Rraycom Privacy Notice

Last Updated on Nova 25, 2021

I.Scope of this Notice

Shenzhen Shoushi Technology Co., Ltd. takes your privacy seriously. This Privacy Notice ("Notice") covers information that Shenzhen Shoushi Technology Co., Ltd., and its subsidiaries and affiliates (collectively, "Rraycom," "we," "us," or "our") collect, use, share, and store, including personal information (i.e. information that can be used to personally identify you by itself or when combined with other information).

This Notice covers information collected and processed by Rraycom when you use our smart home devices ("Products") and platform services ("Services"), including cloud service, Apps, websites managed and/or operated by Rraycom ("Site"), etc. You may be a visitor to our Site ("Visitors"), a user of one of our Products or Services ("User"), or a customer of one of our business clients or partners ("Third-Party Customer"). If you are a Third-Party Customer, then Rraycom usually does not collect personal information directly from you. Your agreement with the relevant business client or partner should describe how your personal information is shared with Rraycom. If you have any questions about this sharing, you should direct them to the relevant business client or partner. This Notice describes how we collect, use, share and secure the information we process. It also describes your choices regarding use, access and correction of your personal information.

II.Your Permission

By using Rraycom's Services, you give Rraycom permission to collect, process, and store data as described in this Notice. Rraycom's servers are located in the United States of America and your information, including personal information, may be transferred to the United States and processed there. Your information, including personal information, may also be transferred to and processed in other countries where Rraycom or its affiliates, subsidiaries or agents operate. Your information may also be shared with third-party service providers in other countries in order to provide our Services. These countries may not have privacy laws similar to or as comprehensive as the laws where you reside and/or are a citizen. By using Rraycom’s Services, or by accessing its Site (including Rraycom.com) you explicitly consent to this transferring, processing, and storage of your information, including personal information.

III.Information that Rraycom collects

When you use our Services or Products

If you are a User, the information we collect or obtain may include:

• contact details, such as your name, title, e-mail address, telephone and fax numbers, and physical address;
• information about your company, job title and function;
• information about your gender, date of birth, etc.;
• your e-mail marketing preferences;
• payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by our third-party payment processors on our behalf and Rraycomstores only the last four digits of your payment card and the expiration date;
• information such as your nationality and country of residence that allows us to determine various legal requirements and your eligibility under export control regulations to receive information about certain technologies;
• information used to customize and facilitate your use of our Site and App, including login and technical information;
• audio, video and photographic information that you record with your Products connected to the Rraycomserver;
• technical information such as the IP address and browser type and version when your browser, mobile device or Product contacts our servers;
• location data;
• during setup, Rraycomdevices may ask for your Wi-Fi network name (SSID) and password to connect to the internet;
• inquiries about and orders for our Services;
• information that assists us in identifying the Products and Services that best fit your requirements;
• event registration information;
• feedback from you about our Site and our Services generally;
• any information as collected pursuant to the description under "information collected automatically when you visit our Site" below;
• any information that you voluntarily provide.

Some jurisdictions may have laws and regulations that affect the collection of personal information from cameras. You, not Rraycom, are responsible for staying current with and complying with all laws and regulations that affect the collection of personal information by these devices in your country. Rraycom cameras are marketed and intended for purely personal or household use, but the collection of personal information from others may be affected by laws and regulations in your area.

When you visit our Site

We collect information about your visit to our Site, including what pages you view, the number of bytes transferred, the links you click, the materials you access, and other actions taken within Rraycom's Site. On any page that you enter with a user ID. We also collect certain standard information that your browser sends to every website you visit, such as your Internet Protocol (IP) address, your browser type and capabilities and language, your operating system, the date and time you access the Site, and the website from which you linked to our Site. We do not link this information to your identity.

Your general information about the browsing session, a hashed version of the Facebook ID, and the URL being viewed may also be collected for our Facebook Ads. For information about Facebook Ads and information on how to opt out, please go to https://www.facebook.com/about/ads.

Cookies and other tracking

We use cookies (small text files stored in your browser) and other techniques including tracking pixels to improve your experience on our Site. We permit third-party advertising partners to use cookies and other technology to collect information about your browsing activities when you use our Site. Most browsers will provide instructions on controlling which cookies can be used. If you choose to block or otherwise limit our cookies, it may affect the quality of services provided.

IV.How Rraycom uses the information it collects

Rraycom uses the information we collect in a number of ways, such as:

• Providing you with the RraycomSite and Services for which you have registered, as well as any Services, support, or information you have requested;
• Better understanding how our Site and Services are being used so we can improve them;
• Diagnosing problems in our Site and Services;
• Sending you business messages such as those related to payments or expiration of your subscriptions;
• Sending you information about Rraycomand its controlled subsidiaries and affiliates, such as new application releases, special offers, and similar information;
• Reducing fraud, software piracy, and protecting our customers as well as Rraycom;
• To administer our Services or Site (including any searches or requests for information about our Services);
• For assessment and analysis of our market, customers, products and services, including asking you for your opinions on our Services and carrying out customer surveys;
• To enable us to monitor, review and improve the Services which we offer;
• For internal record keeping;
• To allow us to contact you with direct marketing and promotional offers;
• To allow us to identify motion and other events in the information collected by your devices;
• To direct our targeting of Facebook Ads and Google Ads. For more information on Facebook Ads and your options, please see https://www.facebook.com/about/ads. For more information on Google Ads and your options, please see https://policies.google.com/technologies/ads.

V.Disclosure of your personal information

Except as described below, Rraycom will not share personal information outside of Rraycom and its controlled subsidiaries and affiliates without your permission.

Disclosure to service providers. Rraycom contracts with other companies to provide services on our behalf, such as hosting our Site, handling and storing our emails, sending out information, handling requests, processing transactions, and analyzing our Site. For example, Rraycom utilizes a third-party service provider to send an initial SMS notification to verify that your phone number is a working number.

One of the third-party services that we use is Google Analytics. You can find more information on how Google uses data, see https://policies.google.com/technologies/partner-Site.

Disclosure to distributors. In responding to a request made by you, we may share your personal information with companies that distribute our Products. We provide these companies with only those elements of your personal information they need to respond to your request.

Disclosure in connection with transactions. In connection with certain transactions, we may disclose personal information to financial institutions, government entities, and shipping companies or postal services involved in fulfillment.

Disclosures in connection with acquisitions or divestitures. Circumstances may arise where for strategic or other business reasons Rraycom decides to sell, buy, merge or otherwise reorganize businesses in some countries. Such a transaction may involve the disclosure of personal information to prospective or actual purchasers, or receiving it from sellers. Rraycom will take reasonable steps to request that the purchaser treat the data as stated in the Rraycom Privacy Notice in effect at that time.

Disclosure for other reasons. We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements or with legal process served on us, to protect and defend our rights or property, or in urgent circumstances to protect the personal safety of any individual, or where you have consented to the disclosure..

VI.Consent to international transfers of personal information

The personal information we collect may be sent to the United States or to any other country in which Rraycom or its affiliates, subsidiaries or agents operate. We may also store and process the information there. Your information may also be shared with third-party service providers in other countries in order to provide our Services. Although the laws that protect personal information in those countries may differ from the laws where you live, we will take reasonable steps to ensure that your privacy is protected. By using our Products and Services, or by providing your information to us, you explicitly consent to this transfer.

VII.Security

We are committed to ensuring that your personal information is kept and stored securely and we maintain reasonable physical, technical and organizational measures and procedures to safeguard and secure the information we collect through our Services and Site.

This has been done to help prevent unauthorized or unlawful processing of your personal information and accidental, unauthorized or unlawful access, use, processing, copying, alteration, transfer, loss or destruction of, or damage to your personal information. We endeavor to protect the privacy of your account and other personal information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We protect the security of your personal information by:

• Using encryption where appropriate;
• Using password protection where appropriate; and
• Limiting access to your personal information (for example, only our staff or employees who need access to it for the purposes described in this Privacy Notice will have access to it).

These measures do not release you from the responsibility of taking appropriate steps to keep your personal information safe and secure, such as avoiding obvious user ID's or passwords, changing your password regularly and ensuring that you do not disclose your password(s) to others or grant any other person access to your user account and your personal information. We cannot guarantee that your personal information is secure when submitted or otherwise communicated through insecure means.

VIII.Use of Rraycom services by children

Rraycom Services are marketed to and intended to be used by adults. Children under the age of 18 (or equivalent minimum age in the jurisdiction where they reside) require consent from a parent or guardian to use Rraycom products. We do not knowingly collect personal information from children under the age of 18 (or equivalent minimum age in the jurisdiction where they reside).

IX.Your choices

• You can opt out of receiving our marketing and promotional emails by adjusting the settings in your Account or by following the instructions provided on any marketing or promotional email received from us.
• Your browser may allow you to disable cookies on our Site. Most browsers will provide instructions on controlling which cookies can be used. Please be aware that if you choose to block or otherwise limit our cookies, it may affect the quality of services provided.
• You have privacy settings that you can adjust on your Rraycomaccount.
• In some cases, you can review and correct some of your personal information that Rraycomprocesses by accessing your account and updating your personal information. You can help us to maintain the accuracy of your information by notifying us of any change to your mailing address, phone number, or e-mail address. Note that we need to retain certain records for legal or internal business reasons and that some of your information may remain on backup systems, in compliance with applicable law. We will retain your personal information for as long as necessary to provide you with the Services you are eligible to use, or as needed to comply with our legal obligations or enforce our agreements.
• You also always have the choice to not use our Services and to cancel your accounts and discontinue use of our products at any time.

X.Data processing, storage and transfers where the General Data Protection Regulation applies

This section only applies where the General Data Protection Regulation (“GDPR”) is applicable.

Identity of Controller and Processors

A data controller is the natural or legal person, or entity that directs the processing of your personal data and is chiefly responsible for the data. A processor is the natural or legal person, or entity that processes personal data on behalf of a controller.

For Users. Generally, for data collected from Rraycom’s Products and Services, Rraycom will be the controller of your data.

For Third-Party Customers. Generally, Rraycom will be the processor of your data. If Rraycom processes your data on behalf of a business client or partner, the relationship between Rraycom and the business client or partner should be described in the privacy policy of the business client or partner.. Please see the privacy policy of the corresponding business client or partner for further information, including, if applicable, the purpose(s) and legal bases of processing and the relevant contact information of the business client or partner.

Consent to International Transfers

The personal information we collect on our Site may be sent to the United States or to any other country in which Rraycom or its affiliates, subsidiaries or agents operate. We may also store and process the information in these countries. Your information may also be shared with third-party service providers in other countries in order to provide our Services. The laws that protect personal information in these countries may differ from the laws where you live. By using our Site and/or Services or by giving your information to us, you explicitly consent to this transfer and processing of your data, including personal information. We also use appropriate safeguards, including standard contractual clauses for the transfer of personal information to third parties, where appropriate.

Please note that any information you publish publicly on our Site and App may be accessed globally.

Legal Bases for Processing

Rraycom relies on the following legal bases to collect, process, transfer, and store your personal information:

1.To allow us to enter into or fulfill the terms of a contract with you. We may need to collect and process your personal information in order to enter into or complete a contract that you are a party to, for example, we may need your name and address to deliver products to you after you order them.

2.To allow us or our partners to fulfill our legitimate business interests, such as:
a.Preventing fraud;
b.Maintaining the security of our Products and Services;
c.Conducting daily business operations;
d.Conducting direct marketing;
e.Providing, maintaining, and improving our Products and Services;
f.Managing user account;
g.Managing our Products and Services;
h.Performing research that improves our products or services for the users or public;
i.Fulfilling obligations to our partners.

3.To comply with legal obligations. Rraycom may be required to process and/or disclose your personal information when legally required to do so as in when filing taxes or answering law enforcement subpoenas. Rraycom may also disclose your information if required in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, to comply with legal obligations, or when we believe in good faith that the law requires it. We may also disclose your personal information to verify or enforce our Terms & Conditions or other policies, or to otherwise protect the rights, property, safety, or security of third parties, visitors to our Site or the public.

4.To process your information after obtaining specific consent from you to do so. For example, to contact you with special offers after you grant Rraycom consent to contact you with marketing material. Whenever consent is used to process your data you will be provided with details on how that information will be used before you grant consent. You have the right to withdraw consent for this type of processing at any time. Information on how to withdraw consent will be provided before your information is processed based on your consent. Withdrawing your consent will not affect the lawfulness of processing based on consent that was performed before consent was withdrawn.

Your Rights

The following rights are available under the General Data Protection Regulation. Please read the relevant regulations and guidance from the applicable regulatory authorities for further information on these rights.
1.The right to be informed;
2.The right of access;
3.The right of rectification;
4.The right to erasure;
5.The right to restrict processing;
6.The right to data portability;
7.The right to object;
8.Rights in relation to automated decision making and profiling.

In addition to the above-mentioned rights, if we rely on consent for the processing of your personal information, you have the right to withdraw it at any time free of charge. When you do so, this will not affect the lawfulness of the processing before your consent is withdrawn.

You also have the right to request confirmation regarding whether we are processing your personal information.

You also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

If you would like to exercise any of yours rights under an applicable law, please contact us at  Shenzhen Shoushi Technology Co., Ltd. 11 Building, Heshakeng Industrial Zone, Longbo Road, Buji District, 518000, Shenzhen, Guangdong, China.

 You may also submit an email to aftersale@rraycom.com. In order to protect your identity and the security of your personal information, Rraycom reserves the right to take reasonable steps to verify your identity before acting on any requests. Rraycom also reserves the right to charge a reasonable amount for requests.

XI.Your California Privacy Rights

Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for those third parties' direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at  aftersale@rraycom.com with "Request for California Privacy Information" as the subject line. Please be sure to provide in the body of your email request sufficient information to properly identify you and/or the members of your family.

XII.Changes to this Privacy Notice

Rraycom may occasionally update this Notice. When we do, we will revise the "last updated" date at the top of this Notice. We will provide notice of any updates that materially expand the sharing or use of your personal information in ways not disclosed in this Notice at the time of collection.

XIII.Questions and Contact Us

 Shenzhen Shoushi Technology Co., Ltd. 11 Building, Heshakeng Industrial Zone, Longbo Road, Buji District, 518000, Shenzhen, Guangdong, China. Or submit an email to  aftersale@rraycom.com We will promptly address your concern and strive to reach a satisfactory resolution.