Version 1.0

Published date: 2025/9/25

Effective date: 2025/9/25

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 Wave Privacy Policy" (hereinafter referred to as "this Policy") applies to our Insta360 Wave and built-in system services (hereinafter referred to as "Wave Services"). Insta360 Wave is an intelligent omnidirectional speakerphone we developed, dedicated to providing you with clearer and smarter audio solutions. Insta360 Wave Controller is a client application for controlling Insta360 Wave, designed to help you operate Insta360 Wave devices more conveniently through computers. It also provides you with additional practical functions, such as marking audio highlights during meeting recordings, adding screenshots, identifying conference software status, and providing recording reminders, etc. 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 Wave 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 contact us at dpocontact@insta360.com.

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. Children's Data
7. Special rules for California consumers: Do Not Sell or Share My Personal Information
8. Special rules for Singapore residents: Do Not Call
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 Wi-Fi, country, language, device manufacturer and model, device identification code, etc.;

1.1.2 When you need to use the screenshot function during voice recording, we will obtain your screen capture permission and access your screenshot images to assist you in completing the screenshot service.

1.1.3 When you use the "Bluetooth Mode", we need to obtain Bluetooth permissions from you and collect your device's Bluetooth name. Meanwhile, we need to obtain your address book permission and access your contacts' information to display incoming call information (including the incoming phone number and the name of the caller (if available)) on your device in Bluetooth Mode, enabling you to quickly answer or hang up calls via the device.

1.1.4 To enhance the security of your use of our services and optimize your user experience, when you agree to join the User Experience Program, we may collect your preferences and usage habits through data tracking and other similar technologies. You have the right to withdraw your consent to the User Experience Program at any time through "Settings - General - Terms&Policies".

1.1.5 To provide you with the function of identifying speakers in speech-to-text conversion, we will collect your voice information during each online voice communication and use artificial intelligence technology to analyze and process your voiceprint features. Such information collection is solely for providing you with speech-to-text conversion and speaker identification functions. After you delete your recordings or unbind your device, we will delete your voiceprint feature information to ensure the security of your information. For details, please refer to the "Insta360 Wave Voiceprint Recognition Service Privacy Statement".

Please be aware and assured that we highly respect and attach great importance to protecting your privacy. Without your explicit consent, we will not store any video and voice content or records generated during your use of Insta360 Wave for communication, nor will we retain any of your 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

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

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

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

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

e) Processing as 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 as set out in this Policy and to 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 as required by law or in accordance with 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 with third parties, and if you refuse to consent to our sharing of information with 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 in accordance with laws and regulations, or for public health emergencies.

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, you can contact us at dpocontact@insta360.com.

2.2 Outsourcing

To enhance service quality and operational efficiency, we may engage vetted third-party data processors to handle specific categories of your 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 data centers and service providers in many parts of the world to store your personal information, including the United States of America, Germany and Hong Kong SAR. 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) Using trusted protection mechanisms to prevent malicious attacks on personal information;

c) Deploying access control mechanisms and making 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, which may cause 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 subjects 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, 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 personal information

You have the right to view your personal information collected by us by sending an email to 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 Wave, or send an email to service@insta360.com or DPOcontact@insta360.com.

4.3 Right to delete personal information

You may request us 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 from us and we will provide appropriate remedies.

4.6 The right to restrict the processing of personal information

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 personal information we continue to collect or to 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 to 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 fee for repeated requests that exceed reasonable limits, as appropriate. We may refuse unwarranted 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 in 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

We use data centers and service providers in many parts of the world, including the United States of America, Germany and Hong Kong SAR. The data protection laws of the data centers may differ from those of the users’ country of residence. We are taking reasonable measures to ensure that all personal information is adequately protected.

EU/EEA users: If your data is transferred outside the EU/EEA region, we will implement appropriate measures before and throughout the transfer. These measures include conducting transfer impact assessments and ensuring that the recipient entity is contractually bound to uphold data protection standards similar to or equivalent to those in the EU/EEA.

If you have any questions or would like to learn more details about our data transfer practice, please contact us at dpocontact@insta360.com.

6. Children's Data

We define "children" as individuals (i) under the age of 16 residing in the EU/EEA, (ii) anyone under 13 residing in all other regions, or (iii) individuals who qualify as "children" under the applicable data protection laws of their respective jurisdiction. We do not knowingly collect personal information from children. Children may not register for an account on our Platform or send us personal information such as their names, addresses, phone numbers, email addresses, etc., unless permitted by local law and their guardians have given their consent. We will only use or publicly disclose personal information collected from children with the consent of their guardians as permitted by law, with the consent of the guardian, or as necessary to protect the child. We do not sell or share children’s data under the definition of the California Consumer Privacy Act (CCPA) and its regulations.

If we become aware that we have collected personal information from a child without the consent of the child'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 child, please contact us.

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 (https://www.insta360.com/support/supportcourse?post_id=20779) 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, you can reach us via the following means:

For specific issues related to the software or the user's personal account (including access to one's own personal information), please e-mail us at dpocontact@insta360.com. For general inquiries or complaints about privacy issues, please e-mail us at dpocontact@insta360.com or write to us:

For US users:

ARASHI VISION (U.S.) LLC, 2323 Main St, Unit 16, Irvine, CA 92614

For EU users:

Insta360 GmbH, Gartenfelder Straße 29-37 Gebäude 31, 13599 Berlin, Germany

For all other users:

Arashi Vision Inc., 25th Floor, Building 1, Jinlitong Financial Center, 1100 Xingye Road, Haiwang Community, Xin'an Street, Bao'an District, Shenzhen, Guangdong, China

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.