Kami Vision Privacy Policy

Last Updated: November 15, 2021

Kami Vision is concerned about privacy issues and wants you to be familiar with how we collect, use, and disclose information. This Privacy Policy explains how Kami Vision and its subsidiaries and other group companies (collectively, “Kami Vision,” “we,” “our,” or “us”) collect, store, use, disclose or otherwise process information about you in the course of our business, including personal information (i.e., information that directly or indirectly personally identifies you, such as your name, email address, or billing information) or a combination of data that can be reasonably used to infer information about you (such as your mobile phone number or IMEI number).

This Privacy Policy applies to all such information that we collect, store, use or otherwise process during the course of our business, including through our websites that link to this Notice (such as www.kamivision.com) (the “Sites”), our SaaS-based Vision AI products and services (the “Products”), and through other means, such as our and our partner’s events, sales, and marketing activities. It also describes your privacy rights.

ABOUT OUR PRODUCTS. We provide our Products to our customers under an agreement with them and solely for their benefit and the benefit of their personnel and other personnel authorized by them as users of the Products (“Authorized Users”). Our customers can efficiently store and analyze all their data in the Products. Because the Products are SaaS-based, Authorized Users may access and use the Products from all over the world, subject to Kami Vision’s agreement with customers and any applicable laws.

This document also includes information related to the operation of the following Products: the Kami Action Camera, Kami Dash Camera, Kami Home Cameras, and Kami Outdoor Cameras, (collectively, “Kami Cameras”). In this Privacy Policy, the expression “Products” also includes our Mobile App, PC App, and Kami Cloud as defined in our Terms of Use .

This Privacy Notice should be read in conjunction with the Terms of Use of which it forms a part, and which also apply when you visit our website or use Products. By submitting information to us through or in connection with the Sites or by purchasing or using Products, you agree to the terms and conditions of this Privacy Policy.

How We Collect Data

We will collect and store your personal data when you interact with our Sites, when you contact us, request our Products, or when you use our Products, as further detailed below. We collect personal information in writing, by telephone, by email, and via Internet or web transmission.

Information Security

Kami Vision uses reasonable and appropriate organizational, technical, administrative and physical measures to protect the integrity and security of your information. These measures may vary based on the sensitivity of your information. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to access it and they will only process your personal data on our instructions and are subject to a duty of confidentiality.

What Personal Information does Kami Vision collect?

• Identity data – includes first name, last name, date of birth.

• Contact data – includes billing address, email address, and telephone numbers.

• Technical data – includes information about your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

If you are a customer of Kami Vision, personal data that we hold about you may include the same information listed above, along with:

• Business data – your function/job title within the company and your work email address, company’s name, postal address, VAT and/or company number.

• Financial and transaction data – including bank account and payment card details as well as details about payments to and from you and other details of services you have purchased from us.

• Marketing and communications data – where you have opted-in via your user preferences in your account settings, we hold details about your preferences for receiving marketing from Kami Vision and our third parties, your communication preference, your language and your social network accounts.

Specific Products collect specific additional data as further detailed below.

Neither the Sites nor the Products are directed to individuals under the age of thirteen (13), and we request that these individuals do not provide us with personal information. Only individuals aged 18 and older are permitted to have Kami Vision Accounts.

Retention of Personal Data

Your personal data will be retained only for as long as it is reasonably necessary to carry out the purposes set out in this Privacy Policy (unless longer retention is required by applicable law), including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve these purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, for tax purposes, we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers.

In some cases, you can ask us to delete your data, as discussed below. Once you have asked us to delete your account, we will delete all information that we are not required or permitted to retain by law.

We may keep an anonymized form of your personal data (so that it can no longer be associated with you) for research or statistical purposes without time limits, in which case we may use this information indefinitely without further notice to you.

What information do the Kami Cameras collect?

The Kami Cameras collect:

• Setup information you provide

Information input during setup: When you set up a Kami Camera, you will be asked for certain basic information like your email address, your Facebook username, and your general location (e.g., city or country).

• Snapshots, Video Clips, and Other video and audio signals and data

When you use the recording feature of your Kami Camera or the snap shots and/or recordings are stored on your camera and are not stored on a Kami Vision server without your intervention, such as through you purchasing a subscription to Kami Cloud.

• “Facial Detection”, “Human Detection”, “People Tracking”, “Pose Identification”, “Footfall Measurement”, and “Baby Monitoring”:

If you choose to use the facial detection, human detection, baby monitoring, people tracking, pose identification, or footfall measurement features on your Kami Camera, we will process facial and/or human body images and underlying face and body prints for the purpose of enabling your device to recognize familiar faces and people and to notify you of familiar and unknown people. Using the Products and your account, you control whether this biometric processing occurs. Depending on where you live and how you configure the Products, you may need to get explicit consent to scan the faces of people visiting your home and/or business locations.

• Technical information from the device

In order to improve your experience over time, help troubleshoot problems you may encounter, and provide updates to your Kami Camera, we store your device information, such as camera model and serial number, hardware and software versions, and mobile phone information like unique identifiers (including IMEI and MAC), operating system, crash logs, error logs, and language settings. In addition, we will collect your mobile phone’s IMEI and MAC numbers for logging you into and authenticating you to your Product or Kami Vision’s systems. Further, to improve your experience, we collect but do not associate your account or email with aggregated, non-identified, data about Product functions used and frequency of use.

• Shared content

Kami Vision Camera Authorized Users tend to enjoy sharing certain content like video clips, images, captions, and comments with other people. Your content can be shared as directed by you or your Authorized Users through Kami Vision’s community website or third-party applications and services, such as Facebook or YouTube. Such third-party applications and services are not controlled by Kami Vision and have their own privacy and service policies. Kami Vision is not responsible for the privacy practices of any website or third-party applications and services that it does not own or otherwise control and you should read the privacy policies of websites, applications and services owned and controlled by others before deciding whether to proceed.

The content you share by placing it on Kami Vision Community is available for sharing for a limited time (e.g., 30 days or less) after which it is deleted from Kami Vision’s systems, although Kami Vision retains the right to store the content for internal research and development.

Data protection and privacy laws in your locality may impose certain responsibilities on you and your use of Products. You (not Kami Vision) are responsible for ensuring that you comply with any applicable laws when you use Products. Note that recording and sharing clips that involve other people may affect their privacy and data protection rights.

What information does Kami Vision Cameras collect?

Kami Vision Cameras collect:

• Setup information you provide

When you set up Kami Vision Cameras, you will be asked for certain basic information like your email address, your Facebook username, and your general location (e.g. city or country).

• Snapshots, Video Clips, and Other video and audio signals and data

When you use the recording or streaming features of your Kami Vision Cameras, we will record and process video and/or audio recordings received from your device, subject to your configuration and settings. If you have enabled motion sensing or sound detection, we will record and process video and/or audio recordings upon sensing motion or detecting sound and may send notifications to you regarding the sensed motion or sound. In addition, if you have the recording feature enabled, we will capture, process and retain video, photo, and audio data recordings received from your device for a limited time (for example, 1, 7, 15, or 30 days, depending on your subscription) and you will be able to access, download, and delete those recordings using Kami Vision services during that time. After the subscription period, you will not be able to access the recordings beyond the time frame allotted for your subscription. Kami Vision retains the right to store the recordings for internal research and development use.

• “Facial Detection”, “Human Detection”, and “Baby Monitoring”:

If you choose to use the facial detection, human detection, or baby monitoring features on your Kami Vision Cameras, we will process facial and/or human body images and underlying face and body prints for the purpose of enabling your device to recognize familiar faces and people and to notify you of familiar and unknown people. Using the Products and your account, you control whether this biometric processing occurs. Depending on where you live and how you configure the Products, you may need to get explicit consent to scan the faces of people visiting your home locations.

• Technical information from the device

In order to improve your experience over time, help troubleshoot problems you may encounter, and provide updates, we store your device information, such as camera model and serial number, hardware and software versions, and mobile phone information like unique identifiers (including IMEI and MAC), operating system, crash logs, error logs, and language settings. In addition, we will collect your mobile phone’s IMEI and MAC numbers. This information is used to login and authenticate you to your Products. Further, to improve your experience, we collect but do not associate your account or email with aggregated, non-identified data on functions used and frequency of use.

• Saved and shared content

Your Kami Vision Cameras can utilize the Kami Cloud subscription service to store audio, camera, and video content during a selected subscription period (for example, 1, 7, 15, or 30 days). After the subscription period, you will not be able to access the recordings beyond the time frame allotted for your subscription. Kami Vision retains the right to store the recordings for internal research and development use.

We have technical barriers to prevent unauthorized viewing or hearing of your audio, camera, and video content, and we do not share your audio, camera, or video content, unless required by law. You may choose to download your content for sharing, including through a third-party application or service, such as Facebook or YouTube that is not controlled by Kami Vision and has its own privacy and service policies. Kami Vision is not responsible for the privacy practices of any website or third-party applications and services that it does not own or otherwise control and you should read the privacy policies of websites, applications and services owned and controlled by others before deciding whether to proceed.

Data protection and privacy laws in your locality may impose certain responsibilities on you and your use of Products. You (not Kami Vision) are responsible for ensuring that you comply with any applicable laws when you use Products. For example, you may need to display a notice that alerts visitors to your home that you are using a Product. Note that recording and sharing clips that involve other people may affect their privacy and data protection rights.

How does my Product or account interact with third parties?

Any Kami Vision data that you choose to share with a third party is governed by that third party’s privacy policy while in that party’s possession. The Products may from time to time include links to third party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third party websites and are not responsible for their privacy statements. When you leave the Products, we encourage you to read the privacy policy of every website you visit.

Any data that Kami Vision receives from third-parties (for example, information received from Facebook after you login to your Facebook account to share content) will be processed and stored by Kami Vision and will be treated in accordance with this Privacy Policy. This information may be processed in the same manner as any other data that is a part of your Kami Vision account or the Kami Vision logs.

What additional information does Kami Vision collect and store when a user connects a Product to the Internet or creates an account?

Wi-Fi Network Information: To connect your Products, including Kami Cloud, or to access your Products over the Internet from a computer, a smartphone or a tablet, you may need to connect it to your Wi-Fi network. During setup, the Product will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with Kami Vision’s systems and download software updates.

Once connected to your Wi-Fi network, your Product regularly sends the data described in this Privacy Policy (excluding your Wi-Fi password) to Kami Vision to provide you with services.

Email Addresses: When you create a Kami Vision account, we collect and store your email address. From that point forward, your email address is used for communications from Kami Vision. In addition, Kami Vision may provide you with the ability to login with alternative credentials, such as a Facebook account.

Basic Profile Information: Your account allows you to provide certain basic profile information like a username of your choice and profile photo. Usernames and profile photos may be shown to others in connection with the Products. We routinely record log entries and technical information when your mobile device, tablet, PC, or Product contacts our systems.

Websites and Cookies: If you visit any Kami Vision websites, we or our third party partners may collect information using cookies, web beacons, or log file information. Such information might include: Browser type, device type, URL addresses, IP addresses, operating system type, and geolocation data to understand where visitors reside and provide location specific content, to provide information to improve our website, prevent fraudulent activity, understand how visitors use our website, and provide personalized and relevant content. If you set your browser to refuse or disable all or some browser cookies, some parts of the Kami Vision websites or products may become inaccessible or not function properly.

Remember that when you visit our Sites, we collect personal information. Like most Internet sites, we routinely record log entries (including information such as your IP address) and technical information (such as your browser type and version) when your browser, mobile device or Product contacts our servers.

How does Kami Vision use the information it collects?

We use this information to provide, develop and improve the Products, including making assessments and recommendations about products or safety. We may use your contact details to send you this information, to ask you to participate in surveys about your use of Products, and to send you other communications from Kami Vision or selected partners or affiliates.

We may also use this information in an aggregated, non-identified form for training, research and development purposes, and to help us make sales, marketing, and business decisions. For example, we use aggregated, non-identified information about the number of times users in a particular region use a particular function to help us determine if the function is desired by customers. We may also use non-identified recordings (e.g., video clips and snapshots) for internal research use to develop our AI models. We may use service providers or consultants to perform some of these functions. Those service providers and consultants are restricted from sharing your information for any other purpose.

If you have agreed that we may do so, we may use your information to send you marketing via the communications methods you have selected via your user preferences in your account settings. Not all Products conduct direct marketing. Where this functionality is available, you can change your preferences at any time and switch this option on/off.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our systems. Depending on your location and type of data, Kami Vision may process your personal information on servers that are not in your home country. If you are in the United States, Kami Vision processes your personal information only in the United States. If you are outside of the United States, Kami Vision processes your personal information in Germany (e.g., if you are located in the European Union) and/or Singapore (e.g., if you are located in the Asia Pacific regions).

In general for purposes of applicable law (e.g., GDPR), Kami Vision is a controller of the information collected in connection with the Products. If you are in the UK, European Economic Area or Switzerland, you should know that Kami Vision is the controller of your personal information. However, in the case of “Snapshots, Video Clips, and Other video and audio signals and data” and “Facial Detection”, “Human Detection”, “People Tracking”, “Pose Identification”,“Footfall Measurement”, and “Baby Monitoring” you are the controller of these data and Kami Vision is a processor.

International Transfers of Personal Data

Depending on your geographic location, your personal information may be collected, processed and stored by Kami Vision or its service providers in the United States and other countries. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If we provide any information about you to any such entities, we will take appropriate measures to ensure such companies protect your information in accordance with this Policy and applicable law.

Definitions

TermDefinition
“Comply with a Legal Obligation”Processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
“EEA”The European Economic Area, being the member states of the European Union together with Norway, Iceland and Liechtenstein.
“Legitimate Interests”The interests of our business in conducting and managing our business to enable us to provide you with the best and most secure experience when using the Products and related functionality, or the interests of a third party. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our or any third party’s legitimate interests. We do not use your personal data for activities where our (or the relevant third party’s) interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law). You can obtain further information about how we assess our and any relevant third party’s legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of a Contract”Processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

If you are using Products in the European Economic Area (“EEA”) please be aware that we may transfer your personal data to a third party in countries outside the EEA for further processing in accordance with the purposes set out in this Privacy Policy. In particular, your personal data may be transferred to the United States and other countries (including to Germany and Singapore) where Kami Vision operates and to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organizational, contractual or other lawful means.

If you are in the UK or the EEA, and we transfer your personal data outside of the EEA, we ensure a similar degree of protection applies by implementing at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection as it has in Europe. For transfers of data from the EEA to the United States or Singapore, Kami Vision (i.e., the controller) has entered into the European Commission’s Standard Contractual Clauses with its service providers (i.e., processors) to protect user’s privacy rights.

• Please contact us if you would like further information on the specific mechanism used when transferring your data outside the EEA.

Our legal bases for processing information

If European data protection law applies to the processing of your information, we process your information for the purposes described in this Privacy Policy, based on the following legal grounds:

• When we’re providing a product or a service: We process your data to provide and support a product or service you have asked for, such as in the course of Performance of a Contract, including but not limited to delivering our Terms of Use.

• When we are pursuing Legitimate Interests: We process your information for our Legitimate Interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:

• offering and improving the Products

• developing new products and features

• understanding how people use our products and services

• performing research that improves our services for our users and benefits the public

• protecting against harm to the rights, property, and safety of Kami Vision, our users, and the public

• detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services

• maintaining and improving the integrity of our computing systems, and protecting our users’ data security

• enforcing legal claims, including investigation of potential violations of applicable Terms of Use.

• When we are complying with a Legal Obligation: We process your data when we have a Legal Obligation to do so, for example, if we are responding to a legal process or an enforceable governmental request.

• With your consent: We may periodically send promotional notifications to you related to the Products if you have registered with us or requested information from us and you have not opted-out of receiving that marketing. You may opt-out of receiving promotional communications from us in your account settings or follow the unsubscribe instructions at the bottom of any email or text from us. If you opt-out, we may still send you non-promotional communications, such as those about your account. Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your express opt-in consent before sending third party direct marketing communications to you via email or text message. Where necessary, we ask for your consent to process your information for these and other certain specific purposes and give you the right to withdraw that consent at any time by contacting us.

Change of Purpose

• We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you would like an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

• If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

• Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is to Comply with a Legal Obligation.

In what circumstances does Kami Vision share my information?

We do not share personal information for any commercial or marketing purposes unrelated to the activation and delivery of the Products without asking you first. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

The following are the limited situations where we may share personal information:

• With your permission: We may share personal information when we have your permission. One example of this is if you sign up for programs offered by our partners; if you do this, we may share certain information with the partner. This could include things like your enrollment information and the activation status of your device. If you connect third-party devices and services to your Products, you are shown information about any proposed exchange of data. Kami Vision or the third party will request your consent to these exchanges on your behalf and you can change your mind at any time. When you use third-party products and services integrated with the Products, the third-party’s own terms and privacy policies will govern your use of those products and services.

• For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers and systems for technical problems. These vendors, service providers, and technicians (as well as Kami Vision employees) can access certain information about you or your account relating to this work, but these technicians are not allowed to use this data for non-Kami Vision purposes and are required to process such information in compliance with the law and this Privacy Policy. We have implemented confidentiality policies and have technical barriers in place to prevent unauthorized employee access to video and audio recordings that you have not shared.

• As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request that a purchaser treat our data under the Privacy Policy.

• For legal reasons: We may provide information to a third party, without your knowledge or consent, if we believe in good faith that we are required to do so for legal reasons to Comply With a Legal Obligation or other applicable laws around the world (for example, in the country of your residence). For example, we may disclose information in response to a court order, judicial or other government request, subpoena, or warrant, in the manner legally required, and we may disclose information in response to lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security. We also reserve the right to disclose information that we believe, in good faith, is appropriate or necessary to: (1) protect Kami Vision from potential liability or fraudulent, abusive, or unlawful uses; (2) investigate and defend ourselves against third-party claims, or allegations; (3) protect the security or integrity of the Products; or (4) protect the rights, property, or safety of Kami Vision, our Users, or others.

If you select an outside party for the purchase, installation, or service of your Kami Vision device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a Kami Vision Product from a retailer, the retailer may collect personal information as part of the transaction.

What choices do I have and how can I delete my personal information?

If you are a Kami Cloud subscriber, Kami Vision generally stores your personal information on Kami Vision’s systems until you delete or edit it, or for as long as you remain a Kami Vision customer, in order to provide you with the Products, but your audio, photo, and video files are stored for a limited time (e.g. 1, 7, 15, or 30 days, depending on the type of subscription you have purchased). After the subscription period, you will not be able to access the recordings beyond the time frame allotted for your subscription. Kami Vision does retain the right to store the audio and video recordings and photo files for internal research and development.

Your Kami Vision account allows you to delete audio, photo, and video files that you choose before the limited storage time has elapsed. In addition, should you wish to delete your entire account, including all recordings associated with it, contact support@kamivision.com.

As described above, some information is processed and stored directly on the Kami Vision device. All personal information is encrypted as it is transmitted to Kami Vision. You can delete the information on the Kami Vision device by resetting it to the defaults.

Kami Vision generally stores your personal information on Kami Vision’s servers until you delete or edit it, or for as long as you remain a Kami Vision customer in order to provide you with the Products. In addition, Kami Vision may store your personal information to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

You can access, amend or delete your personal information from Kami Vision’s systems through the controls in your Kami Vision account. Because of the way we maintain certain services, after your information is deleted, backup copies may linger for some time before they are deleted, and we may retain certain data for a longer period of time if we are required to do so for legal reasons.

Individual Rights in the European Economic Area

If you are located in the European Economic Area (EEA), you may seek confirmation regarding whether Kami Vision is processing personal information about you, request access to your personal information and ask that we correct, amend or delete your personal information. In addition, you may object to Kami Vision’s processing of your personal information at any time. Please note that doing so may impact your use of the Products.

If applicable law provides you the right to request access to, receive a report regarding, object to or restrict processing, seek rectification or request erasure of personal information held about you by Kami Vision, you may do so, as applicable, through controls in the Kami Vision apps or by contacting Kami Vision at support@kamivision.com .

Further information on your rights in the EEA is set out below:

• Right to obtain a copy of your personal data – you have the right to obtain a copy of the personal information we hold about you. If you would like to make a SAR, i.e. a request for copies of the personal data we hold about you, you may do so by contacting us at the contact details above. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity.

• Right to rectification – you may request that we rectify any inaccurate and/or complete any incomplete personal data, though we may need to verify the accuracy of the new data you provide to us.

• Right to withdraw consent – you may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal data is essential.

• Right to request restriction of processing of your personal data – this entitles you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy;

• Where our use of the data is unlawful but you do not want us to erase it;

• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims;

• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Right to object to processing – including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your personal data insofar as we base the processing of your personal data on Legitimate Interests and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. If you wish to do so, we kindly ask for an explanation of the reasons for the objection. If your objection is justified, we will discontinue or adapt the data processing or explain why we have compelling legitimate grounds to continue processing your personal data notwithstanding your objection. In relation to automated processing and profiling, you may object to the processing and you will have the right to obtain human intervention. You may, of course, object to the processing of your personal data for advertising and data analysis purposes at any time.

• Right to erasure – you may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our Legal Obligations. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see above), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Right to data portability – in certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Your right to lodge a complaint with the supervisory authority – please contact us first about any questions or if you have a complaint in relation to how we process your personal data. However, you do have the right to contact the relevant EEA supervisory authority directly.

As mentioned above, we do not generally rely on consent to process your personal data. If we do, you may withdraw your consent at any time (although this will not affect the lawfulness of any processing carried out before you withdrew your consent). If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity in order to respond to any exercise of the above rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you’re based in the EU, you have the option to file a complaint against the processing of your personal data with the competent supervisory authority. [In the UK, this is the Information Commissioner, whose contact details can be found at www.ico.gov.uk.] We would however appreciate the chance to deal with your concerns before you approach the supervisory authority so please contact us in the first instance.

California Consumer Privacy Act

For purposes of the California Consumer Privacy Act of 2018 (the “CCPA”), we have collected and disclosed from residents of California the following categories of personal information in the preceding 12 months:

CategoryCollectedDisclosed
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiersYesNo
Personal information as defined in the California customer records law, e.g., name, signature, contact information, and social media account handle and other information you may share or make public on social networksYesNo
Characteristics of protected classifications under California or federal lawNoNo
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendenciesYesNo
Biometric informationYesNo
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisementYesNo
Geolocation dataYesNo
Audio, electronic, visual, thermal, olfactory, or similar informationYesNo
Professional or employment-related informationNoNo
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act, e.g., student recordsNoNo
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudesYesNo

Under the CCPA, residents of California who use the Sites or Products have certain rights, including:

• The right to request that we disclose to you:

• the categories of Personal Information we have collected about you;

• the categories of sources from which the Personal Information is collected;

• the business or commercial purpose for collecting or selling Personal Information;

• the categories of third parties with whom we share Personal Information;

• the specific pieces of Personal Information we have collected about you;

• the categories of Personal Information about you that we have sold during the preceding 12 months*;

• the categories of third parties to whom your Personal Information was sold, by category or categories of Personal Information for each third party to whom your Personal Information was sold*; and

• the categories of Personal Information we have disclosed about you for a business purpose during the preceding 12 months.

*Although you have the right to request this information, we do not sell your Personal Information.

• The right not to be discriminated against because you exercise any of your rights under the CCPA, including, but not limited to, by:

• denying you goods or services;

• charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

• providing you with a different level or quality of goods or services; or

• suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

• The right to request the deletion of your Personal Information.

Kami Vision does not sell your personal information. We may share your information only as described in this Privacy Policy. Kami Vision processes your information for the purposes described in this Privacy Policy, which include “business purposes” under the CCPA. These purposes include:

• offering and improving Products

• developing new products and features

• understanding how people use our Products

• performing research that improves our Products for our users and benefits the public

• protecting against harm to the rights, property, and safety of Kami Vision, our users, and the public

• detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our Products

• maintaining and improving the integrity of our computing systems, and protecting our users’ data security

• Using service providers to perform services on our behalf, in compliance with our privacy policies and other appropriate confidentiality and security measures

If you have additional questions or requests related to your rights under the CCPA, you can contact us as explained below.

If you would like to make a request under the CCPA, please contact support@kamivision.com. For your protection, we may need to verify your identity before implementing your request by asking you to reconfirm information we have already collected to be sure that the request is authorized.

Can the Privacy Policy be changed?

Please note that this Privacy Policy may change from time to time. We will provide notice of any changes by contacting you through a notification in the Kami Vision mobile app or through the email contact information you provided when setting up your Kami Vision account.

How can I contact Kami Vision?

If you have any questions, please contact us at: support@kamivision.com

Cookie Policy

The Kami Vision website and app use cookies to distinguish you from other users of the website and app. This helps us to provide you with a good experience when you browse the service and also allows us to improve our website and/or app. If other Products use cookies we will inform you.

This section of the Privacy Policy explains what cookies are, why we use them and what you may do if you wish to restrict, remove or refuse to accept cookies. By continuing to use the Kami Vision website and/or app, you agree to the use of cookies for the purposes set out in this Privacy Policy.

A cookie is a small file that a website, app or its service provider transfers to your computer’s hard drive, mobile phone or other device, through your web browser (if you agree) that enables the website’s, app’s or service provider’s systems to recognize your browser and capture and remember certain information. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website.

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie Name Purpose Duration More information

[Google Analytics _ga] Used to distinguish users 2 years These cookies are used to collect information about how visitors use our Website. We use the information to compile reports and to help us improve the Website. The cookies collect information in an anonymous form, including the number of visitors to the Website, where visitors have come to the Website from and the pages they visited.

https://developers.google.com/analytics/devguides/collection/

analyticsjs/cookie-usage

[Google Analytics _gat] Used to throttle request rates to maintain Website performance 1 minute

[Google Analytics _gid] Used to distinguish users 24 hours

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the relevant website and/or app.

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