Version 1.0

Version release date: 2024/12/17

Version effective date: 2024/12/17

Arashi Vision Inc. (hereinafter referred to as “Insta360”, “us” “our” or “we”) and its affiliates recognize the importance of protecting the personal information we may collect from visitors, users and any other individual or entity (collectively, “Users”, “you”, or “your”). We value your interests and fundamental rights and are committed to processing personal information in a professional, lawful and ethical way. The "Insta360 Connect Privacy Policy" (hereinafter referred to as "this Policy") applies to our Insta360 Connect and built-in system services (hereinafter referred to as "Connect Services"). Insta360 Connect is an intelligent dual-camera video conferencing All in One developed by us, which brings you an unprecedented immersive face-to-face meeting experience with professional audio & video capabilities. For parts not covered by this policy, the Insta360 Privacy Policy shall prevail. Unless otherwise agreed, terms used in this policy have the same meanings as those in the Insta360 Connect User Agreement.

Please read this Policy carefully as it will help you understand what we do with the personal information that we process. Please pay special attention to the important contents of this Policy, which have been highlighted in bold form. We attach great importance to the protection of your personal information and will follow current laws and regulations to properly handle your personal information based on legal and legitimate methods and the principle of good faith by using or continuing to use our Services after we have updated this Policy (and we will promptly notify you of such updates), you agree to the content of this Policy (including the updated version) and our collection, use, storage and protection of personal information about you in accordance with this Policy. If you have any other queries regarding this Policy or our use of your personal information, please refer to our contact information at the end of this Policy.

This policy will help you understand the following:

1. How we collect and use your personal information

2. How we share, outsource, transfer, and disclose your personal information

3. How we protect and store your personal information

4. How you manage your personal information

5. How your personal information is transferred globally

6. Protection of minors’ information

7. Special rules for California consumers: Do Not Sell or Share My Personal Information

8. Special rules for California consumers: Do Not Sell or Share My Personal Information

9. Notices and Revisions

10. How to contact us

1. How we collect and use your personal information

Personal information is all kinds of information relating to an identified or identifiable natural person, recorded electronically or by other means, excluding information that has been anonymized. Please note that the definition of "personal information" (or "personal data" and other similar expressions) may vary from country to country or region to region, so please refer to the laws and regulations related to the protection of personal information in your region.

We collect and use personal information that you voluntarily provide in the course of using the products and services or as a result of using the products and services, and obtain personal information about you from third parties for the purposes described in this Policy, in accordance with the principles of legitimacy, legality and necessity. If we want to use your personal information for purposes other than those described in this Policy, or use the information collected for a specific purpose for other purposes, we will inform you in a reasonable manner and obtain your consent again before using it.

*If you are a resident of Singapore, the following information is not "personal information" for the purposes of this Policy:

⦁ "Business contact information", i.e., "an individual's name, job title, business e-mail address or business fax number, and any other similar information about the individual that is not provided by the individual solely for his or her purposes".

⦁ Personal data contained in records that have been in existence for at least 100 years;

Personal data of deceased individuals who have been dead for more than 10 years.

1.1 Information we collect

When you use our products/services, we need to collect and use your following personal information:

1.1.1 To provide you with basic features and services, we may read information related to your device, such as connected Wi-Fi, country, language, device manufacturer and model, device identification code, TV/monitor resolution, etc.;

1.1.2 When you use "Speakerphone Mode", we need to obtain Bluetooth permissions from you and collect the Bluetooth name of your device and the paired Bluetooth name list of your own devices.

1.1.3 To improve the security and user experience of your use of our services, upon your opt-in consent to the User Experience Program, we may collect some information such as your service usage habits and preference, etc. (see Appendix: Insta360 Connect event tracking list). You have the right to withdraw your consent to the User Experience Program at any time through ‘Settings’.

1.1.4 In order to provide you with Speaker Tracking, Group Framing, and Gallery Mode, we may collect your voice and facial image information during each meeting, and use artificial intelligence technology to analyze and process your voiceprint and facial features. This type of information collection is only used in the meeting so as to provide you with the Speaker Tracking, Group Framing, and Gallery Mode. After each meeting, we will delete your collected voice and facial image information and will not store your voiceprint and facial features. For details, please refer to the the Privacy Statement for Facial and Voiceprint Recognition Service.

1.1.5 In addition to the above information, in order to provide you with customer service, we may collect the content you send to us through customer service.

Please be aware and assured that we highly respect and attach great importance to protecting your privacy. We will not store any video and voice content or records generated during your use of Insta360 Connect for communication, nor will we retain any of your facial or voiceprint features.

1.2 How we use the information we collect

We strictly abide by the provisions of laws and regulations and the agreements with users under this Policy to use the information collected for the following purposes. If we intend to use your information for purposes beyond those listed below, we will explain this to you and obtain your consent in advance.

a) To provide users with the basic service functions of the services or necessary to maintain the safe and stable operation of our platform services, such as the detection and handling of product or service failures.

b) To make improved products or offer superior service by analyzing the log files we collected.

c) To send you relevant information, such as changes to our Policy terms, conditions and policies regarding the services.

d) To prevent, detect, and investigate fraud, security hazards, illegal activity or violations of agreements, policies or rules with us or our affiliates in order to protect the legal rights of you, our other users, or us or our affiliates.

e) For auditing, developing new products, analyzing usage trends, improving operational efficiency and promotional purposes.

f) Other uses for which we have your consent.

1.3 Exceptions to the collection and use of personal information

You understand and agree that we have the right to collect and use your personal information without your consent in the following circumstances.

a) Processing as is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract;

b) Processing as is necessary for compliance with a legal obligation to which we are subject;

c) Processing as is necessary in order to protect the vital interests of you or of another natural person;

d) Processing as is necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in us;

e) Processing as is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data.

f) Other circumstances which are allowed by applicable laws.

1.4 Rules for the use of the information we collect

1.4.1 We will use the personal information collected to set out in this Policy and for carry out the features of our services.

1.4.2 After collecting your personal information, we will de-identify the information through technical means, and the de-identified information will not be able to identify the subject. Please understand and agree that information obtained through the foregoing activities will be treated by us as non-personal information, unless otherwise required by applicable laws and regulations. We may provide our partners with aggregate information obtained on the basis of de-identified information about how users use and viewpoints provided through the Software so that our partners have an understanding of the frequency, volume and activities of users using the Software. For the avoidance of doubt, under this section, we will only use the information for lawful purposes and the aggregate information provided to our partners will not indicate any specific user. We may also use or share with third parties for lawful purposes any information that we have collected in the aggregate or that is not identifiable.

1.4.3 Please understand and agree that for all personal information you provide while using our products and/or services, unless you delete or reject our collection through system settings, you will be deemed to have continuously authorized consent to our use for the duration of your use of our products and/or services.

1.4.4 We will seek your prior consent when we want to use your personal information for purposes other than those stated in this Policy, or when personal information collected for a specific purpose is used for other purposes. Please understand that the products and/or platform services we provide to you are subject to change from time to time. If you choose to use other products and/or services not listed in this Policy, we will provide you with a detailed explanation of the purpose, manner and scope of the collection and seek your consent through agreements, page prompts and other means before collecting your personal information. If you do not agree to provide the aforementioned information, you may not be able to use the product and/or service, but it will not affect your use of existing products and/or services.

2. How we share, outsource, transfer, and disclose your personal information

2.1 Sharing of your personal information

For the purpose of providing you with better, more optimal and personalized services, or jointly providing services to you, or for the purpose of preventing Internet fraud, as required by law or as agreed with you or with your consent, we may share your personal information with our affiliates, partners, or other third parties in accordance with legal provisions or agreements with you or with your consent. Please be aware that you have the right to refuse to consent to our sharing of your personal information to third parties, and if you refuse to consent to our sharing of information to third parties, you may not be able to use the corresponding functions. We will not share your personal information with third parties except in the following circumstances:

2.1.1 Obtain your prior consent or authorization;

2.1.2 In accordance with laws and regulations, administrative and judicial mandatory requirements;

2.1.3 To the extent permitted by law or regulation, as necessary to protect our affiliates or partners, you or other users or the public from harm to their interests, property or safety;

2.1.4 Enable the core functions of our products and/or services or to provide the services you require;

2.1.5 Handling disputes or controversies between you and others for you at your request;

2.1.6 In accordance with the relevant agreement with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents agreed to be provided;

2.1.7 Based on academic research;

2.1.8 Based on the public interest of society in accordance with laws and regulations, public health emergencies and use.

Please note that we will only share your personal information with third parties (as shown on the page) as necessary to achieve the purposes described in Section 1 of this Policy. At the same time, we will only share personal information that is necessary to provide our products and services, and we will enter into strict confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.

For details of the circumstances under which we share personal information with third parties are as follows:

2.2 Outsourcing

We currently use Alibaba Cloud to store the personal information we collect. For the companies, organizations and individuals we outsource to process personal information, we will require them to comply with strict confidentiality obligations and take effective confidentiality measures through written agreements, on-site audits, etc., and require them to process your personal information only within the agreed scope of the contract, and not to use your personal information for their own benefit.

2.3 Transfer of personal information

We will not transfer your personal information to any company, organization or individual, except for the following:

a) Obtain your prior consent or authorization;

b) Provided in accordance with the relevant agreement or other legal document signed with you;

c) In the event of a merger, acquisition, transfer of assets, liquidation or similar situation involving the transfer of personal information, you understand and agree that your personal information will be transferred to the relevant third-party company or organization. We may require the new company or organization holding your personal information to continue to be bound by this Policy, or we may require that company or organization to seek your authorized consent again.

2.4 Disclosure of personal information

We will only disclose your personal information if we take security measures that are consistent with industry standards and if:

a) After obtaining your consent;

b) In the case of laws and regulations, legal proceedings, litigation or mandatory requirements by government authorities.

3. How we protect and store your personal information

3.1 How long do we store your personal information

We will only store your personal information for as long as necessary for the purposes described in this Policy and for as long as required by law, regulation and supervision, unless there is a mandatory retention requirement by law.

If we terminate the service or operation, we will promptly stop the activities of continuing to collect your personal information, and at the same time will comply with the requirements of relevant laws and regulations to notify you in advance, and delete or anonymize your personal information after the termination of the service or operation, unless otherwise provided by laws, regulations or regulatory authorities.

3.2 Where we store your personal information

Currently, we use the Alibaba Cloud database (Hong Kong) to store your personal information. This means that your personal information may be transferred to, or accessed by, countries or regions other than your place of residence.

3.3 How we protect your information

We have taken reasonable and practicable security measures, consistent with industry standards, to protect your information from unauthorized access, disclosure, use, modification, damage or loss of personal information. We take the following steps to keep your data secure:

a) Using encryption technology to improve the security of personal information, protected by SSL protocol encryption when exchanging data between your browser and the server, providing HTTPS protocol for secure browsing;

b) Use of trusted protection mechanisms to prevent malicious attacks on personal information;

c) Deploy access control mechanisms and make every effort to ensure that only authorized personnel have access to personal information;

d) Conducting security and privacy training courses to enhance employees' awareness of the importance of protecting personal information;

e) Specialized data compliance management systems, processes and organizations are in place to safeguard information. For example, we strictly limit the scope of people who access information, require them to comply with confidentiality obligations, and conduct audits.

We will take all reasonably practicable steps to ensure that no unrelated personal information is collected. We will retain your personal information only for the shortest period necessary to achieve the purposes described in this policy, unless otherwise required by the laws and regulations of your location.

The Internet environment is not 100% secure and we will endeavor to ensure or warrant the security of any information you send us. If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legal rights and interests, we will assume appropriate legal liability. After the unfortunate occurrence of personal information security events, we will strictly follow the requirements of the laws and regulations of your location and inform you in a timely manner of: the basic situation and possible impact of the security event, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents and fulfill the obligations stipulated in other laws and regulations in accordance with the requirements of regulatory authorities.

4. How you manage your personal information

In accordance with the relevant laws, regulations and standards of, as well as the prevailing practices in other countries and regions, we protect your right to exercise the following rights with respect to your personal information. Please note, however, that we may not be able to respond to your request for personal information rights if the relevant personal information you have requested has exceeded the minimum period necessary to achieve the purposes described in this policy or has been deleted. The personal information rights you may exercise include:

4.1 Right to access to personal information

You have the right to view your personal information collected by us by sending an email to the service@insta360.com or DPOcontact@insta360.com to submit your request. We will review it as soon as possible and reply within 15 working days after verifying your user identity.

4.2 Right to correct your information

If you discover that we have processed your personal information incorrectly, you have the right to request that we make corrections. You may contact us at any time through the contact information provided on Insta360 Connect, or send an email to service@insta360.com or DPOcontact@insta360.com.

4.3 Right to delete personal information

You may request us to delete personal information in the following cases:

a) We collect and use personal information in violation of laws and regulations;

b) Our processing of personal information is in breach of the agreement with you;

c) We collect and process your personal information without your consent;

d) You no longer use our products or services, or you cancel your account;

e) We no longer provide products or services to you.

If we decide to respond to your request for deletion, we will also simultaneously notify the entities (if any) from which we obtained your personal information to request its prompt deletion, unless otherwise required by law or regulation, or unless such entities have your independent authorization. When you delete information from our platforms, we may not immediately delete the corresponding information from our backup systems, but will delete it when the backup is updated.

4.4 Right to portability of personal information

You have the right to obtain a copy of your personal information and you can do so at any time by contacting our customer service or DPO(service@insta360.com or DPOcontact@insta360.com) and we will respond to your request within 15 business days. Where technically feasible, such as data interface matching, we may also transfer a copy of your personal information directly to a third party designated by you at your request.

4.5 Stop automated decision making

Currently, we do not make decisions solely based on non-manual automatic decision-making mechanisms such as information systems and algorithms, etc. If there is a situation in the future involving the use of automatic decision-making mechanisms to make decisions, we will strictly inform you in accordance with relevant laws and regulations through appropriate means. If these decisions significantly affect your legal rights, you have the right to an explanation. If these decisions significantly affect your legal rights, you have the right to seek an explanation from us and we will provide appropriate remedies.

4.6 The right to restrict the processing of personal information

You may limit our processing of your personal information in the following circumstances.

a) When you question the accuracy of the personal information we have collected about you, or when we are verifying the accuracy of the personal information in question

b) When you believe that our processing of your personal information is unlawful.

c) When we no longer need your personal information in question for the processing purposes set out in this Policy, but you need that personal information for legal claims.

d) When the legal basis for processing your personal information is in the public interest, or the legitimate interests of us and third parties.

4.7 Right to object to personal information

You have the right to object at any time to our processing of your personal information for direct marketing purposes, as well as the right to object to automated decision-making, including analysis that has legal effect or significant impact on you. You have the right to adjust the scope of the personal information we continue to collect or withdraw your authorization at any time, and when you withdraw such consent or authorization, we will no longer process the corresponding personal information and will not be able to continue to provide you with the services for which you have withdrawn your consent or authorization. Your adjustment of the scope of your authorization will not affect the processing of your personal information by Insta360 based on your consent or authorization prior to the adjustment.

4.8 Respond to the above request

If you are unable to access, correct, delete, or view and edit your personal information in the manner described above, or if you believe that Insta360 has violated any laws, administrative regulations, or agreements with you regarding the processing of your personal information, you may contact us through the channels set forth in this Policy. For security purposes, you may be required to provide a written request or otherwise prove your identity. We may first ask you to verify your identity and process your request within the period specified by the laws and regulations of your region. In principle, we do not charge any fees for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits, as appropriate. We may refuse unwarrantedly repetitive requests, require excessive technical means (requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are impractical (involving backups of information stored on tapes).

In the following cases, according to the laws and regulations, we cannot respond to your request:

a) Directly related to national security or national defense security.

b) Directly related to public safety, public health, and significant public interests.

c) Directly related to crime investigation, prosecution, trial and execution of judgments, etc.

d) Where there is sufficient evidence that you have subjective malice or abuse of rights.

e) Where responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations.

f) where trade secrets are involved.

If we respond to your request for deletion, we will also notify the entities from which we obtained your personal information and request that they delete the corresponding information in a timely manner, unless otherwise provided by law or regulation or unless these entities have your independent authorization.

*If you are a Hong Kong resident, in principle, we will respond to your request for access within 40 days, unless:

a) The request is neither made in writing in Chinese nor writing in English;

b) You have not provided us with information that is reasonably necessary to respond to the request, etc.

If you are a Hong Kong resident, in principle we will respond to your request for correction within 40 days, unless:

a) We are unable to determine your identity;

b) The request is neither made in writing in Chinese nor in writing in English;

c) We are unable to determine whether the correction request is accurate/confident that the correction request is inaccurate, etc.

5. How your personal information is transferred globally

Currently, we use the Alibaba Cloud database (Hong Kong) to store your personal information. This means that your personal information may be transferred to, or accessed by, countries or regions other than your place of residence. These countries or regions may have different regulations on the protection of personal information, or even no corresponding regulations on the protection of personal information. In such cases, we will make every effort to ensure that your personal information is adequately protected in accordance with this Policy. We will strictly follow the laws and regulations of your location and the regulations of the relevant regulatory authorities, and fulfill our obligations under the laws and regulations, such as explaining to you the purpose of the outbound of personal information and the type of personal information involved, and requesting the overseas organizations to keep your personal information obtained confidential through effective measures such as signing agreements and on-site verification.

6. Protection of minors’ information

Our products and services are intended for adults and are not directed at minors.We do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a minor without the consent of the minor's guardian, we will delete the data as soon as we are aware of it. If you believe that we may improperly hold personal information from or about a minor, please contact us.

*The age of majority is determined by the laws and regulations of your country or region.

7. Special rules for California consumers: Do Not Sell or Share My Personal Information

California Consumers have the right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration. If you are a California Consumer and would like to exercise your Right to Opt-Out of Sale or Sharing, you may email DPOcontact@insta360.com to submit your "Do Not Sell or Share My Personal Information" request.

8. Special rules for Singapore residents: Do Not Call

If you are a resident of Singapore, you have the right to apply the Do Not Call rules, which means that if you do not wish to receive telemarketing messages via phone call, SMS or fax, you can register your Singapore telephone numbers with the DNC(Do Not Call) Registry. You can remove your number from the DNC Registry whenever you want.

9. Notifications and Revisions

This Policy may be updated to provide you with better service as our business evolves. However, we will not reduce your rights under this Policy without your consent. We will notify you of updates to this Policy by posting updated versions on our website and by appropriate means before they become effective, and we invite you to visit our platform to keep up to date with the latest Privacy Policy.

We will also provide more prominent notice of material changes (we will provide specific notice of changes to our Policy, including, but not limited to, a special notice on the viewing page).

Material changes within the meaning of this Policy include, but are not limited to:

a) Significant changes in our service model, such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;

b) Significant changes in our ownership structure, organizational structure, etc. such as changes in ownership due to business restructuring, bankruptcy and mergers, etc.;

c) Changes in the primary recipients of personal information sharing, transfer or public disclosure;

d) Significant changes in your rights to participate in the processing of personal information and how they are exercised;

e) In the event of a change in the department responsible for handling the security of personal information, our contact information and complaint channels;

f) When the personal information security impact assessment report indicates a high risk.

10. How to contact us

If you have any questions, comments or complaints about our Privacy Policy, or wish to contact us, please do so as follows:

For Specific issues related to the software or the user's account (including access to one's own information), please e-mail us at service@insta360.com.

For general inquiries or complaints about privacy issues, please e-mail us at DPOcontact@insta360.com or write to us at the following address: 25th Floor, Building 1, Jinlitong Financial Center, 1100 Xingye Road, Haiwang Community, Xin'an Street, Bao'an District, Shenzhen, Guangdong, China, postal code: 518000.

If you are not satisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you may also file a complaint or report to the regulatory authority in your area.

Appendix: Insta360 Connect event tracking list