[V4.0]

updated date:【August 13, 2024】

effective date:【August 20, 2024】

Arashi Vision Inc. (the “Insta360”, “us” “our” or “we”) and its affiliates understand the importance of your privacy to you and will respect your privacy. The Insta360 Privacy Policy ("this Policy") applies to the products and services that we provide and the extensions thereof, including various products and services that we provide to you through the Insta360 APP, our official website, our client, app and new forms emerging with technology ("our Platform"). If a separate privacy policy or user service agreement exists for a specific product or service, the privacy policy or user service agreement for that product or service will prevail. If the privacy policy or user service agreement for the product or service is not covered by such product or service, this Policy shall prevail. If one of our affiliated companies uses the products or services provided by us in their products or services but does not set up a separate privacy policy, this Policy shall also apply to such products or services. Unless otherwise agreed, the terms used in this Policy shall have the same meaning as those defined in the Insta360 User Service Agreement.

If you are a minor or a person without full capacity (“minor” or “minors”)under the laws of the jurisdiction in which you reside, please carefully read and fully understand this Policy in the company of your legal guardian and use Insta360 products and services after obtaining the consent of your legal guardian.

Please read this Policy carefully (especially the bolded content) and make sure you understand our rules for processing your personal information. We will process your personal information appropriately based on lawful and legitimate means and in good faith, in accordance with current laws and regulations. If you have any questions about this Policy, you can contact us through the contact information posted on our Platform.

This Policy contains:

1.How we collect and use your personal information

2.How we use cookies and similar technologies

3.How we share, transfer, and disclose your personal information

4.How we protect and store your personal information

5.How you manage your personal information

6.How your personal information is transferred globally

7.Protection of personal information of minors

8.Marketing and "Do Not Track ("DNT")" signals

9.Special rules for California residents: Do Not Sell My Personal Information

10.Special rules for Singapore users: Do Not Call

11.Notification and Revision

12.How to contact us

1. How we collect and use your personal information

Personal information is all kinds of information relating to an identified or identifiable natural person, recorded electronically or by other means, excluding information that has been anonymized. Please note that the definition of "personal information" (or "personal data" and other similar expressions) may vary from country to country or region to region, so please refer to the laws and regulations related to the protection of personal information in your region.

We collect and use personal information that you voluntarily provide in the course of using the products and services or as a result of using the products and services, and obtain personal information about you from third parties for the purposes described in this Policy, in accordance with the principles of legitimacy, legality and necessity. If we want to use your personal information for purposes other than those described in this Policy, or use the information collected for a specific purpose for other purposes, we will inform you in a reasonable manner and obtain your consent again before using it.

*If you are a resident of Singapore, the following information is not "personal information" for the purposes of this Policy:

⦁ "Business contact information", i.e., "an individual's name, job title, business e-mail address or business fax number, and any other similar information about the individual that is not provided by the individual solely for his or her personal purposes".

⦁ Personal data contained in records that have been in existence for at least 100 years;

Personal data of deceased individuals who have been dead for more than 10 years.

1.1 Information we collect

When you use our products/services, we need to collect and use your personal information as follows:

1.1.1 Registration and Login

When you register and login to your account on our Platform via your email address, we need to collect your email address and password. During registration, we will verify your identity by sending a verification code to your email address to confirm your identity. After registering your account, you can choose to provide your nickname, picture, gender, date of birth, location, profile description, background picture. If you refuse to provide the above information, it will not affect your use of our Platform to register an account.

You can use a third party account (including WeChat, Facebook, Apple, google and other accounts) to log into our Platform, we will collect your information on third-party platforms (public information, such as profile photo, nickname and other information provided by you), used to generate and access our Platform account, so that you can directly register, log in and use our Platform and related services.

1.1.2 Purchasing our products.

Online Shopping. When you choose to shop in our Online Stores, in order to ensure the safe delivery of your purchase, we need to collect your name, phone number, address, bank card information (if you choose to pay by credit card), invoice information (if you choose to invoice). If you choose to shop in "Guest Mode", we will also need to collect your email address.

Shopping in retail stores. When you choose to shop in our retail stores, in order to match the retail stores in your area, we need to collect your location.

Official Store Reviews. When you choose to upload a consumer review on our Official Store, please note that your nickname will not be anonymized or de-identified, so if you are reviewing under your real name, we may need to collect your name.

1.1.3 Marketing

When you choose to participate in the activities held by us or subscribe to our event information, in order to timely push the event information to you or get in touch with you, we will collect your name, phone number or email address, home address, survey content, etc. on the basis of your consent, you can unsubscribe by contacting us.

1.1.4 Service & Support

Purchase of Insta360Care & Extended Warranty. When you need to purchase or activate Insta360Care or extended warranty service, we need to collect your product serial number, product purchase information, Insta360Care card number, password and agreement number to match it with your purchase.

After-sales service application. When you apply for after-sales service, in order to match you with the nearest repairer and more accurately determine the problem and provide repair service, we need to collect your location, product serial number, product purchase information, problem description, Insta360 Care agreement number (if you have purchased Insta360 Care), Insta360 extended warranty agreement number (if you have purchased Insta360 Extended Warranty), pickup and delivery address. If you apply for our Online Repair service, we need to collect your name, phone number, email address, return address, product serial number, fault condition, date of purchase of product, etc.

Report bugs and provide suggestions. When you need to report bugs and provide suggestions to us, in order to contact you, we need to collect information about the problem you need to give feedback on (such as product category, problem type, recurrence steps, recurrence probability, whether you can recover it, etc.) and your name, phone number or email address.

Customer Service. When you contact us through our Platform, by email or in any written form, in order to resolve your issue, we need to collect a record of the communication between you and customer service.

1.1.5 Upload your work

Insta360 Awards. When you participate in our call for submissions with prizes (including but not limited to Insta360 Awards, #NoDroneNoProblem Awards, Shot Lab Challenge, Tiny Planet Challenge, FlashCut Challenge, collectively, “Insta360 Awards”) , in order to confirm that your uploaded work is made by our products and to contact you in a timely manner, we need to collect your submission type, camera type, name, email address, content of your work (which may include your portrait, voice and other personal information, etc.), title, description of your work, date of creation, time of creation, geographical location, etc.

Rising Talents. When you participate in our Rising Talents program, in order to confirm that your uploaded content is made by our products and to contact you in a timely manner we need to collect your Name, Email address, Links to users' social platforms (IG, TT, and/or, YT Shorts) ,Verticals, and Submission content (local upload or social link that could include personal image, voice, content location, creation time and date, etc.)

Other submission. When you choose to upload your text, image and video works (including public post, private post and save into draft box) to our Platform, in order to manage and recommend your work, we need to collect your nickname, profile picture, content you published or to be published, as well as information of device you are using to create the content, the time of creation, and the location.

Issuance of campaign rewards. When you receive our campaign rewards, in order to issue the rewards to you, we need to collect your Paypal account number, Paypal email, name and country.

AIGC function and relevant services. When you use “AI Warp” function and relevant services provided by our Platform, you will need to upload your original pictures or videos(hereinafter referred to as “Original Content”) to the server so that we can generate a new pictures or videos through the AI model for you to download and save to your device. The uploading and processing of Original Content are necessary for providing the services. We need to collect the characteristic information contains in the Original Content you uploaded(e.g., landscape, food, portrait, etc.) which is or will be de-identified, and analyze the characteristic information through algorithms in order to help you get better processing results. We will notify you and obtain your express consent when you use the function for the first time; if you refuse, you will not be able to use this function and relevant services; if you agree, we will take strict encryption measures during the transfer, analysis, processing, sharing and temporary storage of the Original Content you upload as required by applicable laws and relevant rules to ensure the security of the Original Content. The use of the Original Content is limited to providing you with AI-Generated Content services, where we only provide processing services based on the AI model for your Original Content according to your prompt. Please be aware and assured: the Original Content you upload to the server will only be stored in the server temporarily, so that we can provide the processing services for you; and once the service is finished, the Original Content will be deleted automatically by the system. During the process, we will not extract any personal identifiable information or use the information for any identification purposes.

1.1.6 Become our partners

Become a reseller. When you apply to be a reseller, in order to qualify you and contact you, we need to collect your name, position, phone number, email address, company information (including company name, registered name, address, type of stores or websites), cooperation type (including products and cooperation intention).

Become an Affiliate. When you apply to be an Affiliate, in order to contact you and match you with promotional activities suitable for you, we need to collect your name, phone number, email address, location, company, position, access to Affiliate Program and promotion strategies. If we are required to pay you a commission, we will also need to collect information about your receipt of payment. The information we collect may vary depending on the payment method you choose. You can choose from the following four payment methods, which correspond to the personal information collected as follows:

Payment Methods	Types of Personal Information Collected
Overseas banking information	1. Name of the payee 2. Bank account number (European banks need to provide IBAN) 3. Name of the bank where the account is opened 4. Bank address 5. Recipient's address 6. SWIFT Code
Domestic bank informatio	1. Name of the bank where the account is opened (accurate to the branch) 2. Bank account number 3. Recipient's name 4. Union bank number 5. Individual income tax information: name, gender, document type, document number, nationality, place of birth, date of birth, cell phone number, whether disabled or not, whether martyrs or not (when the remittance amount is more than 800, users are required to provide)
Alipay	1. Alipay account 2. Recipient's name 3. Individual income tax information: name, gender, document type, document number, nationality, place of birth, date of birth, cell phone number, whether or not disabled, whether or not a martyr (remittance amount of more than 800 need to be provided by the user)
PayPal	PayPal account

SDK Application. When you submit an SDK application to us, in order to contact you, we need to collect your product information (including product model, serial number of your device), user type, name, location, contact information and reason (s) for applying the SDK.

1.1.7 Enhance or optimize our services

Access our Platform by mobile electronics (including APP, WeChat mini program, etc.).In order to enhance or optimize our services, we may read the information of your device, such as device model, device identifier, operating system, screen resolution, telecom operators, Android ID, Android SD card data etc.

Accessing our Platform by computers. To enhance or optimize our services, we automatically receive and record information on your browser and computer, such as your Media Access Control (MAC) address, GPS address, screen resolution, operating system and its version, device manufacturer and its model, language, Internet browser and its version, the name of the software you are using and its version and the time it was taken.

Content you upload through our Platform. To enhance or optimize our services, we may collect information you upload, such as the date, time, and location of shared photos or videos taken or uploaded.

1.1.8 Provide basic services and improve security

When you use our products or services, we need to collect information such as Log files generated when you use our products and services.

When you submit information using our Platform, we need to collect information such as the status of your WI-FI connection and the serial number of your hardware.

When you access our web pages from your computer or access our mobile web pages from your mobile phone, download or use our or our affiliates' client software to use our services, we may read information related to your device, such as media access control (MAC) address, browser name and version, language, location device manufacturer and model, device identifier, operating system, resolution, telecom operators, etc.

To improve the security of your use of our services and to more accurately prevent phishing site scams and Trojan horses, we may determine the risk of your account by knowing some of your Internet usage habits, your user behavior data, user's device information, URL access records (e.g. device terminal type, device terminal screen resolution, device network operator, etc.) and may record URLs that we consider risky.

1.1.9 Any other information you send us in addition to the above.

1.2 Device permission

To collect the above, we may need you to turn on your device access to us in your device:

Permission Name	Type of System Involved	Purpose of permission
Network	IOS/ Android	Control and Manage Cameras
Bluetooth	IOS/ Android	Connect and Control Cameras
Album	IOS/ Android	Download and Export Files from Cameras
Local Network	IOS/ Android	Search for Nearby Cameras
Notification	IOS/ Android	Receive timely APP Alerts
Location	WeChat mini program	Get Location to fill in User Address
Alerts	Website/Online stores	Marketing
Personalized Recommendations	IOS/ Android	Marketing
Storage	IOS/ Android	Connect and control the camera

1.3 How we use the information we collect

We strictly abide by the provisions of laws and regulations and the agreements with users under this Policy to use the information collected for the following purposes. If we intend to use your information for purposes beyond those listed below, we will explain this to you and obtain your consent in advance.

a)To review and approve the user's account registration application.

b)To provide users with the basic service features of the services and software and hardware of our Platform used.

c)To make improved products or offer superior service by analyzing log files we collected.

d)To approve your application and to respond to your queries.

e)To send you relevant information, such as changes to our Policy terms, conditions and policies regarding the services.

f)To completing surveys about our products or related services, or promotions and campaigns that you have chosen to participate in.

g)To facilitating social sharing features.

h)To provide you with personalized service.

i)To provide you with relevant information about our products and services or the products or services of our affiliates or other third parties, and to push seminars or interest groups related to products and services to you.

j)To prevent, detect, and investigate fraud, security hazards, illegal or violations of agreements, policies or rules with us or our affiliates in order to protect the legal rights of you, our other users, or us or our affiliates.

k)We may use, share or disclose information from one service in combination with information from other services for the purpose of providing you with a more personalized use of the service, such as the need to give you a broader social circle.

l)For auditing, developing new products, analyzing usage trends, improving operational efficiency and promoting promotional purposes.

m)Other uses for which we have your consent.

With your opt-in, we may use the foregoing information to push you ads that may be of interest to you, such as pushing you information about our products and services. If you do not wish to receive such information, you may unsubscribe by replying to the email or by switching off “Product promotions” in App settings > Notifications to unsubscribe from push notifications.

1.4 Exceptions to the collection and use of personal information

You understand and agree that we have the right to collect and use your personal information without your consent in the following circumstances.

a) Processing is necessary for the performance of a contract to which you are party or in order to take steps at the request of you prior to entering into a contract;

b) Processing is necessary for compliance with a legal obligation to which we are subject;

c) Processing is necessary in order to protect the vital interests of you or of another natural person;

d) Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

e) Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you which require protection of personal data.

f) Other circumstances which are allowed by applicable laws.

1.5 Rules for the use of the information we collect

1.5.1 We will use the personal information collected for the purposes set out in this Policy and for the purpose of carrying out the features of our services.

1.5.2 After collecting your personal information, we will de-identify the information through technical means, and the de-identified information will not identify the subject. Please understand and agree that information obtained through the foregoing activities will be treated by us as non-personal information, unless otherwise required by applicable laws and regulations. We may provide our partners with aggregate information obtained on the basis of de-identified information about how users use and viewpoints provided through the Software so that our partners have an understanding of the frequency, volume and activities of users using the Software. For the avoidance of doubt, under this section, we will only use the information for lawful purposes and the aggregate information provided to our partners will not indicate any specific user. We may also use or share with third parties for lawful purposes any information that we have collected in the aggregate or that is not identifiable.

1.5.3 Please understand and agree that for all personal information you provide while using our products and/or services, unless you delete or reject our collection through system settings, you will be deemed to have continuously authorized consent to our use for the duration of your use of our products and/or services. After you cancel your account, we will stop using and delete your personal information, except as otherwise provided by law or regulation. To cancel your account, navigate to the official website, click My Account > Change Password > Delete My Account or through the Insta360 App, go to App Settings > Personal > Edit Information > Delete Account.

1.5.4 We will seek your prior consent when we want to use your personal information for purposes other than those stated in this Policy, or when personal information collected for a specific purpose is used for other purposes. Please understand that the products and/or Platform services we provide to you are subject to change from time to time. If you choose to use other products and/or services not listed in this Policy, we will provide you with a detailed explanation of the purpose, manner and scope of collection and seek your consent through agreements, page prompts and other means before collecting your personal information. If you do not agree to provide the aforementioned information, you may not be able to use the product and/or service, but it will not affect your use of existing products and/or services.

2. Cookies and similar technologies we use

To make your visit easier, Insta360 may identify you through small data files when you visit our Platform or use our Platform Services in order to eliminate the need for you to repeatedly enter registration information or to help estimate the security of your account. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively, "Cookies"). The cookies technology used by Insta360 does not capture personal email addresses or any personal information.

Cookies are used primarily to enhance your experience when visiting our Platform or using our Platform Services, to provide you with customized display options, to provide statistical reports on web activity, or to secure software and website security requirements. We also use cookies to preload relevant content.

When you first visit our Platform or use our Platform services, if you agree to our use of Cookies in accordance with the terms of this Policy, you are allowing us to use Cookies each time you visit or use thereafter. you can disable Cookies by configuring your browser, or by alerting you when a website uses Cookies. However, if you disable Cookies, you may not be able to use the features or services of our Platform properly.

For more information regarding how we use cookies, please refer to our Cookie Policy.

3.How we share, transfer, and disclose your personal information

3.1 Sharing of personal information

Our affiliates, partners or other third parties may share your personal information with us for the purpose of providing you with better, more optimal and personalized services, or jointly providing services to you, or for the purpose of preventing Internet fraud, as required by law or as agreed with you or with your consent. Please be aware that you have the right to refuse to consent to the sharing of your personal information with third parties, and that if you refuse to consent to the sharing of information with third parties, you may not be able to use the corresponding features. We will not share your personal information with third parties except in the following circumstances:

3.1.1 Obtain your prior consent or authorization;

3.1.2 In accordance with laws and regulations, administrative and judicial mandatory requirements;

3.1.3 To the extent permitted by law or regulation, as necessary to protect our affiliates or partners, you or other users or the public from harm to their interests, property or safety;

3.1.4 Enable the core functions of our products and/or services or to provide the services you require;

3.1.5 Handling disputes or controversies between you and others for you at your request;

3.1.6 in accordance with the relevant agreement with you (including the electronic agreement signed online and the corresponding platform rules) or other legal documents agreed to be provided;

3.1.7 Based on academic research;

3.1.8 Based on the public interest of society in accordance with laws and regulations, public health emergencies and use.

Please note that any information (including personal information) you upload to the public areas of our Platform may be seen, collected and used by other visitors. You are solely responsible for any personal information you choose to upload to the public areas of our Platform.

Please note that we will only share your personal information with third parties (as shown on the page) as necessary to achieve the purposes described in Section 1 of this Policy. At the same time, we will only share personal information that is necessary to provide our products and services, and we will enter into strict confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.

For details of the circumstances under which we share personal information with third parties are as follows, please refer to “I.List of personal information shared with Third parties” of “List of Personal Information Shared”

3.2 outsourcing

In order to improve efficiency and reduce costs, we may outsource third-party professional service providers to process your personal information on our behalf, for example, we may hire professional service providers to provide storage services, online customer service, etc. For the companies, organizations and individuals we outsource to process personal information, we will require them to comply with strict confidentiality obligations and take effective confidentiality measures through written agreements, on-site audits, etc., and require them toprocess your personal information only within the agreed scope of the contract, and not to use your personal information for their own benefit. We currently outsource third parties with the processing of your personal information as follows:

Oursourcee	Types of information outsourced to be processed	The purpose of outsourcing
Ali cloud	Images, videos, database data	Provide data storage services
Udesk	Images, videos, database data	Provide domestic online customer service
Intercom	user emails, chat records	Provide foreign online customer service
zendesk	user emails, chat records	Provide foreign online customer service

3.3 Transfer of personal information

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

a)Obtain your prior consent or authorization;

b)provided in accordance with the relevant agreement or other legal document signed with you;

c)In the event of a merger, acquisition, transfer of assets, liquidation or similar situation involving the transfer of personal information, you understand and agree that your personal information will be transferred to the relevant third party company or organization. We may require the new company or organization holding your personal information to continue to be bound by this Policy, or we may require that company or organization to seek your authorized consent again.

3.4 Disclosure of personal information

We will only disclose your personal information if we take security measures that are consistent with industry standards and if:

a)After obtaining your consent;

b)In the case of laws and regulations, legal proceedings, litigation or mandatory requirements by government authorities.

3.5 Third-party plug-in/SDK access

In order to provide and optimize our products and/or services, third party plug-ins/SDKs are embedded in the Platform, and these third party plug-ins/SDKs may collect your personal information while cooperating with us to provide you with more comprehensive services. We will take necessary measures to control the collection and use of your personal information by such third-party plug-ins/SDKs to ensure that your personal information is effectively protected. Please refer “II.List of personal information shared with third-party SDKs/APIs” of “List of Personal Information Shared”.

4.How we protect and store your personal information

4.1 How long we store your personal information

We will only store your personal information for as long as necessary for the purposes described in this Policy and for as long as required by law, regulation and supervision, unless there is a mandatory retention requirement by law.

If we terminate the service or operation, we will promptly stop the activities of continuing to collect your personal information, and at the same time will comply with the requirements of relevant laws and regulations to notify you in advance, and delete or anonymize your personal information after the termination of the service or operation, unless otherwise provided by laws, regulations or regulatory authorities.

4.2 Where we store your personal information

Currently, we use AliCloud database (Hong Kong) to store your personal information. This means that your personal information may be transferred to, or accessed by, countries or regions other than your place of residence. These countries or regions may have different regulations on the protection of personal information, or even no corresponding regulations on the protection o f personal information. In such cases, we will make every effort to ensure that your personal information is adequately protected in accordance with this Policy. We will strictly follow the laws and regulations of your location and the regulations of the relevant regulatory authorities, and fulfill our obligations under the laws and regulations, such as explaining to you the purpose of the departure of personal information and the type of personal information involved, and requesting the overseas organizations to keep your personal information obtained confidential through effective measures such as signing agreements and on-site verification.

4.3 How we protect your information

We have taken reasonable and practicable security measures, consistent with industry standards, to protect your information from unauthorized access, disclosure, use, modification, damage or loss of personal information. We take the following steps to keep your data secure:

a)Using encryption technology to improve the security of personal information, protected by SSL protocol encryption when exchanging data between your browser and the server, providing HTTPS protocol for secure browsing;

b)Use of trusted protection mechanisms to prevent malicious attacks on personal information;

c)Deploy access control mechanisms and make every effort to ensure that only authorized personnel have access to personal information;

d)Conducting security and privacy training courses to enhance employees' awareness of the importance of protecting personal information;

e)Specialized data compliance management systems, processes and organizations are in place to safeguard information. For example, we strictly limit the scope of people who access information, require them to comply with confidentiality obligations, and conduct audits.

We will take all reasonably practicable steps to ensure that no unrelated personal information is collected. We will retain your personal information only for the shortest period necessary to achieve the purposes described in this Policy, unless otherwise required by the laws and regulations of your location.

The Internet environment is not 100% secure and we will endeavor to ensure or warrant the security of any information you send us. If our physical, technical, or administrative safeguards are compromised, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legal rights and interests, we will assume appropriate legal liability. After the unfortunate occurrence of personal information security events, we will strictly follow the requirements of the laws and regulations of your location and inform you in a timely manner of: the basic situation and possible impact of the security event, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the disposal of personal information security incidents and fulfill the obligations stipulated in other laws and regulations in accordance with the requirements of regulatory authorities.

5. How you manage your personal information

In accordance with the relevant laws, regulations and standards of, as well as the prevailing practices in other countries and regions, we protect your right to exercise the following rights with respect to your personal information. Please note, however, that we may not be able to respond to your request for personal information rights if the relevant personal information you have requested has exceeded the minimum period necessary to achieve the purposes described in this policy or has been deleted. The personal information rights you may exercise include:

5.1 Right to Access to personal information

You have the right to access your personal information as provided by law and regulation. If you wish to access and edit your personal information in your account, you may do so by logging into your account on our website or App and accessing the relevant pages for personal information, changing your password, changing your email address, etc.

5.2 Right to correct your information

If you discover that we have processed your personal information incorrectly, you have the right to request that we make corrections. You may contact us at any time through the contact information provided on the website or in the App, or send email to service@insta360.com.

5.3 Right to delete personal information

You may make a request to us to delete personal information in the following cases, unless otherwise provided by law or regulation:

a)We collect and use personal information in violation of laws and regulations;

b)Our processing of personal information is in breach of the agreement with you;

c)We collect and process your personal information without your consent;

d)You no longer use our products or services, or you cancel your account;

e)We no longer provide products or services to you.

If we decide to respond to your request for deletion, we will also simultaneously notify the entities(if any) from which we obtained your personal information to request its prompt deletion, unless otherwise required by law or regulation, or unless such entities have your independent authorization. When you delete information from our Platform, we may not immediately delete the corresponding information from our backup systems, but will delete it when the backup is updated.

5.4 Cancellation of accounts

You may cancel your previously registered account through the means set forth in our Platform or by contacting Customer Service. When you contact our customer service to cancel, we will complete your request within 15 business days; after canceling your account, we will stop providing you with products or services and delete your personal information upon your request, except as otherwise provided by laws and regulations. For details, please refer to the "Account Cancellation Instructions".

5.5 Right to portability of personal information

You have the right to obtain a copy of your personal information and you can do so at any time by contacting our customer service and we will respond to your request within 15 business days. Provided that it is technically feasible for us to do so, for example by matching data interfaces, we can also transfer a copy of your personal information directly to the third party you specify at your request.

5.6 Stop automated decision making

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

5.7 The right to restrict the processing of personal information

You may limit our processing of your personal information in the following circumstances.

a) when you question the accuracy of the personal information we have collected about you, or when we are verifying the accuracy of the personal information in question

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

c)when we no longer need your personal information in question for the processing purposes set out in this Policy, but you need that personal information for legal claims.

d)when the legal basis for processing your personal information is in the public interest, or in the legitimate interests of us and third parties.

5.8 Right to object to personal information

You have the right to object at any time to our processing of your personal information for direct marketing purposes, as well as the right to object to automated decision-making, including analysis that has legal effect or significant impact on you. You have the right to adjust the scope of the personal information we continue to collect or withdraw your authorization at any time, and when you withdraw such consent or authorization, we will no longer process the corresponding personal information and will not be able to continue to provide you with the services for which you have withdrawn your consent or authorization. Your adjustment of the scope of your authorization will not affect the processing of your personal information by Insta360 based on your consent or authorization prior to the adjustment.

5.9 Respond to the above request

If you are unable to fulfill your rights as described above, or if you believe that Insta360 has violated any laws, administrative regulations, or agreements with you regarding the processing of your personal information, you may contact us through the channels set forth in this Policy. For security purposes, you may be required to provide a written request or otherwise prove your identity. We may first ask you to verify your identity and process your request within the period specified by the laws and regulations of your region .In principle, we do not charge any fees for your reasonable requests, but we will charge a cost fee for repeated requests that exceed reasonable limits, as appropriate. We may refuse requests that are unwarrantedly repetitive, require excessive technical means (requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are impractical (involving backups of information stored on tapes).

In the following cases, according to the laws and regulations, we cannot respond to your request:

a)directly related to national security or national defense security.

b)directly related to public safety, public health, and significant public interests.

c)directly related to crime investigation, prosecution, trial and execution of judgments, etc.

d)where there is sufficient evidence that you have subjective malice or abuse of rights.

e)where responding to your request will result in serious damage to the legitimate rights and interests of you or other individuals or organizations.

f)where trade secrets are involved.

If we respond to your request for deletion, we will also notify the entities from which we obtained your personal information and request that they delete the corresponding information in a timely manner, unless otherwise provided by law or regulation or unless these entities have your independent authorization.

*If you are a Hong Kong resident, in principle, we will respond to your request for access within 40 days, unless:

a)The request is neither made in writing in Chinese nor in writing in English;

b)You have not provided us with information that is reasonably necessary to respond to the request, etc.

If you are a Hong Kong resident, in principle we will respond to your request for correction within 40 days of unless: a)We are unable to determine your identity;

b)The request is neither made in writing in Chinese nor in writing in English;

c)We are unable to determine whether the correction request is accurate/confident that the correction request is inaccurate, etc.

6.How your personal information is transferred globally

Currently, we use AliCloud database (Hong Kong) to store your personal information. This means that your personal information may be transferred to, or accessed by, countries or regions other than your place of residence. These countries or regions may have different regulations on the protection of personal information, or even no corresponding regulations on the protection of personal information. In such cases, we will make every effort to ensure that your personal information is adequately protected in accordance with this Policy. We will strictly follow the laws and regulations of your location and the regulations of the relevant regulatory authorities, and fulfill our obligations under the laws and regulations, such as explaining to you the purpose of the outbound of personal information and the type of personal information involved, and requesting the overseas organizations to keep your personal information obtained confidential through effective measures such as signing agreements and on-site verification.

7. Protection of minors’ personal information

We do not knowingly collect personal information from minors. Minors may not register for an account on our Platform or send us personal information such as their names, address, phone numbers, email address, etc., unless permitted by local law and their guardians have given their consent. We will only use or publicly disclose personal information collected from minors with the consent of their guardians as permitted by law, with the consent of the guardian, or as necessary to protect the minor.

If we become aware that we have collected personal information from a minor without the consent of the minor's guardian, we will delete the data as soon as we are aware of it. If you believe that we may improperly hold personal information from or about a minor, please contact us.

8. Marketing and "Do Not Track ("DNT")" signals

We do not track its Users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third- party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

9. Special rules for California residents: Do Not Sell My Personal Information

California Consumers have the right to opt-out of the “sale” of your Personal Information for monetary or other valuable consideration. If you are a California Consumer and would like exercise your Right to Opt-Out of Sale or Sharing, please submit your request at https://store.insta360.com/ by pressing Do Not Sell or Share My Personal Information button at the bottom of the page.

10. Special rules for Singapore residents: Do Not Call

If you are a resident of Singapore, you have the right to apply the Do Not Call rules, which means that if you do not wish to receive the telemarketing messages via phone call, SMS or fax, you can register your Singapore telephone numbers with the DNC(Do Not Call) Registry. You can remove your number form the DNC Registry whenever you want.

11. Notification and Revision

This Policy may be updated to provide you with better service and as our business evolves. However, we will not reduce your rights under this Policy without your consent. We will notify you of updates to this Policy by posting updated versions on our website and mobile devices and by appropriate means before they become effective, and we invite you to visit our Platform to keep up to date with the latest Privacy Policy.

We will also provide more prominent notice of material changes (we will provide specific notice of changes to our Policy, including, but not limited to, a special notice on the viewing page).

Material changes within the meaning of this Policy include, but are not limited to:

a)Significant changes in our service model,such as the purpose of processing personal information, the type of personal information processed, and the way personal information is used;

b)Significant changes in our ownership structure, organizational structure, etc. such as changes in ownership due to business restructuring, bankruptcy and mergers, etc;

c)Changes in the primary recipients of personal information sharing, transfer or public disclosure;

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

e)In the event of a change in the department responsible for handling the security of personal information, our contact information and complaint channels;

f)When the personal information security impact assessment report indicates a high risk.

We will also keep an older version of this Policy on file for your review.

12. How to contact us

If you have any questions, comments or complaints about our Privacy Policy, or wish to contact us, please do so as follows:

Specific issues related to the software or the user's personal account (including access to one's own personal information), please e-mail us at service@insta360.com.

For general inquiries or complaints about privacy issues, please e-mail us at service@insta360.com or write to us at the following address: 12F, Building T2, Everest Qianhai Financial Center, Nanshan District, Shenzhen, Guangdong Province, China, post code: 518000.

If you are not satisfied with our response, especially if our processing of personal information has harmed your legitimate rights and interests, you may also file a complaint or report to the regulatory authority in your area.

This version of the Privacy Policy was updated on【13, August】2024, and will become effective on【20, August】2024. Click to review older versions of the Privacy Policy.