Last updated: 2021.07.23
Vision intelligence Co.,Ltd (hereinafter referred as "we" or "us"), having the principle place of business at 66 Yunfei Road, Hefei City, Anhui Province, developed this Privacy Policy (hereinafter referred as “Privacy Policy”) for your reference so that you will be able to understand how we process your personal data when you use our Sling (hereinafter referred to as "products") or services. Please read our privacy practices carefully and contact us if you have any questions.
1.Terms and Definitions
2.Legal Grounds to Processing of Personal Data
3.Information We Collect
4.Purposes of Processing of Personal Data
5.Ways of Processing of Personal Data
6.Retention Terms
7.How We Share Your Personal Data
8.Your Rights
9.Cookies
10.Third Party Links
11.Security
12.Minor’s Privacy
13.International Transfer
14.Notification Regarding Updates
15.Data protection officer and contact
16.Contact Us
Data controller：Means the legal entity (alone or jointly with others) determining the purposes and means of the processing of personal data. Vision intelligence Co.,Ltd is the data controller, if not otherwise determined by law.
Personal data：Means any information relating to an identified or identifiable natural person ("data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; You (user or visitor of the Services) are the data subject.
International transfer：Means transmission of personal data to the territory of a foreign country or region, public authority of a foreign state, foreign individual or foreign legal entity.
Vision intelligence Co.,Ltd will process your personal data only where there are legal grounds to do so. Those grounds include the following:
a. Consent: You have provided your consent to the processing of your personal data.
b. Legal situations: The processing of your personal data is required or authorized by applicable laws, or relates to suspected unlawful activity, serious misconduct, legal proceedings or law enforcement.
c. Reasonable expectations:
The processing of your personal data is necessary for the purposes of our legitimate interests. We believe that our processing of your personal data is within our legitimate interests and within your reasonable expectations in a number of situations, including but not limited to:
a.Usage of products and services:We may collect information from you in the course of providing service to you in relation to the products and services. The information collected includes voice recordings you enter when you use the voice recognition, functions of the Sling.
b.Log and device data information:We may collect relevant log data when you’re using the services. In other words, when you’re using our services, the system may automatically collect the device or software data through cookies, web beacons or other means, such as the configuration data, your IP address and the version and device identifiers used for computers which are provided by your computer devices, the Sling or other programs to access our services.
c.Other Information:When you use some services and such services may require specific use of your information, we will specify such information in separate terms, agreements, or privacy policies and will collect, process, use, or transfer such information according thereto and get your consent where appropriate.
We do not generally ask you for sensitive personal data, i.e. personal data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal records, or trade union or professional association membership, genetic data for the purpose of uniquely identifying a natural person, and data concerning health or data concerning a natural person’s sex life or sexual orientation. However, you may voluntarily provide sensitive personal data in the use of our services (e.g. by including it in the messages you input). If we need to collect or process sensitive personal data (such as facial feature, fingerprint feature, heart rate, step count, etc.) in other circumstances, we will do so with your consent or where we are otherwise required or permitted by law.
We will process your personal data to fulfill the following purposes:
a.Provide, maintain, improve, protect, and develop our services and products;
b.Send notices to you of our software updates, updated policies or other information that we believe may be important to you;
c.Interact with you about your device, services, or any of your questions and requests.
We will carry out the following operations on your personal data: collection, recording, systematization, accumulation, storage, alteration (update, modification), retrieval, use, transfer (provision, access), depersonalization, blocking, and deletion (destruction) of personal data. For the voice that you enter by yourself, we only collect it but will not do any other processing.
We does not take any decisions involving the use of algorithms or profiling that significantly affect you.
We are required to ensure such processing is subject to suitable safeguards, including reasonable steps to ensure personal data is accurate, complete, up-to-date and relevant, and your rights to access and correct personal data about you.
We process your personal data for as long as is necessary to fulfill the purpose of its processing. We will terminate processing of your personal data if you withdraw your consent, unless we are entitled (or obliged) to continue processing your personal data on other legal grounds.
When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems, unless the personal data is required to be stored for longer periods (e.g. for archiving purposes in the public interest, or for scientific or historical research purposes). While we will endeavor to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, such data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.
We do not sell any personal information to third parties. We may, where necessary, share your personal information with our third party service providers and business partners:
a.in order to comply with applicable laws or regulations;
b.in order to comply with a court order, subpoena or other legal process;
c.in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere);
d.where we believe it is reasonably necessary to comply with applicable laws or regulations;
e.to help us provide you with products and services described in this Privacy Policy.in order to enforce the service enhancements.
Personal data may be shared with:
a.Third Parties. At times we may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request. This includes Google,Spotify,Apple,iFlytek,and these third parties may process your personal information on Vision intelligence Co.,Ltd behalf or for one or more of the purposes of this Privacy Policy(for example, iflytek needs to collect the Installed Application information).
When we do, we are committed to ensuring that the sharing of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. We require those third parties to handle it in accordance with relevant laws and reasonable safeguards in your jurisdiction.
We does not sell personal information, and personal information will never be shared with third parties for their marketing purposes. We strongly suggest that you take the time to read the third party privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to the processing operations performed by third parties on your personal data.
The following are the applicable third party privacy policies when you use the specific services listed above:
Spotify’s Privacy Policy: https://www.spotify.com/us/legal/privacy-policy/
Google’s Privacy Policy: https://www.google.com/policies/privacy
Apple's Privacy Policy: https://www.apple.com.cn/legal/privacy/
iFlytek's Privacy Policy:https://global.xfyun.cn/doc/policy/privacy.html
b.Legal and law enforcement. We are required to disclose your personal data by local judicial or governmental authorities, agencies or as mandated under applicable laws.
c.Change of control – New Owners. In the event of any actual or prospective merger, restructuring or bankruptcy, We may also provide your personal data to related third parties ，and we will further notice you about the change.
When sharing your personal data with our Affiliated Entities, Third Parties and New Owners, we require that they securely store the personal data we provide to them and all such entities are contractually bound by us to keep the personal data confidential.
Being a data subject, you have other rights with respect to your personal data in accordance with relevant laws. We have established the approach and management process to realize the rights of the data subject. You can exercise your rights by sending your request to sling@vision-intelligence.tech as set out in Contact Us Section of this Privacy Policy. We shall at no time however be responsible/ liable for the authenticity/ veracity of the information you provide. Please note that we may keep a record of your communications to help us resolve any issues which you raise.
You have the following rights in relation to your personal data:
a.Right to know
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal information and your rights. This is why we are providing you with the information in this Privacy Policy
b.Right to access
You may ask us for a copy of the information we hold about you at any time. You may also access and update the details relating to the personal information by logging into your account. You have the right to access the following information:
If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.
c.Right to rectification
You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.
d.Right to erasure
You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:
We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of personal data we will take all reasonably practicable steps to delete the relevant personal data.
e.Right to object
This right enables you to object to us processing your personal data where we do so for one of the following reasons:
f.Right to withdraw consent
Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your personal data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your personal data for that purpose, in which case we will inform you of this basis.
You have the right to withdraw your consent to the processing of your personal data any time with effectiveness for the future. To do this, please send your withdrawal request to sling@vision-intelligence.tech Your personal data will be deleted within a reasonable time period after receipt of your withdrawal. We draw your attention to the fact that we may continue processing your personal data if we are entitled (or obliged) to continue processing your personal data on other legal grounds.
Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will notify you before lifting any restriction on processing your personal data.
g.Right to restrict processing
You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will notify you before lifting any restriction on processing your personal data.
h.Right of data portability
You have the right to transfer your personal data between service providers, provided that: 1) the personal data is processed by automated means; 2) the personal data has been provided to us by data subjects; and 3) the basis for processing is consent, or that the data are being processed to fulfil a contract or steps preparatory to a contract. In effect, this means that you are able to transfer the details we hold about you to another third party. To allow you to do so, we will provide you with your personal data in a commonly used machine-readable format so that you can transfer the personal data. Alternatively, we may directly transfer the personal data for you.
i. Right to immunity from discrimination
If you choose to exercise your privacy rights, you have the right to not to receive discriminatory treatment or a lesser degree of service from us.
j.Right to opt-out
You have the right to opt-out of the sale of your personal information. We does not sell your personal information.
k.Right to complain
You have the right to lodge a complaint with the relevant supervisory authority.
When you make a request, we may need to obtain your personal information (such as account information, contact information, etc.) to verify your identity. After successful verification, you can exercise your rights according to your needs.
Cookies are small amounts of data that are stored within your computer’s Internet browser, accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online later. The cookies are not able to execute code or access other information stored on the computer.
Web beacons are transparent pixel images that are used in collecting information about website usage, email response and tracking. This involves us placing and storing a cookie file on the hard drive of your device, which records your navigation of our website and other service offerings to help us improve your experience and to deliver a more tailored service.
When you consent to Cookies on our services, these may be used to do the following:
We will not use cookies to determine your identity.
At any point, you can set your browser to reject cookies or to notify you when you sent a cookie. To learn more about your ability to manage cookies and web beacons, please consult the privacy features in your browser. However, please note that if you do this you may not be able to use the full functionality of this Website.
Our Services may contain links to other third party websites, products and services, or use or offer products or services from third parties. Information collected by third parties is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties. We are not responsible for the privacy practices or the content of these third party sites.
We takes security measures to protect your information, including but not limited to administrative, technical and physical measures. However, please note that although we have implemented these measures, there is no security measure that can guarantee the absolute safety and security of your information. If you believe that your login credentials have been compromised, please contact us at once.
When you use our products, the personal data you share is visible to other users and in some cases search engines and the public and can be read, collected, used and retained by those other parties. You are responsible for the personal data you choose to share or submit in these instances. It is your responsibility to make sure that your personal data is accurate.
Below are some examples of data security measures we undertake:
a.Ensuring the security of the premises where the information systems used to process personal data are located. Such security shall prevent any uncontrolled access to such premises by persons having no rights to access such premises.
b.Using technical means to protect the information including but not limited to encryption and anonymization techniques.
c.A variety of security technologies and procedures are adopted by us to protect against the loss, illegal use, unauthorized access or disclosure of data. For instance, in some services, we shall use the encryption techniques (such as SSL) to protect the relevant data you provide. However, please understand that due to technical limitations and possible malicious means, in the Internet industry, even if we have tried our best to strengthen security measures, it is still impossible to always make sure that the data is 100% safe. You need to understand that the system and communication network that you use to access our services may go wrong due to factors beyond our control.
d.Appointing a data protection officer.
e.Identifying threats to the security of personal data while they are being processed in our information systems.
f.Assessing the effectiveness of measures taken to ensure the security of personal data.
g.Detecting instances of unauthorized access to personal data and taking appropriate measures to mitigate the effects of such unauthorized access.
h.Taking all practicable measures to restore personal data which have been modified or destroyed as a result of unauthorized access.
i.Establish an emergency plan for personal information leakage, including notification and disclosure mechanisms.
j.Monitoring measures taken to ensure the security of personal data and the level of protection of personal data information systems.
k.Establishing rules for access to personal data being processed in our information systems and recording all processing actions performed on personal data contained in our information systems.
Our services are not intended for minors as defined by applicable laws. We do not knowingly collect personal data via our Services from minors. We will only use or disclose minor information if (a) legally permissible; (b) the parent or other legal representative of the minor has provided consent; or (c) there are other legal grounds as per applicable data protection laws. When you are the parent or other legal representative of the minor, we guarantee that you can exercise your right to withdraw your consent and request the deletion of the minor’s personal data. If we accidentally collect a child's personal data without verified prior consent from the child's parents, we will attempt to delete the data as soon as possible. If you believe a minor has provided personal data to us without parental/legal guardian consent, please contact us.
The data related to our product is processed in U.S. Your personal data will not be transferred or shared across borders, except in the following situations:
Please note that if you reject us for international transfer, you can contact us via sling@vision-intelligence.tech. After you have clearly expressed your intention to refuse the transfer, we guarantee that without your re-consent, we will not transfer your data internationally.
We want to make sure that your personal data is transferred in a secure way. Where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy. For example, this could be:
We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you via your registered contact information such as email (sent to the email address specified in your account) or publish on Vision intelligence Co.,Ltd websites or notify you via mobile devices so that you can learn about the information we collect and how we use it. Such changes to Privacy Policy will apply from the effective date specified in the notice or website. We encourage you to check this page regularly for the latest information on our privacy practices. Your continued use of the services will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal information from you or when we use or disclose your personal information for new purposes.
We have appointed data protection officers to oversee the protection of your personal data. If you have any questions about this Privacy Policy or about data protection at Vision intelligence Co.,Ltd in general, you can contact the data protection officer responsible for your country at any time. The contact details of the data protection officer is: wangjiaxiang@vision-intelligence.tech
If you have any questions about the way we handle your personal data which have not been answered in this Privacy Policy, you may email us at sling@vision-intelligence.tech.
When we receive privacy or personal information questions about access/download requests, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information. If you are not satisfied with the response you received, you can hand over the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.