PRIVACY POLICY

Updated: 24 April, 2024

Thank you for using our Services. We, as the supplier, will provide following services for your management in conjunction with various products which can be connected with LTS Connect APP (“Products”): (1) Our user website and user accounts that may be accessed at www.ltsecurityinc.com, and all associated sites connected with www.ltsecurityinc.com, excluding any third parties’ sites (the “Portal”); (2) software applications that can be downloaded to a mobile device (“Mobile Apps”), including LTS Connect and LTS Platinum Partner; and (3) any services available on the Portal, and Mobile Apps (“Available Services”). The term “Services” means the Portal, Mobile Apps, and Available Services.

This Privacy Policy explains how we handle the collection, storage, and disclosure of information, including personal information, regarding Services. It also applies to any information we collect from the operation of Products while connected to Services and any other services that link to this Privacy Policy.

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.

You can determine when this Privacy Policy was last revised by referring to the date it was “Updated” above.

1. What Information We Collect and Why We Collect the Information

We collect the following information to provide, improve, and protect our Services:

Account information. You will need to register an account via the Portal or Mobile Apps to access the Services(“Account”).We collect, and associate with your Account, the information you provide to us or necessary to collect when you registering/logging into your Account, setting up two-factor authentication, and use the Services to manage Products, e.g. your email address,company name ,company address, phone number, company type and IP address. We may also collect your trademarks, company logo, VAT number or other materials for authentication of your status, and also as a display of the basic information in the App or Portal.

Product information. Our Services are designed to make it simple for you to manage the Products and provide technical support and remote configuration. To make that possible, we need to associate Product with your Account by collecting the Product information when you scan the Product code or enter the Product name, the Product’s verification code and serial number which are unique to the Product connected to Services and associated with your Account, all of which shall be under the express consent of the owners of the Products. We also collect the parameter and configuration information of the Product when you configure the Product in your Account.

Usage information. We collect information related to how you use Services and manage the Product, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities. We use this information to improve our Services, develop new services and features, and protect our users. For example, to improve Services, we collect information about how you interact with Services to understand what features are most useful to you and improve them. To protect our users, we analyze things like IP addresses, device type, login history, and password changes to detect and respond to abusive behavior. We may also record adjustments you make to the Products through Services and we store this information along with data collected directly by the Product.

Device information. We also collect information from and about the devices you use to access Services. This includes things like the browser, device name, type of network and operator you use, and the UUID, model, system version, language and time zone of your device.

Cookies and other technologies. We also use cookies, web beacons, pixel tags, and other technologies to keep records, store your preferences, and collect information such as log data and device data. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information. This allows us to better understand how you use our Services, diagnose and troubleshoot any problems you have, and otherwise administer and improve our Services and Products. For more information about cookies, please refer to our Cookie Policy.

When you use the Mobile Apps, we may need to obtain additional permissions from your mobile device, for example, Camera access is needed during the use of Mobile Apps in order to capture the QR Code; in case scanning QR Code from your photo albums, you may need to allow the Mobile Apps to access the document and media of your mobile device; when you set WIFI parameter, the permission to access to location will be required;

You may need to enable the phone function when make a phone call for dialing the phone numbers in the Mobile Apps. You can manage your device authorization by turning on or turning off permissions at any time.

We will also process the personal information which you voluntarily provide to us. If you do not provide your personal information, we may not be able to provide you with our Services.

2. How We Use Your Information

We process your information for the following purposes, as a controller, depending on the specific Services you use and how you interact with us: (1) to provide Services described in Terms of Services; (2) in furtherance of our legitimate interests in operating Services and business; and (3) with your consent. In some cases, we may process your information to comply with applicable law, legal process, or regulation; protect any person from death or serious bodily injury; or to carry out a task in the public interest.

Below are the examples:

a. Providing, processing, maintaining, improving and developing Services and Products;

b. Communicating with you about Services, the Products, or addressing any general queries, such as updates, customer support.

c. Analyzing and developing statistical information about the use of Services to better improve

d. Sending you reminders, technical notices, updates, alerts, support and administrative messages, service bulletins, and requested information;

e. Personalizing your experience with Services and Products;

f. Increasing the safety of Services and Products – for example, for user authentication, security protection, fraud detection, filing, and backups;

g. Managing our everyday business needs, such as auditing, administration of Services, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Service;

h. Enhancing other information we have about you to help us better understand you and determine your interests;

i. In the context of a corporate transaction (e.g., corporate restructuring, sale or assignment of assets, merger) and to protect our rights or property, to enforce our Terms of Service and legal notices and for the establishment, exercise and defense of legal claims;

j. Meeting a legal obligation, a court order or other binding decision(s); and

k. Accomplishing a purpose unrelated to those described in this Privacy Policy by first notifying you and, where required, offering you a choice as to whether or not we may use your Personal information in different manner.

Here are more details on how we use your information (which may include personal information):

a. When you respond to our e-mails, contact our customer service, or use other customer support tools, we collect your information to provide you with support, verify your identity with your Account profile information, and confirm your Product.

b. When you access Services, we will collect information to provide you with a more relevant experience, to prevent misuse, and to ensure that Services are working properly. We may also record adjustments you make to the Products through Services. We store this information along with data collected directly by the Product. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

3. Information Processed on Your Behalf as a Processor

Where personal information of third party individuals (“Third Party Data”) are collected and processed via the Products or Services purchased by you, we will process such Third-Party Data, as a processor, on your behalf.

(1) When you use [Company-Employee] function as an organization administrator, we will collect and process personal information of third party individuals including but not limited to the names, photos, identification number of your employee, job position, group number of your employee, account information of your employee( phone number, e-mail address), etc;

(2) When you use [Operation Log], we will collect and process the name, e-mail address of your employee, the corresponding site and device information and operation content, which is conducted by your employee;

(3) When you use [Health monitoring], we will collect and process the site owners’ e-mail address or any designated party’s e-mail to send the report of device health status to site owner or any other designated party.

(4) When you use “Site Information Management”, we may collect and process information including but not limited site’s name, site owner’s name, site owner’s phone number or e-mail, site address, site GPS location, number of devices, device name, serial number, model, etc.

(5) When you use “Hand Over by Transferring”, we will collect and process the site owners’ e-mail and phone number. For using [Site Information Management], [Remote configuration], [video live view], [video play back] function, you shall be required to apply for and obtain additional permissions from site owner. For specific guidance, you could refer to the permission instructions on Portal or Mobile Apps. Site owners may withdraw their permissions at any time and at their sole discretion.

When you use Service to live view and playback the video, we will only transmit it, rather than store it.

In above cases, you, as the controller of third party data, will be solely liable to collect and process such data in accordance with applicable laws and regulations, including but not limited to obtain explicit consent of data subject.

4. How We Share Your Information

We do not sell any Personal information to third parties. We may share your personal information with third parties as discussed below:

Others working for and with us. We use certain trusted third parties (for example, providers of customer support and IT services) to help us process, store, and protect some of your information and otherwise help us administer Services effectively, facilitate payments, provide a better user experience, and increase the quality of Services. These third parties will access your information only to perform tasks on our behalf in compliance with this Privacy Policy, and we’ll remain responsible for their handling of your information per our instructions. For a list of trusted third parties that we use to process your personal information, please contact us.

New Owner. If we and/or all or part of our assets are ever sold or transferred, your personal information may be among the items sold or transferred. Under such circumstance, we will notify you by sending an email to the email address associated with your account or via an in-app notification of (i) the identity and contact information of the purchaser or transferee, (ii) your right to revoke your consent to the provision of personal information, and (iii) the means by which you may revoke such consent.

Law and Order; the Public Interest. We access, preserve and share your information with regulators, law enforcement or others:

a. In response to a legal request (e.g. a search warrant, court order or subpoena) if we have a good-faith belief that the law requires us to do so;

b. When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorized use of Services and Products, breaches of our terms or policies, or other harmful or illegal activity; to protect ourselves (including our rights, property or Services), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off Services.

Aggregated or Anonymized Information. We may also disclose non-personal information (for example, aggregated or anonymized data) publicly or with third-parties, provided those data have been rendered anonymous in such a way that you are no longer identifiable in line with applicable data protection laws. For example, we may share non-personal information:

· for the same reasons we might share personal information;

· to better understand how our customers interact with Services and Products, in order to optimize your experience, improve our products, or provide better services;

· for our own research and data analytics.

5. Securing and Retention of Your Information

Security. We have implemented commercially reasonable administrative, technical, and physical security controls that are designed to safeguard personal information. We have a team dedicated to keeping your information secure and testing for vulnerabilities. We conduct periodic reviews and assessments of the effectiveness of our security controls. We also continue to work on features to keep your information safe in addition to things like two-factor authentication and encryption of videos.

Not withstanding the above, no data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we use appropriate technical and organizational measures to protect the information we hold for you, we cannot guarantee the security of any information you transmit over the internet with the existing security technology.

However, we handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects. If you have any further questions about the security of our Services, Please contact us by phone at support@ltsecurityinc.com.

Retention. Generally, we store your information as long as necessary to pursue the purposes outlined in this Policy, to comply with applicable law, or until you ask us to delete or edit it. Please contact us using the contact details below if you would like more information about our retention policies.

You can access, update or delete your personal information via your Account profile by selecting “Person” button. We are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile and data. Your personal information might not be immediately deleted, as we are required to retain records relating to Services for financial reporting and compliance reasons pursuant to applicable laws. In addition, because of the way we maintain certain services, after you delete certain information, we may temporarily retain backup copies of such information before it is permanently deleted.

6. Children’s Privacy

We do not intend that any portion of its Services will be accessed or used by children under the age of 18, or equivalent minimum age in the relevant jurisdiction and such use is prohibited. Our Services are designed and intended for adults. By using the Services, you represent that you are at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction and understand that you must be at least 18 years old, or above the equivalent minimum age in the relevant jurisdiction in order to create an account and purchase the goods or services advertised through the Services. If we obtain actual knowledge that an account is associated with a registered user who is under the age of 18 years old, or equivalent minimum age in the relevant jurisdiction, we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction and believe he or she has disclosed personal information to us please contact us by email at support@ltsecurityinc.com. A parent or guardian of a child under the age of 18, or equivalent minimum age in the relevant jurisdiction may review and request deletion of such child’s personal information as well as prohibit the use thereof.

7. Global Operations and Data Transfers

We transfer and process your information globally both in our own facilities and with service providers, or partners, regardless of where you use our services. As we are operating globally, we may transfer your personal information to our affiliates worldwide, when processing that information for the purposes described in this Privacy Policy. We shall do so in accordance with the applicable laws. In particular, we will ensure that all transfers will be in accordance with requirements under your applicable local data protection laws by putting in place appropriate safeguards. You hereby agree to transfer the data and you have the right to be informed of the appropriate safeguards taken by us for this transfer of your Personal information.

8. Your Choices

We think that you benefit from a more personalized experience when we know more about you and your preferences. However, you can limit the information you provide to us as well as the communications you receive from us through your Account preferences.

9. Changes

We may revise this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by the email address specified in your Account or by means of notice on the Portal or Mobile Apps of any such changes. You can determine when this Privacy Policy was last revised by referring to the date it was “Last Updated” above.

10. Contact Us

Please contact us if you have any questions or comments about our privacy practices or this Privacy Statement. Please provide: (i) your name (or nickname) and preferred method of contact; and (ii) the details of your request or comment along with any corresponding website links.

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the proceeding calendar year. In particular, the law provides that companies must inform consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by us pursuant to Section 1798.83 of the California Civil Code, please contact us via the email or address stated above. Please allow 30 days for a response.

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