeted at children under 16 years of age. No one under age 16 should provide any personal data to or on our Services. We do not knowingly collect personal data from children under 16.
Valor strongly recommends that parents take an active role in supervising the online activities of their children. If you believe we might have any information from or about a child under 16, please contact us at cloudservice@valorusa.com.

3. How long do we store your personal data for

Your personal data will be retained for as long as required for the purposes described in this Privacy Policy or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In the event where we cease our products or part or all of our services, we will notify you and delete your personal data in concern or anonymize such information within a reasonable period of time.
When you have not used the services of IC Home App or cloud for 3 years, we will delete your personal information and we will notify you 3 months before deleting or anonymize your personal information in the form of push notifications, announcements, etc., e.g. we will send an email to inform you.

4. Information Sharing

We might disclose your personal data with certain trusted third-parties for the following reasons:

To our subsidiaries and affiliates to provide you the services you have requested us for and for the purposes of our legitimate interests of customer relation management
To forwarders/carriers and other business partners to the extent that we need to deliver your orders
To IT services providers who offer support during our daily operations, such as the maintenance of digital databases
To third-party hotline service provided for receiving and following up on your request for after-sales
To marketing services providers in order to provide you the services you have requested us for, such as receiving the news you have opted-in
To a buyer or potential possible buyer of our business for evaluation and completion of transactional corporate matter.

All such third-parties will be required to adequately safeguard your personal data, subject to agreements that correspond to the requirements of applicable laws.
We may also disclose your personal data:

To comply with any court order, law or legal process, including to respond to any government or regulatory request or for investigations (e.g. disclosure to prevent crime or fraud, or to comply with a court order or legislation).
To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the legitimate rights, property or our safety, our customers or others.

As regards the personal data collected during your use of the IC Home App and Cloud, we ensure you that we will not share such data unless you have explicitly requested such sharing, when for example: you apply to connect your IC Home App and device with IFTTT, Google Home, Alexa, etc.

5. Data Security Measures

We have implemented appropriate technical and organizational measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. In the case of information leakage or other incidents involving information security, we will initiate contingency plans to prevent the spread of security incidents and inform you in the form of push notifications and announcements.

6. Third-Party Suppliers and Their Services

To ensure you have a smooth browsing experience, you may receive content or network links from third-party suppliers (hereinafter referred to as the third-party) beside us and our partners. Except as otherwise expressly stated in this IC Home Privacy Policy, this IC Home Privacy Policy does not apply to situations where a third-party independently provides services to you through our services, such as websites that may include the services we offer or other third-parties' sites that have a link to our services. Please note that if you use such third-parties' products and/or services and provide your personal information, your information will be handled in compliance with that third-party's privacy statement or similar policies. We cannot control the privacy and data protection policies of the third-parties, and the third-parties are not bound by this policy. Before submitting personal information to third-parties, please see the privacy policy of these third-parties. You can choose whether to access links, contents, and services provided by third-parties. We take no responsibility when your information was misused or improperly disclosed in such occasions.

7. International Transfers

We offer our services through the use of servers located in different countries. As such, your information might be transferred outside the region and country you use our website and services, including to regions/countries outside the European Economic Area ( "EEA") which might have different legal rules and might not offer an adequate level of protection as determined by the European Commission. However, we have taken the necessary measures to ensure that your information is processed in conformity with the applicable laws and appropriate technical security measures are adopted to safeguard your privacy. Where necessary we use Standard Contractual Clauses, which are approved by the European Commission to comply with applicable legislation.

8. Your Rights

You can review and change your personal data by logging into your account on our website and visiting your account profile page. If you are not able to find your personal data you may also send us an e-mail at cloudservice@valorusa.com to request access to, or require us to correct or delete any personal data that you have provided to us. You may also object to or request us to restrict your processing. If we process your personal data based on consent, you may withdraw your consent at any time by contacting us (see below). A summary of your legal rights is set out below:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you want to access your head portrait, user name, email address and other basic information, or video, image, order, device and other service information on your IC Home account, you can enter IC Home and tap on corresponding function button, access to relevant information.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you want to change your nickname, email address, etc. on your IC Home account, enter IC Home, tap on related function button.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. If you want to delete the basic information such as email address, and password, or service information such as video, image, cloud record and alarm on your IC Home account, you can delete your information by tapping on related data clear function button through "Me->Settings->Account and Security->Delete Account".

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. If you want to disable user experience program and alarm information on your IC Home account, you can enter IC Home and tap on corresponding close button to turn it off

For security reasons, we will take steps to authenticate your identity before providing access to your personal data. You also have the right to lodge a complaint with the relevant Consumer Protection Authority.

9. Changes to Our Privacy Policy

We keep this Privacy Policy under review and modify this Privacy Policy from time to time. We will inform you about any modifications to the Privacy Policy. We will also provide a notice of the modifications on the homepage for a short period. The date the Privacy Policy was last revised is identified at the top of the page.

10. Contact Information

To ask questions or comment about this Privacy Policy and/or our privacy practices, please contact us by email at cloudservice@valorusa.com or by mail at:
Valor USA, LLC
8181 W Broward Blvd.
Ste. 201
Plantation, FL 33324
C/O: Legal Department