Privacy Policy

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or parts of our Service.
• Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Application refers to Vivoo Eye, the software program provided by the Company.
• Company (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to VIVOO TECHNOLOGY COMPANY LIMITED, 2/13A Bach Dang Street, Tan Son Hoa Ward, Vietnam.
• Country refers to: Vietnam.
• Device means any device that can access the Service such as a computer, a cell phone or a digital tablet.
• Designated Hardware means the physical companion hardware device (including connected cameras) that pairs with the Application via Bluetooth to provide the Service's core features.
• Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a law uses a specific term.
• Service refers to the Application.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

• Information regarding Your location
• Pictures and other information from Your Device's camera and photo library — for example, to scan a QR code to pair with the Designated Hardware, or to select or upload a profile photo. This is separate from the Designated Hardware's own camera footage, which is addressed under "Camera Media and Event Content" below.

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device. You can enable or disable access to this information at any time, through Your Device settings.

Bluetooth

The Application uses Your Device's Bluetooth connectivity solely to discover and pair with the Designated Hardware during setup and to maintain communication for the Service's core features. No data transmitted via Bluetooth is shared with third parties beyond what is necessary to operate the Designated Hardware.

Biometric Authentication (Face ID)

The Application offers an optional sign-in convenience feature using Face ID, provided directly by Apple's LocalAuthentication framework on Your Device.

What data is involved: The Application does not collect, receive, access, view, transmit, or store any face data, facial image, facial scan, face geometry, face template, or any other biometric identifier. When You choose to enable Face ID, all biometric processing (face scanning and matching) is performed entirely by Apple's operating system within the Device's Secure Enclave, a dedicated hardware security component that is isolated from the Application, the Company, and any third party.

What the Application receives: The Application only receives a simple authentication result (success or failure) from the operating system after You authenticate. No image, scan, biometric template, or other representation of Your face is ever made available to the Application, to Us, or to any Service Provider or third party.

Use: This authentication result is used solely to unlock the Application or confirm Your identity for sign-in purposes on Your own Device.

Sharing with third parties: We do not share any face data with third parties, and We are technically unable to do so, because We never receive or have access to any such data.

Storage and retention: We do not store any face data on Our servers or on the Device, and therefore no retention period applies. Any biometric data used by Face ID is managed exclusively by Apple's operating system according to Apple's own security architecture, not by the Company.

Your control: Face ID sign-in is optional. You may disable it at any time in the Application's settings or in Your Device's Face ID & Passcode settings, and continue to use the Application with a password or other available sign-in method.

Face Data and Biometric Information

Vivoo Eye does not collect, extract, analyze, store, retain, share, or process biometric face data for the purpose of identifying or authenticating any individual.

The Application may store or display camera-generated media, including live streams, event snapshots, thumbnails, notification images, and recorded video clips, that may visually contain people or human faces. However, Vivoo Eye does not generate or store any face template, face geometry, facial recognition profile, biometric identifier, or other biometric face data from such content.

The "Human detected" feature is used only to classify the presence of a person in camera content for security monitoring and event notification purposes, and is not used to identify a specific individual.

Vivoo Eye does not share biometric face data with third parties because it does not collect biometric face data.
Vivoo Eye does not retain biometric face data because it does not collect biometric face data.

Camera Media and Event Content

Vivoo Eye allows users to view and manage live streams, notification images, event snapshots, thumbnails, and recorded video generated by connected cameras (the Designated Hardware). Such media may contain images of people, including faces, depending on what is captured by the user's camera.

This media is used only to provide camera monitoring, playback, event review, notifications, and related security features requested by the user. This media is not used by Vivoo Eye for facial recognition or identity recognition.

By default, recorded video clips are retained on cloud storage according to the user's selected cloud storage plan, or locally on the Designated Hardware's SD card, subject to available storage capacity and automatic overwriting when full. Users may delete this footage manually at any time within the Application.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service.
• To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
• For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
• To contact You: by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.
• To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those You have already purchased or inquired about, unless You have opted not to receive such information.
• To manage Your requests: to attend and manage Your requests to Us.
• For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving Our Service, products, services, marketing, and Your experience.

We may share Your Personal Data in the following situations:

• With Service Providers: to monitor and analyze the use of our Service, and to contact You.
• For business transfers: in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: who will be required to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: to offer You certain products, services or promotions.
• With other users: where the Service offers public areas, when You share Personal Data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
• With Your consent: for any other disclosed purpose.

For the avoidance of doubt, no face data or other biometric identifier is shared in any of the situations above, as the Company does not collect or have access to such data (see "Biometric Authentication (Face ID)" above).

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:

• Account Information – User Accounts: retained for the duration of Your account relationship plus up to 24 months after account closure, to handle any post-termination issues or resolve disputes.
• Customer Support Data – Support tickets and correspondence: up to 24 months from the date of ticket closure, to resolve follow-up inquiries, track service quality, and defend against potential legal claims. Chat transcripts: up to 24 months, for quality assurance and staff training purposes.
• Usage Data – Application usage statistics: up to 24 months, to understand feature adoption and service improvements. Server logs (IP addresses, access times): up to 24 months, for security monitoring and troubleshooting purposes.
• Camera Event Media – recorded video clips, snapshots, and thumbnails: retained according to the user's selected cloud storage plan or local device storage capacity, as described under "Camera Media and Event Content" above. Users may delete this content at any time.

As described above, no face or biometric data is retained by the Company at any time, as none is collected.

We may retain Personal Data beyond the periods stated above for the following reasons:

• Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
• Legal claims: Data is necessary to establish, exercise, or defend legal claims.
• Your explicit request: You ask Us to retain specific information.
• Technical limitations: Data exists in backup systems that are scheduled for routine deletion.

You may request information about how long We will retain Your Personal Data by contacting Us.

When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:

• Deletion: Personal Data is removed from Our systems and no longer actively processed.
• Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
• Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.

Data Retention and Deletion

Vivoo Eye retains account and service-related information only for as long as necessary to provide the requested services, comply with legal obligations, resolve disputes, and enforce agreements.

Camera event media and recordings are retained according to the applicable device storage, cloud storage, recording retention, and user deletion settings associated with the camera service.

Vivoo Eye does not retain biometric face data because it does not collect biometric face data.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy, and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if You have one, and visiting the account settings section that allows You to manage Your personal information. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.

Please note, however, that We may need to retain certain information when We have a legal obligation or lawful basis to do so.

Your Privacy Rights

Depending on applicable law, You may have the right to access, correct, restrict, or object to the processing of Your Personal Data, and to withdraw consent at any time where processing is based on consent. To exercise these rights, please contact Us using the details in "Contact Us" below.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Because the Designated Hardware may be installed by Users in locations where children could be present, Users are responsible for ensuring that any use of the camera's recording features complies with applicable law regarding the privacy of minors, including obtaining any consent required from a parent or guardian of a minor who may be recorded.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective, and update the date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of Vietnam, without regard to its conflict of law provisions.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: contact@vivooeye.com