EXVISION, INC.

PRIVACY POLICY

(Effective Date: May 12, 2016)

Exvision, Inc. (“Company,” “we”, “us” or “our”) maintains this Privacy Policy (“Privacy Policy”) that summarizes the treatment of information provided or collected on the sites and in connection with our various services (collectively, the “Services”) where this Privacy Policy is posted, including, without limitation, our website(s) (our “Sites”).

By accepting our Privacy Policy and the applicable End User License Agreement (“EULA”) you consent to our collection, storage, use and disclosure of your information as described in this Privacy Policy.   

Types and Collection of Information

Our primary goal in collecting the information described below is to provide you, the user, with a customized experience on our Service and to deliver better service, products, and more relevant content to our customers, prospective customers, and visitors.   

1. Types of Information We Collect

We collect two basic types of information in connection with our Service: (a) Personal Information and (b) Anonymous Information.  Personal Information, Anonymous Information and Aggregated Information as used in this Privacy Policy are defined below:

Personal Information” means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s first and last name, home or other physical address, email address, telephone number, social security number.  Personal Information also includes identifiers, such as cookies, IP addresses and Mobile Device IDs that recognize individuals over time and across different websites or online services, where those identifiers can be reasonably linked to an identifiable individual.

Anonymous Information” means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual person.  When Anonymous Information is directly or indirectly associated with or combined with any Personal Information, such Anonymous Information will also be treated as Personal Information.

Aggregated Information” means information about groups or categories of persons, which does not identify and cannot reasonably be used to identify an individual person.

2. How We Collect Your Information

Information Collected Directly From You

When you interact with the Service, we collect information (including Personal Information) you provide to us directly as described below:

Registered Information.  When you visit our site http://www.zkoocamera.com or register with us within the Service or download and install any of our software products, you may be asked to provide: (i) your first and last name; (ii) your e-mail and mailing address; (iii) user name and password; (iv) language preferences and (v) such other information (including Personal Information) that may be necessary to complete the registration process.

Information Through Mobile Devices.  When you access the Service through your mobile telephone or other mobile devices (“Mobile Device”), we collect: (i) Mobile Device type and manufacturer; (ii) mobile carrier; (iii) Mobile Device identifiers or advertising identifiers (“Device ID”); (iv) telephone number; (v) Internet Protocol address; (vi) geographic location/country/zip code; (vii) platform version; (viii) installation, navigation, access, interaction, impression and engagement information; (ix) network connection type (3G, 4G, WiFi, etc.); (x) browser type; (xi) Mac address; (xii) iOS advertiser ID; (xiii) user ID and (xiv) such other information you voluntarily provide to us. In addition, we collect information you provide when you sign up to have Short Message Service notifications sent directly to your Mobile Device.   We use your Device ID to verify, audit and analyze your use of the Services.  Please note that the Device ID alone does not constitute Personal Information.

Customer Service and Technical Support.  When you communicate with us in connection with customer service and technical support, we will collect and store your contact information (including, without limitation, name, telephone number and email address), information about your use of the Service, your user ID and such other information you voluntarily provide to us in connection with such inquiry.

Other Sources.  We may collect your information from other sources, including, without limitation, other users of the Service and third party information providers, service vendors and partners.  For example, we collect information you provide to us or third party partners when you enter any promotions, sweepstakes and loyalty program.

Information Collected by Automated Technologies

When you interact with the Service, we collect Anonymous Information through automated technologies as described below:

Cookies.  A “cookie” is a small text file that is sent to your browser from a web server and stored on your computer’s hard drive or Mobile Device.  We may use cookies to track Anonymous Information about our users (e.g., user name, pages viewed, time spent on our Site(s) and the sites visited just before and just after our Service) for statistical and market research purposes.    

We use cookies to gather information about our users’ browser activities.  We may also use local shared objects also known as “flash cookies” to collect information from you.

You have choices with respect to cookies.  By modifying your browser preferences, you have the option to reject all cookies, or limit the type of cookies you allow.  Flash cookies operate differently from browser cookies and cookie management tools available in a web browser will not remove flash cookies.  To learn more about and manage flash cookies please go to the following: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html. Rejecting or limiting the type of cookies may, however, in limited instances prevent you from accessing certain features on our Service.

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer to help the website analyze how our users use our web site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this Site, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Use and Disclosure of Personal Information

Unless otherwise described elsewhere in this Privacy Policy, we will not use or disclose any Personal Information collected from you.  Your Personal Information may be used alone or in the aggregate with information collected from other users.

1. Use by Company

We use your Personal Information for any one or more of the following purposes:

(a) to operate, maintain and improve our products and Service;

(b) to conduct market research analyses, including, without limitation, to analyze user characteristics and usage patterns in order to better understand how our Services are used and market them more effectively and to optimize the display of advertisements;

(c) to communicate with you with your explicit consent or as permitted by law, to send you announcements, newsletters, promotional materials and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, and sweepstakes;*

(d)  to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving our Service;

(e)  to respond to customer service and technical support inquiries, troubleshoot problems, investigate incidents, and handle complaints;

(f) to provide the Services to you and our customers;

(g) to comply with applicable laws, regulations, legal processes or enforceable government requests;

(h) to send notices, such as changes to this Privacy Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such policies; and

(i) to protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.

The Company processes Personal Information on our servers in the United States of America, Japan and in other countries.  In some cases, we may process Personal Information outside of your country.

*Any promotional emails we send will identify us as the sender and will include our contact details.  Moreover, such emails will provide for an unsubscribe option.  In addition, your consent to receiving promotional emails will remain current for until you advise us otherwise in writing.

2. Disclosure to Third Parties

Third Party Service Providers.  We may disclose your Personal Information to third party service vendors and partners (including carriers and content providers) in connection with our provision of the Services.  Such third party service vendors and partners may be located in countries other than your country of residence and provide such services as payment processing, data analysis, e-mail delivery, hosting, order fulfillment, infrastructure and network storage, customer service, technical support, auditing, content licensing and promotional services.

Affiliates.  We may disclose Personal Information to our “Affiliates” (which shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership located in the United States, Japan or anywhere else in the world) for the purpose of transferring and processing such Personal Information based on our instructions and such purposes as described in this Privacy Policy.

Ownership Change.  In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation or other similar process, your Personal Information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction.  If material changes to the Company’s privacy practices will occur as a result of such transaction, you will be notified via prominent notice in our Service of any change in ownership or uses of your Personal Information, as well as choices you may have regarding your Personal Information.

3. Safety, Security and Legally Required Disclosures

Your Personal Information, and communications you make within the Service, may be accessed and disclosed if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our End User License Agreement, or for us to render the service you have requested.

We may also disclose Personal Information when required by law, regulation, court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us.  In addition, we will make any legally required disclosures to government authorities.  In addition, we will provide notice to you of any breach of security, confidentiality or unauthorized release of personal or private data in accordance with applicable laws, rules and regulations.

C. Storage of Information and Security

We employ reasonable measures (both online and offline) to protect the security of information we collect from you.  Such information is housed in secure databases, equipment and servers located in the United States, Japan and/or in other countries.  The databases, equipment and servers we utilize may be owned by third party providers.  To prevent unauthorized access, loss, or misuse, maintain data accuracy, and ensure the appropriate use of information, we have put in place physical, electronic, and managerial procedures to safeguard and secure the information we maintain.  We use industry-standard technology, such as firewalls, in an effort to protect the confidentiality of your Personal Information.

Although we take reasonable precautions against possible security breaches of our Service, databases, equipment or servers, and records, we cannot guarantee that unauthorized access, hacking, data loss, or other security breaches and factors beyond our control will never take place and result in disclosure of your Personal Information.  Accordingly, we disclaim any guarantees, warranties or representations relating to maintenance or nondisclosure of any Personal Information collected from you.  We strongly urge you to take reasonable measures at all times (online and offline) to protect your Personal Information, including your password and other sensitive information.

In addition, while we strive to protect your Personal Information, you should know that information sent over the Internet, whether by e-mail or by using one of our on-line forms, is not necessarily secure against interception.  Therefore, we cannot be responsible for such interception and cannot guarantee the security of such information.

We will investigate, attempt to resolve and take all reasonable steps necessary to ensure that your Personal Information and data is treated securely and in accordance with this Privacy Policy.    

D. Additional Privacy Policy Terms

1. Opt-Out Provision

You may opt out of having your Personal Information used for the following purposes at any time by emailing us a request at: support@zkoocamera.com and include your registered email address so that we can confirm your identity. We will use our commercially reasonable efforts to comply with your request.

(a) Receiving Marketing Communications from the Company.  You may opt out of receiving marketing communications from us relating to our Services, including, without limitation, announcements, newsletters and promotional materials or offers to participate in surveys, campaigns or sweepstakes, by choosing not to opt in when we ask for your prior consent to receive commercial electronic messages, including text and email messages, and direct social media messages.

(b) Disclosing Personal Information to Affiliates.   You may opt out of us disclosing your Personal Information to our Affiliates for marketing purposes by choosing not to opt in if we ask for your consent in advance or emailing us.

(c) Disclosing Personal Information to Third Party Service Providers.  You may opt out of us disclosing your Personal Information to authorized third party service providers for marketing purposes by choosing not to opt in if we ask for your consent in advance or emailing us.

2. Your California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, customers, prospective customers, and visitors of our Service who are residents of the State of California have the right to request certain information regarding its disclosure of Personal Information to third parties for direct marketing purposes.  If you are a resident of California and wish to request such information, please email us at: support@zkoocamera.com with “California Privacy Rights” in the subject line.

3. Review, Update, Correct, or Delete Personal Information

Generally, you may review, update, correct or delete your Personal Information collected by or through our Service by logging into your account.  You may also correct factual inaccuracies.  Certain types of Personal Information that is necessary to check eligibility, such as birth date or age, cannot be deleted for active accounts, but may be modified with sufficient verification of the new information.  Note that we reserve the right to terminate or delete any registration or promotional entry if we believe the Personal Information submitted was knowingly false or fraudulent. To delete your Personal Information, you may also email us at  HYPERLINK “mailto:info@exvision.co.jp” support@zkoocamera.com.  We will use commercially reasonable efforts to honor your request.

4. Notification of Changes

We reserve the right to update and change the terms of this Privacy Policy at any time.  If we decide to update and materially change the terms of our Privacy Policy, we will post those changes in our Services and/or on the applicable Sites, and in the updated Privacy Policy. You should periodically check this Privacy Policy for updates.

By continuing to access or use the Services after we have posted an updated Privacy Policy or have provided you with notice of any material modifications to same, you are agreeing to be bound by the modified Privacy Policy.  If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

5. Links to Third Party Websites, Services and Offers

Our Service may contain links to other websites, services and/or offers from third parties.  We are not responsible for, nor will it be liable to you or any third party for, your interaction with such third parties or the information requests initiated by such third parties or the subsequent use, treatment or dissemination of the information (including any Personal Information) you voluntarily chose to provide to them. You should review the applicable privacy policies and information practices of such third parties carefully before providing Personal Information to them.  Moreover, if you have any questions or concerns, you should contact the third party directly.

6. Protection of Children’s Privacy

Company is committed to providing special protection for the privacy of children who may use our Service.  The Service is not intended for nor directed to children under the age of 13 and we do not knowingly collect, use or retain Personal Information from such children.  If we discover that we have inadvertently collected Personal Information from children under the age of 13, we will take all reasonable measures to delete any records of such Personal Information that come to our attention.

7. Special Note to Parents

If you become aware that your child has provided us with Personal Information, please notify us so that we may delete such information from our records and discontinue any related features or services (see Opt-Out Provision above).  We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet.  We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

8. Users Outside United States

The Company is a U.S. company and Company’s U.S. business operations are primarily conducted in the States of California, U.S.A.  We operate our company and administer this Privacy Policy under applicable U.S. and California laws and regulations.  If you use our Service from outside United States, you are thereby consenting for your Personal Information to be transferred to, stored in and be processed in the United States, Japan and/or in other countries by the Company and/or its Affiliates in the manner described in this Privacy Policy.  Your consent to this Privacy Policy followed by your submission of your Personal Information represents your agreement to such transfer, storage and processing of your Personal Information.  Furthermore, you acknowledge that the privacy laws of the United States and the State of California may differ from the laws in the country where you are located and may not provide you the same rights or protections for your Personal Information as those laws.

As described elsewhere in this Privacy Policy, when you submit Personal Information to us, the information is housed in secure databases, equipment and servers located in the United States, Japan and/or in other countries.  The databases, equipment and servers we utilize may be owned by third party providers.

Users in certain jurisdictions may have a right to access his/her Personal Information held by the Company, its Affiliates or authorized third party service providers.  Your right of access to such Personal Information can be exercised in accordance with applicable laws, rules and regulations.  Please submit any requests for such access to HYPERLINK “mailto:info@exvision.co.jp” support@zkoocamera.com.

9. Language

The controlling language of this Privacy Policy is English.  If you have received a translation into any other language, it has been provided for your convenience only.  The English version of this Privacy Policy shall govern to the extent of any inconsistency between the English version and any translated version.

10. Do Not Track.  We do not respond to DNT (Do Not Track) signals.

11. Contact Us

If you have any questions, inquiries, requests, complaints, or comments regarding this Privacy Policy, or have other questions or suggestions about our information practices, please contact us via email at: support@zkoocamera.com.

Copyright © 2016 Exvision, Inc.  All rights reserved.

Exvision Inc.  440 North Wolfe Road, Sunnyvale, CA 94085