Privacy Policy

This Privacy Policy was updated on July 30, 2020. Please carefully read and understand our privacy protection practices and let us know if you have any questions. Contact details are set out below.
1. Who we are
Shenzhen Qihoo Jian An Intelligent Technology Co., Ltd. (hereinafter refer to as“we”, “us” or “our”) respects your privacy and values the trust you place in us when you share your personal data with us. This policy sets out how we, as data controller, collect and use your personal data, why we use it, with whom we share it, the rights to which you may be entitled and your choices about our use of your personal data.
This policy covers our collection, use, disclosure, process and protection of your personal data arising from use of our official website (“Website”) https://www.smart.360.com.
2. Your personal data
We will collect and use your personal data to allow access to and use of the Website and for other purposes set out in more detail in this section.

	What we collect	How we use it
1.	Data provided as part of your account including: Your username; Your email address; Your password; You do not need to register an account for using the Website. If you choose to register an account, you may use additional features of our service. Upon the registration of an account, you can, at your own discretions, offer us your private information, such as date of birth, hobby, educational background， helpful for us to provide more personalized service and recommendation, but your refusal will not have any influence on your use of other functions of the Website. You can change your private information by visiting the interfaces "360 Personal Center->Account Information->Details".	We use this data, including to: Register account for you and enable you to log in the account; Verify users’ identity and prevent fraud; Identify how you’d like to use your account and improve the existing services; Provide to you more personalized service and recommendation.
2.	Data that we collect through your use of our Website, including: IP address; Device information, such as your device name, device model, operating system version, resolution ratio, system language and so on. Website browsing information, such as URL, information of the websites you visit, your browser type and UA information of the website you request.	We use this data, including to: Identify issues with Website and improve your experience of using it; Improve existing services and develop new services.
3.	Data we collect for statistical analysis purposes: the Usage statistics of the Website, which generally include the use or view frequency statistics of the featured video, news feeds, websites links and other functions.	We use this data, including to: Improve existing services; Statistical analysis and research.
4.	Data we collect when you use or visit the Community function: The content of your post; the time when you post; the content of your comments; the time when you make the comments.	We use this data, including to: Provide and improve our services.
5.	Data we collect when you communicate with us whether in person, through our website, via email, through the feedback channel in the Website, through social media or via any other medium, including: The details of your communications with us; The details of our messages to you.	We use this data, including to: Answer any issues or concerns; Service quality improvement and training purposes; Improve our services; Personalize our service.

Except for those set out in the above, we will NOT collect or process other kinds of personal data concerning you.
Special data
In some jurisdiction, certain types of personal information are more sensitive than others. This “special data” may include data about health, disability, race, ethnicity, criminal offences (or alleged offences), political opinions, biometrics or religion. We do NOT collect or use any special data about you.
3. Sharing of your personal data
There are certain circumstances where we may transfer your personal data to employees, contractors and to other parties, to the extent that such third party has a legal basis or valid jurisdiction to request such data. We will not sell, lease, rent or give away your personal data.

We may share personal data about you with other members of our group of companies so we can provide the best service across our group. They are bound to keep your data in accordance with this Privacy Policy.

If we’re discussing selling or transferring part or all of our business – the data may be transferred to prospective purchasers under suitable terms as to confidentiality;
If we are reorganized or sold, data may be transferred to a buyer who can continue to provide services to you;
If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority;
If we are defending a legal claim your data may be transferred as required in connection with defending such claim;
If we have obtained your explicit consent in advance.

Please be noted that our Privacy Policy does not apply to the products or services offered by any third party. Our Website has incorporated some third parties’ products or services, such as YouTube, and your personal data may also be collected when you use these products or services. For this reason, we strongly suggest that you take your time to carefully read the third party’s privacy policy. We are not responsible for and cannot control how third parties use personal data which they collect from you.
4. How long and where we keep your personal data
We will keep your data for as long as it is reasonably necessary. It will depend on factors such as whether you have an account with us or have interacted with us. We will also routinely refresh our data to ensure we keep it up-to-date.
For clarity, your personal data will be deleted or anonymized when it is no longer needed for its originally stated processing purposes or for any additional compatible purpose for which we may lawfully further process such data.
Legal requirements
Your personal data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claim. We will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
Except the usage statistics data, your personal data we collect will be stored in our database in the People’s Republic of China. We use the Google Analytics for usage data statistics. We may also transfer your personal data to third-party service providers and business partners and your data may therefore be transmitted to other countries or regions. Those countries may not have equivalent data protection laws to those applicable in the EU or the People of China. We do, however, ensure an adequate data protection level by agreements with these third-party service providers and by adopting other necessary arrangements, both technical and organizational.
5. Your rights
You may have certain rights in relation to your data including a right to access or to correct the data we hold about you. We have listed the rights you have over your data and how you can use them below.

Upon request, we will provide you with information about whether we hold any of your personal data. You also have the right to access personal data we hold about you, how we use it, and who we share it with. You can ask us to confirm if we are processing your information through the feedback channel in the Website or sending email to our Data Protection Department.
You can have access to and correct your account information through Settings of 360 Personal Center->Account Information->Details.
You can ask us to restrict how we use your personal data by emailing to our Data Protection Department.
You can ask us to stop using your personal data by emailing to our Data Protection Department, but only in certain cases.
You can withdraw your consent for us to collect or use your personal data by emailing to our Data Protection Department.
You can have your account cancelled through the account cancellation of the 360 Personal Center at any time. Please take note that if you have your account cancelled, your account will no longer be used and your personal data will be deleted.
You have the right to complain to the relevant supervisory authority.

6. Protecting minors' personal data
If you are a minor, your guardian's consent or authorization will be needed for you to use our services. It is recommended that your parents or guardian read these Privacy Policy for you and it is suggested that you submit your personal data with the consent and guidance from your parents or guardian. If you are a minor's guardian, you can contact us by the contact information as stated in Section 9 hereof when you have any doubt about the personal data of the minor under your custody.
7. Security
We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.

We are the leading large-scale internet company which appoints the Chief Privacy Officer (“CPO”) in China. CPO is responsible for various affairs related to the users’ personal data that our software and hardware products and services may involve, including formulating privacy policies for various products and services, reviewing the terms of use for the products and services, and supervising implementation of the working principles and data processing mechanism of the products and services. In addition, we have established a department in charge of personal data protection and act under supervision of the public. We transfer and store personal data using encryption to ensure the privacy of such data.
If you have an account, we may analyze the use time, IP address, and other relevant information for our risk control and management.
We implement access control mechanism in our service end. We require our employees who may have access to your personal data to obey the principle of data minimization and examine the access list and access records on a regular basis.
Our server systems used to store your personal data are equipped with strengthened safeguards. We conduct account audit and monitoring on the operation of our servers. Where any security problem of the server systems is reported, we will immediately complete security upgrades for the server systems to ensure the security of our server systems
We conduct regular training on the relevant laws and regulations related to personal data protection to strengthen our employees’ awareness of privacy protection.
If any destruction of our physical, technical or management safeguard measures occurs, we will launch our emergency plan in a timely manner to prevent the spreading effect of the security incident and will report the same to the competent authority in accordance with the relevant laws and regulations. We will also notify you, in a timely manner, of the security incident, potential impacts and the measures we have taken or will take to deal with the incident, in a reasonable and effective way such as pushing notifications and publishing announcements.

8. Changes to the policy
This policy will be changed from time to time. If we change anything important about this policy (the personal data we collect, how we use it or why), we will highlight those changes at the top of the policy and provide a prominent link to it for a reasonable length of time following the change. Those changes will apply from the effective date specified in the notice We encourage you to check the Privacy Policy regularly for the latest changes. Your continued use of the services on the website will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal data from you or when we use or disclose your personal data for new purposes.
You can email the Data Protection Department for previous versions of the Privacy Policy and you can get in touch at the following email address: privacy.iot@360.cn.
9. How to contact us
If you have any questions about this Privacy Policy or any questions relating to the collection, use, or disclosure of your personal data, please feel free to contact our Data Protection Department at: zh-service@360.cn. Generally speaking, we will reply to you within 15 working days. If you are not satisfied with the response, you can hand over the complaint to the relevant regulatory authority in your jurisdiction.