[V2.1]

Published date: June 5th, 2026

Effective date: June 5th, 2026

This Privacy Policy specially addresses how PixelSpace collects, uses, disclose, transmit and stores (collectively, "processes") your personal data through Insta360 App, Insta360’s Official Store and Insta360 Studio, when providing storage, synchronization, management, editing and sharing services (hereinafter referred to as "Cloud Service" or “Services”) for your camera videos and photos (collectively, "material data").

Insta360+(US) service refers to cloud service for US users (hereinafter referred to as “you”), which is operated by PixelSpace Technology Pte Ltd (hereinafter referred to as "PixelSpace", "we", "us" or“our”) so as to improve the efficiency and reliability of cloud service to the US users and comply with US laws and regulations.

PixelSpace is a service provider for cloud service to users in the United States. PixelSpace allows you to use certain Internet services in accordance with the Insta360+(US) User Service Agreement, including storaging your videos and photos, and make it accessible on your compatible devices and computers, as well as to edit and share your stored videos and photos. Arashi Vision Inc. and its affiliates (hereinafter referred to as "Insta360") may from time to time provide support to PixelSpace with respect to the cloud services. If you have any questions about this Policy, you can send to email to service@pixelspace-tech.com or DPO@pixelspace-tech.com for your enquiry.

BEFORE USING Insta360+(US), PLEASE CAREFULLY READ AND THOROUGHLY UNDERSTAND THIS POLICY, AND MAKE CHOICES YOU DEEM APPROPRIATE. WE WILL ADHERE TO CURRENT LAWS AND REGULATIONS, PROCESS YOUR PERSONAL INFORMATION APPROPRIATELY, BASED ON LEGAL AND LEGITIMATE MEANS, AND IN ACCORDANCE WITH THE PRINCIPLES OF GOOD FAITH. TERMS IN THE POLICY THAT SIGNIFICANTLY RELATE TO YOUR RIGHTS ARE HIGHLIGHTED IN BOLD FOR YOUR ATTENTION.

IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES.

This Policy is exclusive for cloud service in the US. In cases where there are specific agreements that differ from the Insta360 Privacy Policy or Insta360+ Privacy Policy, this Policy shall prevail. Additionally, we recommend careful review of the Insta360+(US) User Service Agreement, especially in cases where this Policy does not make specific provisions.

This Policy contains:

1. Scope of Application and Basis for Personal Information Processing

2. How We Collect and Use Your Personal Information

3. How We Use Cookies and Similar Technologies

4. How We Share, Transfer, and Disclose Your Personal Information

*Additional Note for California Residents

5. How We Store and Protect Your Personal Information

6. Safeguarding Your Personal Information

7. Your Rights

8. Protection of Children's Personal Information

9. Notifications and Revisions

10. How to Contact Us

1. Scope of Application and Basis for Personal Information Processing

1.1 Scope

This Policy applies to Insta360+ cloud service in the US which is operated by PixelSpace. It is applicable when you use Insta360+(US), or access Insta360+(US) through Insta360 App, Insta360’s Official Store, Insta360 Studio.

Please be aware that this Policy is only applicable to the personal information we process and does not extend to personal information handled by third-party products and/or services accessed through Insta360+(US), including any third-party websites, apps, mini-programs, etc.

1.2 Legal Basis for Personal Information Processing

We only process your personal information when deemed necessary, and under applicable law, we do so with a valid legal basis. This may include your explicit consent, compliance with the law, the necessity to provide Services or fulfill our contractual obligations, protect your rights, or pursue our legitimate business interests. We may process your personal information based on the following legal grounds:

a) Consent: Before we process your personal information, you will be informed in an unambiguous way. Without obtaining your consent to the use of your personal information for specific purpose, we will not process your personal information.

b) Business Purpose: The processing of your personal information is necessary for a business purpose that we have disclose to you at the time of collection. Such business purposes include but not limited to fulfilling the terms of service agreement, improving your service experience.

c) Legal Obligations: To comply with applicable laws, government requests, judicial procedures, court orders, or legal processes, such as responding to court orders or subpoenas (including responding to public authorities to meet national security or law enforcement requirements), we may process your personal information as required by law.

d) Scientific, Historical, or Statistical Research: To the extent permitted by applicable laws and regulations, the processing of your personal information is for public or peer-reviewed scientific, historical, or statistical research in the public interest.

e) Necessity for Debugging or identifying and repairing errors: The processing of your personal information is executed in order to identify and repair errors that impair existing intended functionality

f) Legitimate Interests: Within the permissible scope of applicable laws, to achieve our legitimate business interests or to exercise or defend legal claims, we may process your data under reasonable and necessary circumstances.

g) Other Legal Bases Permitted by applicable laws and regulations.

2. How We Collect and Use Your Personal Information

2.1 The categories of Information we collect

a) Contact information, such as your email address.

b) Account information and subscription information, such as your Insta360+(US) account user ID, login IP address, account location, the Regional Data center, current membership plan and validity, order information (including membership type, duration, purchase date, order amount, payment channel, order number), and auto-renewal order information (including status, renewal amount, renewal date, and payment channel).

c) Cloud space usage information, such as your user ID, total storage size of Cloud Space, used and remaining space size, and material data ID, storage path on Insta360+ cloud space, type, name, shooting time, status, size, width, and height.

d) Metadata of uploaded photos and videos, such as EXIF data, camera type, camera serial number, and the storage path of video/photo data inside the camera.

e) Device information, such as device model, operating system, unique device identifiers, IP address, MAC address, browser language,  the state or country from which you accessed the Services, operating system, Internet connection type and service provider, Wi-Fi network, and software and hardware attributes (including device IDs, operating system, and browser type).

f) Cloud sharing data(if cloud sharing service enabled): such as user ID, share expiration time, set permissions, and shared material data name, size, order, and status.

g) Editing data (if editing service enabled), such as your editing records and editing time.

h)Customer service interaction information, such as your text messages, questions, feedback and the photos or videos sent to our customer service.

i) Information collected through automated technologies(e.g. cookies or similar technologies) about your devices and use of the services.

j) Other personal information we collect from you based on your advance explicit consent.

2.2 How We Use Your Personal Information

a) Register Insta360+(US) account, Select account location and Subscribing to Insta360+(US) service: Before you subscribe to Insta360+(US) service, you need to first register an Insta360+(US) account and login, which can be accomplished by shared login with your previous Insta360 account, where PixelSpace may collect [your account information (user ID, login IP address, account location) from your previous Insta360 account]. After registration, if your Insta360+(US) account is located in the United States and is in normal status, you can view the membership service content of Insta360+(US), choose a subscription plan, confirm your account location on the first subscription(used to determine the Regional Data Center where your data will be stored) and confirm and complete payment to purchase the corresponding package. Upon subscribing or purchasing this Services, we collect and use your [account information (user ID, login IP address, account location, the Regional Data center), current membership plan and validity, order information (membership type, duration, purchase date, order amount, payment channel, order number), and auto-renewal information (status, renewal amount, renewal date, and payment channel)]. If you refuse to provide the aforementioned information, you will be unable to use the Insta360+(US) service.

b) Upload and Download Services: After subscribing or purchasing Insta360+(US), you can add your device to your Insta360+(US) through the Insta360 App in order to upload material data such as photos and videos directly from your device. You can also choose to download stored files from Insta360+(US) and configure the network conditions for uploads and downloads. For this, we collect your [metadata of the uploaded videos or photos such as EXIF data, camera device information including device type, device serial number, and the storage path of video/photo file inside the camera)]. Uploading and downloading is a basic function of Insta360+(US), if you do not provide the above data, we will not be able to provide you with the Insta360+(US) Service.

c) Auto Backup Service: You can set the camera to automatically upload photos, videos, and other material data to Insta360+(US) during your device is simultaneously in idle, connected to Wi-Fi, and charging status to backup data. You can choose whether to enable the automatic upload service yourself.

d) Cloud Space Management and Material Data Editing Services: After backing up material data to Insta360+(US), you can manage your Cloud Space and the material data within it using the Insta360 App and Insta360 Studio. Specific operations include:

i. Viewing and Checking Insta360+(US) Usage Details: To perform these actions, we need to collect and use your [user ID, total storage size of Cloud Space, used and remaining space size, and material data ID, storage path on Insta360+ cloud space, type, name, shooting time, status, size, width, and height]. If you refuse to provide the aforementioned information, you will be unable to use Insta360+(US).

ii. Downloading: If you want to download material data from Insta360+(US) to the system's local albums, we need to get access to your system albums,so that the material data could be directly downloaded to the system album. If you refuse to provide the aforementioned information, you will be unable to use the foregoing functions of Insta360+(US), but it will not affect your normal use of other functions of Insta360+(US).

iii. Synchronization of Editorial Data Across Multiple Sites: For this, we will upload your editorial data to the cloud so that you can view the video with editing effects when you log in to your accounts to view the footage on different devices. You can upload locally recorded videos with background music, and the Insta360 App will extract the background music from the video for further editing of related material data in Insta360+(US). For this, we need to access your [local albums and folders containing videos to extract the background music from the videos]. If you refuse to provide the aforementioned information, you will be unable to use the foregoing functions of Insta360+(US), but it will not affect your normal use of other functions of Insta360+(US).

iv. If you have enabled the Moments feature, we will leverage AI algorithms to analyze your [content (including videos and images) within Insta360+ Cloud Storage and associated metadata (e.g., capture time/location/device model)]. This analysis enables theme recognition, smart clip selection, scene segmentation editing, and automated title/cover generation to create your unique video memories.We will notify you through the phone number or email you provided in your Insta360 account so that you can be informed of service progress and results in a timely manner.For detailed descriptions of the Moments functionality, refer to the Insta360+ Moments Service Statement.

e) Cloud Sharing of Material Data: You can externally share the material data stored in Insta360+(US) through links and set corresponding permissions during sharing, including whether to allow individuals with the link to download, the validity period of the shared link, and whether to share editing data. You can view the information links you have shared or cancel the sharing in the Insta360 App. To enable cloud sharing of material data, we need to collect and use your [user ID, share expiration time, set permissions, and shared material data name, size, order, and status]. If you refuse to provide the aforementioned information, you will be unable to use the sharing service of Insta360+(US).

Upon receiving a shared link, material data recipients can view and download the material data through a web-page, Insta360 App or Insta360 Studio. If you wish to open the shared link from other users directly in the Insta360 App or Insta360 Studio, you need to grant PixelSpace permission to access the clipboard. Clipboard permissions are only used to recognize shared links from insta360+(US) and will not be used for other analysis. However, PixelSpace is not responsible for any subsequent actions taken by material data recipients regarding the shared material data.

Additionally, with the aim of preventing the dissemination of illegal content, if PixelSpace receives complaint of illegality or infringement on your shared content, PixelSpace may temporarily disable the access to the shared content and conduct content moderation(including manual moderation) on material data shared by you upon prior notice to you and without violating your privacy. Please understand and agree that during the manual moderation, our staff will check the material data you share and we will do our best to protect your privacy and security. In regard of the complain channel and the relevant rules of content safety inspections, please refer to Insta360+(US) User Service Agreement.

You understand and commit to obtaining authorization from others if the shared material data involves their privacy or intellectual property rights before sharing it with material data recipients.

f) Subscription Expiry Notification: Upon the expiration of your subscribed Insta360+(US) subscription, we will retain your material data for a period of 60 days (retention period). If you choose not to continue the subscription, all your stored material data in Insta360+(US) will be deleted upon the expiration of the retention period.When your subscription expires or the material data retention period ends, we will notify you through the Insta360 App and the phone number or email you provided for the subscription of Insta360+(US).

g) Ensuring Service Security, Optimization, and Improvement: When you use Insta360+(US), we collect and use your User ID, user order information, user transaction information, transaction currency, cloud space usage details, subscription duration, subscription status, subscription region, and the location of storage chosen by you on your first subscription. This data is utilized for internal purposes only, such as ensuring the normal use of Insta360+(US) services, addressing issues encountered during service usage, improving and optimizing the Insta360+(US) service experience, securing your account, preventing, detecting, and investigating fraud, actions harmful to security, illegal activities, or violations of our agreements, policies, or rules. It aims to protect your, our, or our affiliated companies', partners', and the public's legitimate rights and interests. This data will not be disclosed externally.

h) Sending Marketing and Promotional Information: We do not serve third-party advertisements to you while using our Services. However, we may process your personal information, such as email addresses, as well as other data obtained from your interactions with our Services, to send marketing information to you via email. Before sending such marketing information, we will seek your explicit consent. You can unsubscribe at any time by clicking the unsubscribe link in the email and choosing not to receive our marketing information. Please note that if you choose not to receive marketing information, we may still contact you regarding your use of our Services, including but not limited to responding to your questions or requests.

i) Please be aware that, according to relevant laws and regulations, anonymized data is not considered personal information, and we do not need your consent for processing such data. In cases involving the training and application of generative artificial intelligence large models, we adhere to transparency requirements by publicly disclosing relevant information.

2.3 Notice Regarding Sensitive Personal Information

When you use our Services, the material data you upload to the cloud space may involve sensitive personal information, including but not limited to facial information. WE DO NOT DIRECTLY PROCESS THE MATERIAL DATA YOU UPLOAD. THROUGH TECHNOLOGICAL MEANS, WE ENSURE THE SECURITY OF THE MATERIAL DATA UPLOADED TO THE CLOUD SPACE. PLEASE EXERCISE CAUTION WHEN UPLOADING CONTENT CONTAINING SENSITIVE PERSONAL INFORMATION, WHETHER PERTAINING TO YOURSELF OR OTHERS.

2.4 Device Permission Instructions

When using our Services, we may need to request the following device permissions related to personal information on the device you are using:

a) Confirm where your data is stored: When you first purchase Insta360+(US), you will need to specify where your data is stored. If you do not specify your data storage location, you will not be able to complete your purchase.

b) Camera Auto-Start Related Permission: When you use the auto backup service in Insta360+(US), we require your authorization for the camera device's Auto-Start Related Permission. This enables Insta360+(US) to provide you with more timely automatic backup services. Once this permission is granted, Insta360+(US) will operate in the background, adhering to your chosen settings for automatic backup conditions, network preferences, and data types. It ensures that the service runs at reasonable intervals, delivering timely and effective auto backup service. Failure to enable this permission will result in the inability to use the more immediate online auto backup service. However, this does not affect your ability to use other functionalities and services in Insta360+(US).

c) Local Album Permission: When you utilize Insta360+(US) for adding background music to your material or download clip data to your phone's local album, we require your authorization by granting "access Permission" for the local album. This allows us to upload videos/photos from your local album or folder to serve as stickers for material data editing. It also enables the extraction of background music from videos in your local album for use as background music in material data. Failure to enable the mentioned permission will result in the inability to use services related to perspective editing and adding background music. However, it will not impact your normal use of other functionalities and services in Insta360+(US).

d) Clipboard Read/Write Permission: When you act as the sharer of material data or receive shared material data from Insta360+(US) users, we request your permission to access the clipboard, specifically the "Read/Write Permission." This allows Insta360+(US) to write file-sharing links to your clipboard. When you copy an Insta360+(US) sharing link and open it in the Insta360 App, the app reads the sharing password from your clipboard, enabling you to view the shared content. We read the clipboard and don't analyze it for anything else. Failure to enable the mentioned permission will result in the inability to use material data sharing services. However, this will not impact your normal use of other functionalities and services in Insta360+(US).

If you wish to revoke any previously granted device permissions, you can adjust the settings on your device. Please note that enabling any permission signifies your authorization for us to process related personal information to provide the corresponding Services. Revoking a permission means canceling your authorization, and we will no longer process related personal information or provide Services associated with that permission. However, your decision to revoke permissions will not affect the processing of personal information based on your previous authorization.

3. How We Use Cookies and Similar Technologies

Cookies and similar technologies, such as beacons and pixels (hereinafter referred to as “these technologies”), are widely used in the internet industry. In our services, we may collect information about your device model, operating system, unique device identifiers, login IP address through these technologies. We use these technologies to ensure the security and efficient operation of our Services. We may set authentication and security-related Cookies or anonymous identifiers to confirm your secure login to the service or to detect issues like theft, fraud, and other unlawful activities. These technologies also help us improve service efficiency, enhance login and response speeds. Additionally, they can simplify your repeated login steps, eliminating the need to enter your username and password each time, and assist in determining your login status, as well as the security of your account or data. We commit to not using Cookies for any purposes other than those described in this Policy.

4. How We Share, Transfer, and Disclose Your Personal Information

We fully understand the legal responsibilities we must bear in the event of illegal sharing, transfer, or disclosure of personal information causing harm to users. We are committed to maintaining confidentiality obligations for your personal information. Any sharing, transfer, or disclosure of your personal information will be strictly conducted in accordance with the following terms:

4.1 Sharing

In the following circumstances, we may share your personal information:

a) With Service Providers: We may share your personal information with service providers to monitor and analyze the usage of our Services and to communicate with you.

b) With Business Partners: We may share your personal information with our business partners to provide you with certain products, services, or promotional activities.

c) With Government Agencies: We may provide personal information to government authorities as required by public authorities, auditors, or agencies authorized to inspect us, in accordance with their legal obligations, which may request information.

d) With Your Consent: With your consent, we may disclose your personal information for any other purpose.

If there is any sharing activity, we will obtain your individual consent in accordance with the provisions of laws and regulations. We will also require affiliated companies, partners, and third parties to provide evidence of data security capabilities and information security qualifications. In the processing of sensitive personal information, we will request third parties to adopt technologies such as de-identification and encryption to better protect the security of personal information. If you have objections to the third-party processing of personal information or identify risks in their personal information processing activities, please contact us using the contact information provided in this Policy.

4.2 Disclosure

We will only disclose your personal information publicly in the following circumstances:

a) After obtaining your explicit consent.

b) Based on legal requirements: In cases where mandatory legal regulations or government and judicial authorities require it, we may publicly disclose your personal information. When we receive requests for the disclosure of personal information, we will require the requesting party to provide corresponding legal documents, such as subpoenas or investigation letters. We firmly believe that, for requests for the disclosure of personal information, transparency should be maintained to the fullest extent possible within the limits allowed by laws and regulations. We will carefully review all requests to ensure that the disclosure of personal information has a legal basis.

c) For the normal management and maintenance of Insta360+(US) order, we may announce penalties for accounts engaging in violations, fraud, or other severe activities that harm the legitimate rights and interests of PixelSpace, Insta360 and other users. The announcement will mainly include user account information and details of the violation.

4.3 Transfer

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

a) With your consent, we may transfer your personal information to other parties.

b) Transfer is required by applicable laws and regulations or mandatory requests from government departments and judicial authorities.

c) In the event of a merger, acquisition, or bankruptcy liquidation that involves the transfer of personal information, we will require the new entity holding your personal information to continue to be bound by this Policy. Otherwise, we will request the new entity to obtain your consent again.

4.4 Exceptions to Obtaining Prior Consent for Sharing, Transfer, and Public Disclosure of Personal Information

In accordance with legal regulations, there are situations where the sharing, transfer, and public disclosure of personal information do not require prior consent from users:

a) Related to our fulfillment of obligations stipulated by laws and regulations.

b) Directly related to national security and defense security.

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

d) Directly related to criminal investigations, prosecutions, trials, and judgment executions.

e) Necessary for the protection of your or other individuals' vital legitimate interests but difficult to obtain your personal consent.

f) Personal information voluntarily disclosed by you to the public.

g) Collection of personal information from legally publicized information sources, such as lawful news reports and government information disclosures.

h) According to legal regulations, sharing, transferring, or publicly disclosing de-identified personal information, ensuring that it cannot be restored and re-identified as a specific natural person. Such actions do not constitute the sharing, transfer, and public disclosure of personal information, and no separate notification or consent from users is required for the processing of such data.

*Additional Note for California Residents

If you are California residents, we are required to disclose whether your collected personal information has been shared with or sold to any third parties for Advertising/Analytics Purposes under the California Consumer Privacy Act (CCPA) and The California Privacy Rights Act of 2020 (CPRA).

Under CCPA, sharing is defined as renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer's personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

While selling is defined as any arrangement involving the exchange of value between the business and a third party or another company for consumers' personal information. The definition of sharing was expanded by the CPRA, which further clarifies that sharing for targeted advertising purposes is included.

The following chart provides a detailed overview for the sharing or sale of your personal information in the past twelve months:

We do not “sell” or “share” the personal information of known minors under 16 years of age.

We do not use or disclose sensitive personal information for purposes other than those specified in Section 7027(m) of the CCPA regulations.

You have the right to limit our use of your personal information, to opt-out of our share/sale of your personal information for purposes of online analytics and advertising, or to request or execute your other rights under CCPA by simply emailing us at DPO@pixelspace-tech.com with your registered email address.

5. How We Store and Protect Your Personal

Information

5.1 Storage Duration

We only store your personal information for the necessary period as described in this Policy and within the time limits specified by laws, regulations, and regulatory authorities, unless there is a mandatory retention requirement under the law. If we terminate our Services or operations, we will promptly cease the continued collection of your personal information, comply with relevant legal requirements to notify you in advance, and, upon termination of Services or operations, either delete or anonymize your personal information, except as otherwise required by laws, regulations, or regulatory authorities.

5.2 Storage Location

Your material data will be stored and stay safely in AWS Virginia, USA. We will not transfer your material data to any other countries or regions outside USA.

5.3 Storage Security

We have implemented security measures that comply with industry standards to protect your information and prevent unauthorized access, disclosure, use, modification, damage, or loss of personal information. The following measures are taken to ensure the security of your data:

a) We use encryption technology to enhance the security of personal information. Data exchanged between your browser and our servers is encrypted using the TSL protocol, providing a secure browsing experience through the HTTPS protocol.

b) Trusted protection mechanisms are employed to prevent personal information from falling victim to malicious attacks.

c) Access control mechanisms are deployed to ensure that only authorized personnel can access personal information, thus enhancing overall data security.

d) We conduct training courses on security and privacy protection to strengthen employees' understanding of the importance of safeguarding personal information.

e) We have established dedicated data compliance management systems, processes, and organizational structures to ensure information security. For example, access to information is strictly restricted, and individuals are required to adhere to confidentiality obligations. Regular audits are conducted to verify compliance.

We will take all reasonable and feasible measures to ensure that irrelevant personal information is not collected. We only retain your personal information for the shortest period necessary to achieve the purposes described in this Policy, unless otherwise required by local laws and regulations.

The internet environment is not entirely secure. We will make every effort to ensure or guarantee the security of any information you send to us. In the event that our physical, technical, or managerial protective measures are compromised, leading to unauthorized access, public disclosure, alteration, or destruction of information, resulting in harm to your legitimate rights and interests, we will bear corresponding legal responsibilities. In the unfortunate occurrence of a personal information security incident, we will strictly adhere to the requirements of the local laws and regulations in your jurisdiction. We will promptly inform you of the basic details and potential impacts of the security incident, the measures we have taken or will take to address it, suggestions for you to autonomously prevent and mitigate risks, and remedial measures available to you. We will notify you of event-related information via email, letters, phone calls, push notifications, or other effective means. In cases where it is difficult to inform individual data subjects one by one, we will adopt reasonable and effective methods to make public announcements. Additionally, we will proactively report to regulatory authorities the handling of personal information security incidents and fulfill other obligations stipulated by applicable laws and regulations.

6. Safeguarding Your Personal Information

We place great importance on the security of personal information and take all reasonable and feasible measures to protect your personal information:

a) We employ security measures in line with industry standards, including the establishment of reasonable regulations and secure technologies to prevent unauthorized access, use, modification, and to avoid data damage or loss of your personal information.

b) In the event that we cease the operation of Insta360+(US) we will promptly cease the processing of your personal information, notify you of the cessation in an individual or public manner, and delete or anonymize the personal information we hold.

c) We employ physical, technical, and managerial security measures to reduce the risks of personal information loss, misuse, unauthorized access, disclosure, and alteration. This includes but is not limited to data encryption during transmission, firewall and encrypted storage, physical access controls, and data access authorization controls.

d) We conduct regular training on personal information protection to enhance employees' awareness of the importance of protecting personal information.

e) We have developed relevant emergency plans for personal information security incidents, regularly organize internal personnel for emergency response training and drills to ensure that they understand their responsibilities and emergency response strategies and procedures.

f) The internet environment is not completely secure, and while we strive to ensure the security of the personal information we process, we will promptly inform you in accordance with legal requirements in the event of a personal information security incident. This includes informing you of the basic details and potential impacts of the incident, the measures we have taken or will take, suggestions for your autonomous risk prevention and mitigation, and available remedial measures. We will notify you of incident-related information through push notifications, emails, messages, calls, etc. If it is difficult to inform users individually, we will use reasonable and effective methods to make public announcements. Additionally, we will proactively report to regulatory authorities on the handling of personal information security incidents. If your legitimate rights and interests are compromised, we will bear corresponding legal responsibilities.

g) The internet is not an absolutely secure environment, and we strongly recommend that you use secure methods and complex passwords to assist us in ensuring the security of your account. If you discover a leakage of your personal information, especially if your account or password has been compromised, please contact us immediately using the contact information provided in this Policy so that we can take appropriate measures. However, we are not responsible for this until we become aware of the situation and take action within a reasonable time.

7. Your Rights

In accordance with relevant laws, regulations, standards, and prevailing practices in other countries and regions, we ensure your rights to exercise the following rights over your personal information. Please note that if the requested personal information has already exceeded the necessary minimum retention period for achieving the purposes stated in this Policy or has been deleted, we may be unable to respond to your requests regarding personal information rights.

The personal information rights you can exercise include:

7.1 Right to be Informed

You have the right to be informed about how your personal information is processed.

7.2 Right to Access

You have the right, in accordance with relevant laws and regulations, to access your personal information. If you wish to access and edit personal information in your account, you can log in to your account on our website or app and navigate to the relevant pages, such as personal profile, password change, or email change.

7.3 Right to Rectify

If you discover inaccuracies in how we process your personal information, you have the right to request corrections.

7.4 Right to Erasure

You can request the erasure of personal information in the following situations, except as otherwise provided by laws and regulations:

a) The purpose of collecting or otherwise processing personal information no longer requires your information.

b) Our processing is based on your consent, and you withdraw your consent.

c) You object to our processing, and there are no overriding legitimate grounds for processing (including but not limited to completing transactions with you, fulfilling contracts with you, preventing security incidents, fraud, malicious or illegal activities).

d) We unlawfully processed your personal information.

e) Applicable laws require erasure. The right to request erasure of personal information does not apply in the following cases: where laws and regulations provide otherwise; processing is necessary for the exercise of the right to freedom of speech and information; processing is necessary for compliance with a legal obligation; processing is necessary for archiving purposes in the public interest, scientific research, historical research, or statistical purposes, and erasure is likely to render impossible or seriously impair the achievement of such processing objectives; or processing is necessary for the establishment, exercise, or defense of legal claims.

If we decide to respond to your erasure request, we will also notify entities that have obtained your personal information from us (if any) to promptly erase it unless otherwise required by laws and regulations or these entities have obtained your separate authorization. When you erase information from our Services, we may not immediately erase the corresponding information from the backup system but will do so when the backup is updated.

7.5 Right to Account Deletion

You can deactivate a previously registered account by contacting our customer service as stated in Section 11.1 in this Policy. When you contact our customer service for account deactivation, we will fulfill your request within 15 working days. After deactivating the account, we will cease to provide our Services to you and, as per your request, delete your personal information, except as otherwise provided by laws and regulations.

7.6 Right to Data Portability

You have the right to obtain a copy of your personal information. You can contact us at any time, and we will respond to your request within 30 days. If technically feasible, such as through data interface matching, we can also directly transmit a copy of your personal information to a third party specified by you.

It is important to note that the right to data portability may be restricted when our processing of your personal information is necessary for public interests or for the exercise of official authority vested in us. Additionally, exercising the right to data portability should not adversely affect the rights or freedoms of others.

7.7 Restrictions on Automated Decision-Making for Information Systems:

In certain business functions, we may make decisions solely based on non-human automatic decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legal rights, you have the right to request an explanation from us, and we will also provide appropriate remedies.

7.8 Limited Processing Right for Personal Information

You can restrict our processing of your personal information in the following circumstances:

a) You question the accuracy of the personal information we collect from you, or we are verifying the accuracy of the personal information.

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

c) We no longer need your relevant personal information for the processing purposes stated in this Policy, but you need the personal information for legal claims.

d) The legal basis for processing your personal information is for public interest, or our legitimate interests, or those of third parties.

7.9 Right to Object to Personal Information Processing

In the following situations, you have the right to object to our processing of your personal information:

a) You withdraw your consent.

b) The processing of personal information is necessary for the performance of a task carried out in the public interest. However, this does not apply if we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

c) The processing of personal information is necessary for the pursuit of legitimate interests.

d) Personal information is processed for direct marketing purposes. You have the right to object to such processing at any time, and once you exercise this right, personal information must not be processed for such purposes.

e) The processing of personal information is for scientific or historical research or statistical purposes. This does not apply if the processing is necessary for the performance of a task carried out for reasons of public interest.

f) Solely relies on automated processing (including user profiling) to make decisions that produce legal effects or similarly significantly affect data subjects.

7.10Right to Opt-Out

You have the right to opt-out of the processing of personal information for the following purposes: 1. Targeted advertising; 2. Sale of personal information; 3. User profile decisions that have significant legal or similar effects on consumers.

7.11Response to the Above Requests

If you are unable to exercise the rights mentioned above, or if you believe that we have violated any provisions of laws, regulations, or agreements regarding the processing of your personal information, you can contact us through the channels specified in this Policy. For security reasons, you may need to provide a written request or other proof of your identity. In general, we may request you to verify your identity first and will respond appropriately within 【30 days】 in accordance with applicable laws. We will retain your requests and our responses (including any supporting documents) as required by applicable laws.

For your reasonable requests, we generally do not charge any fees. However, for repeated or excessive requests beyond reasonable limits, we may charge certain costs. We may refuse requests that are unfounded, repetitive, require excessive technical means (such as developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are impractical (involving information stored on backup tapes).

In the following situations, we may be unable to respond to your requests according to laws and regulations:

a) Directly related to national security or national defense.

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

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

d) There is sufficient evidence to prove your subjective malice or abuse of rights.

e) Responding to your request would cause serious harm to your or other individuals' legitimate rights and interests.

f) Involving trade secrets.

If we respond to your erasure request, we will also notify entities that have obtained your personal information from us to promptly delete the corresponding information unless otherwise provided by laws and regulations or unless these entities have obtained your independent authorization.

Within 45 days of receiving your personal information request, we will respond. Considering the quantity and complexity of your requests, if necessary, we will explain any extensions and reasons for the extension within the initial 45 days, with the response period extended by an additional 45 days.

If we refuse to take action on your personal information request, we will provide reasons for the refusal and avenues for appeal within 45 days of receiving the request. Within 60 days of receiving the appeal, we will respond in writing, explaining the decision and providing reasons. If the appeal is denied, we will provide an online mechanism (if available) or other means for you to contact the Attorney General to file a complaint.

8. Protection of Children's Personal Information

PixelSpace understands the importance of safeguarding the personal data of chidren which we consider to be an individual under the age of 17 or the equivalent age as specified by law in your jurisdiction..We will not knowingly collect children’s personal information. Children are not allowed to register accounts on our platform or provide personal information such as names, addresses, phone numbers, or email addresses to us. If we discover that we have collected personal information from a child without obtaining the consent of their legal guardians, we will promptly delete the relevant data once informed. If you believe that we may be in possession of personal information from or about a child inappropriately, please contact us.

9. Notifications and Revisions

In order to provide you with better services and to keep pace with the development of our business, this Policy may be updated. However, without your consent, we will not diminish the rights you are entitled to under this Policy. We will publish updated versions on our website and mobile platforms, and notify you of the relevant updates through appropriate means before they take effect. Please visit our platform to stay informed about the latest privacy policy.

For significant changes, we will provide more prominent notifications (such as pop-ups and pushes through the Insta360 App) to explain the specific changes to the privacy policy.

Significant changes referred to in this Policy include, but are not limited to:

a) Significant changes in our Services model, such as the purposes of processing personal information, types of personal information processed, and the ways personal information is used.

b) Significant changes in ownership structure, organizational structure, etc., resulting from business adjustments, bankruptcy, mergers, or other events causing changes in ownership.

c) Major changes in the main entities with whom personal information is shared, transferred, or publicly disclosed.

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

e) Changes in the department responsible for the security of personal information, contact methods, and complaint channels.

f) When the personal information security impact assessment report indicates a high risk. We will also archive previous versions of this Policy for your reference.

10. How to Contact Us

If you have any questions, feedback, or complaints regarding this Policy, or if you wish to contact us, please use the following methods:

10.1 For specific issues related to software or personal user accounts (including obtaining your personal information), please email our customer service at service@pixelspace-tech.com.

10.2 For general inquiries or complaints about privacy issues, please email us at DPO@pixelspace-tech.com.

If you are dissatisfied with our response, especially if our handling of personal information has harmed your legitimate rights, you can also file a complaint or report to the regulatory authorities in your jurisdiction.