Last Updated: July 1, 2026

Effective Date: July 1, 2026

Version: V1.0

 

Zhejiang Sunny Intelligence Technology Co., Ltd. (Registered Address: No. 67-69 Fengle Road, Yangming Subdistrict, Yuyao City, Ningbo, Zhejiang Province; Contact Information: [Please provide official customer service phone number/email address]; hereinafter referred to as “we”) is the operator of the in-vehicle camera module. We place great importance on protecting the personal information and privacy of our users (hereinafter referred to as “you”). When you use the in-vehicle camera module, we will process your relevant personal information. To fully explain how we process your personal information, we have formulated the “In-Vehicle Camera Module Privacy Policy” (hereinafter referred to as “this Privacy Policy” or “this Policy”), and we commit to processing your personal information strictly in accordance with this Privacy Policy.

 

We hereby remind you:

This Privacy Policy applies to information collected in connection with the products or services (collectively, the “Services”) we provide to you through the in-vehicle camera module hardware and related services (including, but not limited to, the accompanying app, official WeChat account, mini-program, official website, Quick Apps, and new formats that may emerge with technological advancements). If a specific service within the in-vehicle camera module has separate personal information processing rules, those separate rules shall take precedence; for matters not covered by such rules, this Privacy Policy shall apply. However, this Policy does not apply to information collected by third parties integrated with the in-vehicle camera module; if you use services provided by third parties, you will be subject to their privacy policies (rather than this Policy).

 

This Privacy Policy will help you understand the following:

I. How We Collect Your Personal Information

II. How We Use Your Personal Information

III. How We Store Your Personal Information

IV. How We Outsource the Processing, Provide to Third Parties, Transfer, and Disclose Your Personal Information

V. How We Protect Your Personal Information

VI. How You Can Manage Your Personal Information

VII. How We Handle Information Regarding Minors

VIII. How This Privacy Policy Is Updated

IX. How to Contact Us

 

 I. How We Collect Your Personal Information

(1) Scenarios in Which We Collect Personal Information

While you are using the in-vehicle camera module, we will collect your personal information in the following ways:

 

1. **Registration and Login**

When you register for an account for the in-vehicle camera module support services, you are required to provide us with your mobile phone number, login password, and [other data types]. We collect this information to help you complete the registration of your in-vehicle camera module service account and to protect the security of your account. If you do not provide this information, we will be unable to create an account for you or provide the services to you as intended.

 

When you use a third-party account (such as a WeChat account) to log in to the in-vehicle camera module support services, we will collect your nickname and [other data types] through that third party. If you do not provide this information, you will not be able to register for or log in to the in-vehicle camera module support services using a third-party account.

 

When you update your personal profile on [Page Name], you may provide your [Data Type]. We collect the above information to help you complete your personal profile; if you choose not to provide this information, it will not affect your use of the basic functions of the in-vehicle camera module.

 

2. **[Service Name]**

When you use [Service Name], [you need to provide us with / we need to collect / we need to collect through a third party] your [Data Type]. We collect the aforementioned information for [Purpose of Data Use]. If we do not collect this information, we will [Reason] [be unable to provide the service to you normally / be unable to provide you with the [Service Name] service, but this will not affect your normal use of our other services].

 

You may also enable 【Device Permission Name, such as Photo Album Permission】 on your device, in which case we will collect your 【Data Type】. We collect the aforementioned information for 【Purpose of Data Use】. If we do not collect this information, we will be 【Reason】 【unable to provide the service to you as intended/unable to provide the 【Service Name】 service to you, though this will not affect your normal use of our other services】.

 

……

 

3. **Ensuring the Security and Stability of Our Network and Services**

To ensure the secure and stable operation of our network and services, we collect your unique device identifier, the serial number of your in-vehicle camera module, IP address, date and time of access, and [other data types]. We collect the aforementioned information to ensure your security and stability when accessing our network, to prevent and mitigate security risks while you use our services, and to ensure the stable operation of network access, products, and services. If you do not provide the aforementioned information, we cannot guarantee the secure operation of the application during your use.

 

4. **Customer Service**

When you submit a complaint, suggestion, or issue report to us, in order to facilitate communication with you, assist you in resolving the issue as quickly as possible, or record the resolution plan and outcome of the relevant issue, we may collect your communication or call records with us, the account information you provide, the contact information you provide, information you provide to substantiate relevant facts, in-vehicle camera module device error logs, and [other data types]. If you do not provide this information, your complaints, suggestions, and feedback may not be addressed in a timely and effective manner; however, this will not affect your normal use of our other services.

 

 (II) Use of Device Permissions

In the course of providing products and/or services to you, we may need to access system permissions on your in-vehicle terminal and associated mobile devices. You can review the “Device System Permission Guide” to learn more about the names of the device permissions we access, descriptions of their functions, and details regarding their usage scenarios or purposes.

 

1. **iOS System Permission Guide**

Permission Name: NSCameraUsageDescription (Camera)

Permission Function Description: Scanning QR codes, taking photos, AR interactions, or augmented reality shopping

Usage Scenarios or Purpose: To enable video recording, photo taking, QR code scanning, and facial recognition login

Prompt: A pop-up window will appear asking for permission before the user uses the corresponding service

Can It Be Disabled: Yes

Consequences of Disabling the Permission: The user will be unable to use video recording, photo taking, QR code scanning, and facial recognition login features

 

……

 

2. **Explanation of Android System Permissions**

Permission Name: android.permission.ACCESS_FINE_LOCATION (Precise Location)

Permission Description: Retrieves your current geographic location

Use Case or Purpose: To provide you with region-specific services for the in-vehicle camera module and to pinpoint device malfunction locations

Prompt Required: A pop-up window will appear asking for permission before you use the corresponding services

Can Be Disabled: Yes

Consequences of Disabling the Permission: We will be unable to provide you with region-specific services or precise location-based device diagnostic services

……

 

If you wish to disable all or some of the device permissions after enabling them, you can do so in your device’s settings. You can also do this through “[Permission Settings Path]” in the in-vehicle camera module’s companion service. Once you disable any device permission, we will no longer be able to collect and use your relevant personal information based on that permission, and we may consequently be unable to provide you with the services associated with that permission. Please note that your decision to disable a permission will not affect the collection and use of information that occurred previously based on your consent.

 

(3) How We Use Cookies and Similar Technologies

1. **Use of Cookies**

(1) To ensure the proper functioning of our official website, to provide you with a more convenient browsing experience, or to recommend services related to in-vehicle camera modules that may interest you, we may store cookies, Flash cookies, or other local storage provided by your browser (or associated applications)—which typically contain identifiers, site names, and certain numbers and characters—on your computer or mobile device (collectively referred to as “Cookies”).

(2) If your browser or browser add-ons allow it, you may adjust your cookie settings or reject our cookies. For more details, please visit https://www.aboutcookies.org/. However, doing so may, in some cases, affect your secure access to our website and may require you to change your settings each time you visit our website.

2. **Use of [Names of Similar Technologies, such as Platform Beacons and Pixel Tags]**

……

 

 (IV) Explanation of Situations Where Consent Is Not Required Based on Other Legitimate Grounds

In accordance with relevant laws and regulations, we may process your personal information without obtaining your consent in the following circumstances:

1. When necessary for the conclusion or performance of a contract to which you are a party;

2. When necessary to fulfill statutory duties or legal obligations;

3. Where necessary to respond to a public health emergency or to protect the life, health, and property of individuals in an emergency;

4. Where personal information is processed within a reasonable scope for the public interest, such as in the course of news reporting or public oversight;

5. Where personal information that you have voluntarily disclosed or that has been otherwise lawfully disclosed is processed within a reasonable scope in accordance with legal provisions;

6. Other circumstances as provided by laws and administrative regulations.

 

II. How We Use Your Personal Information

1. We will collect and use your personal information solely for the purposes and within the scope specified in this Privacy Policy. As our services are upgraded and updated, we may adjust the business functions described in this Privacy Policy and the types of personal information we collect and use. When new features or services are related to the in-vehicle camera module features or services we currently provide, the personal information collected and used will be directly or reasonably related to the original purpose of processing.

2. If we intend to use your personal information in contexts that have no direct or reasonable connection to the original purpose of processing, for purposes not specified in this Privacy Policy, or if information collected for a specific purpose is to be used for other purposes, we will notify you by updating this Privacy Policy, relevant product pages, and other privacy documents, as well as through various means such as pop-up windows, in-app messages, and push notifications. We will also seek your prior consent or ensure that other lawful grounds exist.

3. The sensitive personal information we collect is clearly marked in this Privacy Policy. If your sensitive personal information is disclosed, tampered with, or used unlawfully, it may result in harm to your personal safety or property. To prevent the disclosure or unlawful use of your sensitive personal information, we have implemented appropriate technical and organizational safeguards to ensure the security of your information to the best of our ability.

4. If the information you provide contains the personal information of others, you must ensure that you have obtained valid consent from the relevant individuals before providing such personal information to us. If the information involves a child’s personal information, you must obtain valid consent from the child’s legal guardian before providing it. In such cases, the guardian has the right to contact us through the channels specified in this Privacy Policy to request the correction or deletion of content involving the child’s personal information. If the information you provide infringes upon another person’s right to privacy, personal information, trade secrets, or any other lawful rights and interests, or causes harm to the state, public interests, or others, you shall bear full responsibility on your own, and we assume no liability for this.

5. Please note that the personal information you provide when using the in-vehicle camera module services we offer will remain authorized for our use throughout the period you use our services, unless you delete it or opt out of our collection through system settings.

6. We will compile statistics on the usage of the in-vehicle camera module services we provide and may share these statistical data with the public or third parties for the purposes of product development, service optimization, and security assurance. However, these statistical data do not contain any personally identifiable information about you. When we display your personal information, we will apply de-identification techniques—including masking and blurring—in accordance with the actual functional requirements of our business to protect the security of your information.

 

III. How We Store Your Personal Information

(1) Retention Period

Unless otherwise required by laws and regulations, we will retain your personal information for the minimum period necessary to achieve the processing purposes set forth in this Privacy Policy. The maximum retention period shall not exceed 3 years from the date of collection, i.e., no later than July 1, 2029. Upon expiration of the aforementioned period, we will delete or anonymize your personal information.

 

(2) Storage Location

Personal information collected and generated through our operations within China is stored within China. If it is necessary to transfer your personal information outside of China, we will comply with the legal requirements regarding the cross-border transfer of personal information prior to such transfer.

 

IV. How We Outsource the Processing, Provide to Third Parties, Transfer, and Disclose Your Personal Information

(1) Outsourced Processing

To improve data processing efficiency, reduce data processing costs, and enhance the accuracy of data processing, we may entrust [please specify the type of entrusted party, such as infrastructure providers, data analysis and processing service providers, or in-vehicle system service providers] to process your personal information on our behalf. Such entrusted processing is subject to the purposes stated in this Privacy Policy, and we will prohibit entrusted parties from using the data for unauthorized purposes through written agreements, on-site audits, and other means.

 

(2) Disclosure to Third Parties

For details on how we disclose your personal information to third parties, please refer to the “List of Personal Information Disclosed to Third Parties.”

 

|Recipient Type|Recipient Name|Contact Information|Personal Information Provided|Purpose of Provision|Method of Provision|

|---|---|---|---|---|---|

|【】|【】|【  】|【  】|【】|【】|

 

In the future, if we need to provide your personal information to other third parties, we will notify you of the relevant details on the corresponding page or through other appropriate means, and we will obtain your separate consent or have other lawful grounds to do so.

 

 (3) Transfer

As our business grows, we may engage in mergers, acquisitions, or reorganizations, which may result in the transfer of your personal information. We will require the transferee to continue protecting your personal information in accordance with the law and this Privacy Policy. If the transferee changes the original purpose or method of processing, we will require the transferee to obtain your consent again.

 

(4) Public Disclosure

As a general rule, we will not publicly disclose your personal information. If it is indeed necessary to publicly disclose your personal information, we will obtain your separate consent or meet other conditions prescribed by law.

 

(5) Third-Party SDKs

To ensure the stable operation of the in-vehicle camera module support services and the implementation of related functions, software development kits (SDKs) or other similar applications from business partners may be embedded in these services. We will conduct strict security monitoring of the SDKs used by our business partners to collect information, ensuring they process personal information in accordance with this Privacy Policy and any other relevant confidentiality and security measures to safeguard data security. We will promptly inform you of the latest developments regarding third-party SDKs involved in the collection and use of user information. For more details, please refer to the “Third-Party SDK Statement.”

 

1. **Third-Party SDK Information for iOS**

SDK Name:

Operator:

Purpose of Use:

System Permissions Required:

Types of Information Collected:

Privacy Policy Link:

 

……

 

2. **Third-Party SDK Information for Android Versions**

SDK Name:

Operator:

Purpose of Use:

System Permissions Required:

Types of Information Collected:

Privacy Policy Link:

……

 

V. How We Protect Your Personal Information

We take the security of personal information very seriously and take all reasonable and feasible measures to protect your personal information:

1. We have implemented industry-standard data protection technologies and management measures, such as network isolation, data encryption, and employee access controls, to prevent unauthorized access, disclosure, alteration, loss, or destruction of your personal information.

2. Please be aware that, although we will do our best to ensure or guarantee the security of any information you send to us, the internet is not 100% secure, and we assume no liability for any risks or losses arising from or related to this.

3. In the unfortunate event of a personal information security incident, we will promptly notify you in accordance with legal and regulatory requirements regarding: the basic details of the security incident and its potential impact; the remedial measures we have taken or will take; recommendations for you to independently prevent and mitigate risks; and remedial measures for you. We will promptly notify you of the relevant details of the incident via app push notifications, email, text message, phone call, or other means. When it is impractical to notify each data subject individually, we will issue a public announcement through reasonable and effective channels. At the same time, we will proactively report the handling of personal information security incidents to the regulatory authorities as required.

 

VI. How You Can Manage Your Personal Information

While using the in-vehicle camera module, you may access, copy, transfer, correct, supplement, or delete your personal information, as well as exercise your rights to modify the scope of your authorization and consent, or deactivate your account.

 

(I) Accessing, Copying, and Transferring Your Personal Information

1. If you wish to access or copy your personal information, you may do so via the access path “[Product Access Path].”

2. Please note that the access path may vary across different online platforms. You may follow the prompts on the corresponding page of the in-vehicle camera module, or contact us via the methods specified in this Privacy Policy for assistance.

3. To safeguard your right to obtain a copy of your personal information, we provide an online feature for obtaining a copy. You may apply to obtain a copy of your personal information through “[Product Access Path],” and we will provide it to you via appropriate means within a reasonable timeframe.

4. If you need to transfer your personal information to other platforms, companies, or organizations, you may contact us using the contact information provided in this Policy. We will review your request and, provided that the conditions set by the cyberspace administration authorities are met and it is technically feasible, we will provide you with a means to transfer the relevant personal information.

 

(II) Correcting or Supplementing Your Personal Information

If you discover that the personal information we process about you is incorrect or incomplete, you have the right to request that we correct or supplement it. You may correct or supplement your personal information by following the steps outlined in the section “(I) Accessing, Copying, and Transferring Your Personal Information,” or by contacting us via the contact information provided in this Privacy Policy.

 

(III) Deleting Your Personal Information

You may submit a request to us to delete your personal information under the following circumstances:

1. The processing purposes stated in this Policy have been achieved, cannot be achieved, or are no longer necessary to achieve the processing purposes;

2. Where the processing of your personal information is based on your consent, and you have withdrawn such consent;

3. The retention period for your personal information has expired;

4. We have collected, used, stored, provided to third parties, or disclosed your personal information in violation of laws, administrative regulations, or our agreement with you;

5. You no longer use our in-vehicle camera module services;

6. We cease providing products or services;

7. Other circumstances as provided by laws and regulations.

 

(IV) Modifying the Scope of Your Authorization and Consent

1. You may modify the scope of your consent or withdraw your authorization by adding or deleting information, changing your privacy settings, enabling or disabling the corresponding features and permissions on your device, or contacting us via the methods specified in this Policy.

2. You may opt out of receiving marketing communications from us by contacting us or following the unsubscribe instructions provided in the marketing messages.

3. Please understand that the various services provided by the in-vehicle camera module often require certain permissions to be enabled and the collection of necessary personal information in order to function. When you withdraw your consent, we will be unable to continue providing you with the products or services corresponding to the withdrawn consent; however, this will not affect the processing of personal information that has already been carried out based on your prior authorization.

 

(5) Account Closure

If you wish to close your account, you may do so yourself via “[Product Access Path].” You may also contact us using the contact information provided in this Privacy Policy, and we will respond to your request in a timely manner.

Closing your account is irreversible. We will cease providing services to you, stop collecting your personal information, and, in accordance with your request, delete or anonymize the personal information associated with your account.

 

(6) Restrictions on Automated Decision-Making

Our services may include automated decision-making mechanisms. If a decision made through such mechanisms significantly affects your legitimate rights and interests, you have the right to request an explanation from us and to object to decisions made solely through such mechanisms.

 

(7) Right to Explanation

If you have any questions regarding our personal information processing rules, you may contact us using the contact information provided in this Privacy Policy, and we will explain the relevant personal information processing rules to you.

 

(8) Other Rights Regarding Personal Information

In accordance with relevant laws and regulations, your close relatives may exercise the aforementioned rights—including the rights to access, copy, correct, and delete—with respect to your personal information after your passing; however, you may contact us to make alternative arrangements.

 

(9) Responding to Your Requests as Described Above

To ensure security, you may be required to submit a written request or otherwise verify your identity. We may ask you to verify your identity before processing your request. We will respond within fifteen days or within the timeframe specified by law.

In principle, we do not charge a fee for reasonable requests. For requests that are unreasonably repetitive or exceed reasonable limits, we may charge a reasonable fee at our discretion.

We will be unable to respond to your request in the following circumstances:

1. Where the request relates to our fulfillment of obligations prescribed by law;

2. Where the request is directly related to national security or defense security;

3. Where the request is directly related to public safety, public health, or major public interests;

4. Where the request is directly related to criminal investigations, prosecutions, trials, or the enforcement of judgments;

5. Where we have sufficient evidence indicating that the user acts with malicious intent or is abusing their rights;

6. Where it is necessary to protect the vital legitimate rights and interests of the user or other individuals—such as life or property—but obtaining the individual’s consent is difficult;

7. Where responding to the user’s request would result in serious harm to the legitimate rights and interests of the user, other individuals, or organizations;

8. Where trade secrets are involved.

 

VII. How We Handle Minors’ Personal Information

1. We place great importance on protecting the personal information of minors. In accordance with relevant laws and regulations, the collection and use of personal information from minors under the age of 14 requires authorization and consent from a legal guardian; the collection and use of personal information from minors aged 14 or older but under 18 may be authorized and consented to by a legal guardian or by the minor themselves.

2. If you are a minor (especially one under the age of 14), we ask that you have your parents or other legal guardian carefully read this Privacy Policy and use our in-vehicle camera module services or provide information to us only after obtaining your guardian’s authorized consent.

3. If you are the legal guardian of a minor, please ensure that the minor under your care uses our products or services only after you have provided your authorized consent. If you have any questions regarding the personal information of the minor under your guardianship, please contact us using the methods specified in this Privacy Policy.

 

VIII. How This Privacy Policy Is Updated

Our Privacy Policy may be amended from time to time. This Policy is valid until July 1, 2029, by default, and we will update it prior to its expiration date in accordance with business changes and legal requirements.

We will post information regarding changes to this Privacy Policy on the relevant product pages. For material changes, we will also provide more prominent notifications (such as through pop-up windows or in-app messages) to explain the specific changes to the Privacy Policy and obtain your consent.

We will not curtail the rights you are entitled to under this Privacy Policy without your explicit consent.

“Significant changes” as referred to in this Privacy Policy include, but are not limited to: major changes to our service model; changes in the circumstances under which personal information is provided to third parties, transferred, or publicly disclosed; major changes to your rights regarding the processing of personal information and the methods for exercising those rights; changes to our contact information and complaint channels; or situations where a personal information security impact assessment report indicates a high risk.

We will also archive previous versions of this Privacy Policy for your reference.

 

IX. How to Contact Us

1. If you have any questions regarding this Privacy Policy or the protection of personal information, you may contact us through the following channels:

Contact Information for the Personal Information Protection Officer: [13136107100]

Other Contact Information: [zlyuejx@sunnyoptical.com]

 

2. Generally, we will respond within fifteen days or within the timeframe specified by law. If you are dissatisfied with our response—particularly if our processing of your personal information has infringed upon your lawful rights and interests, and we continue to refuse to make improvements after you have provided feedback—you may also file a complaint or report the matter with regulatory authorities such as the Cyberspace Administration, the Ministry of Industry and Information Technology, the Public Security Bureau, and the Market Supervision Administration, or seek a resolution by filing a lawsuit with the court with jurisdiction over the defendant’s place of residence.