Tips for better handling privacy concerns when using video products

Tips for better handling privacy concerns when using video products

This Document (hereinafter referred to be “the Document”) is the property of Hangzhou EZVIZ Software Co., Ltd. and/or its affiliates (hereinafter referred to as “EZVIZ”), and it cannot be reproduced, changed, translated, or distributed, partially or wholly, by any means, without the prior written permission of EZVIZ. Unless otherwise expressly stated herein, EZVIZ does not make any warranties, guarantees or representations, express or implied, regarding to the Document, any information contained herein.

Thank you for choosing EZVIZ video products!

About This Document

EZVIZ is fully aware that, due to the nature of video/audio-related functions, device users/owners may face various privacy concerns when installing and using video products. This article is intended to provide users with some suggestions on how to deal with privacy concerns with video products. We at EZVIZ hereby earnestly advocate that every user shall use video products properly and responsibly, in order to jointly create a positive environment in which all related practices and uses comply with applicable laws and regulations, respect individuals’ interests and rights, and promote social morality.

Important Reminder

This document does not constitute professional advice from legal practitioners or security experts. It does not cover all the compliance requirements for the installation and the use of video products. We strongly recommend that all users should access their own application needs and seek professional advice when necessary, rather than relying solely on this document.

The creation, publication or updating of this document, at any time, shall NEVER be interpreted as EZVIZ’s intention or action to replace the user’s legal responsibilities or joint responsibilities with the user.

Tip 1 - Obtain some legal knowledge about data protection

You may have heard of the GDPR, the fundamental and most important law on personal data protection in the European Union. In fact, based on the GDPR, the European Commission and various member states have also issued numerous guidelines on its implementation details and application. For consumers, attempts to understand and digest these guidelines may be easier than reading the legal provisions directly.

We recommend that you read through some of the official legal guidelines related to the use of video products, which will help you better understand the origins of privacy concerns over video products, and the ways in which you can better deal with such concerns, as well as the responsibilities and obligations you have as a user of video products.

You can directly read the data protection application guidelines issued by the data protection authority in your country (usually listed on their official website), or the Guidelines 3/2019 on processing of personal data through video devices issued by the European Data Protection Board (EDPB) specifically for the use of video products. (Please visit the EDPB official website: www.edpb.europa.eu)

Tip 2 - Learn the privacy design of your video product

EZVIZ has always practiced “privacy by design (PbD)” in products we build. The company understands users’ need on privacy protection during their use of video products, and uses effective, thoughtful product designs to address such needs.

For example, for the EZVIZ Smart Peephole Doorbells, we have specifically designed the following features and settings in terms of better privacy protection.

1) Users can adjust the detection sensitivity to set a preferred detection distance;

2) Users can easily disable motion-triggered detection function at any time;

3) A warning sticker about a video/audio monitoring area is included in the product’s packaging.

You may learn more about them in the products’ user manual.

For any feedback and advice on the privacy design of EZVIZ products, please contact [support.eu@ezviz.com] or [privacy@ezviz.com]. EZVIZ DPO Team sincerely looks forward to your comments and are ready to assist your inquiry.

Tip 3 - Create your security plan and improve it timely

EZVIZ encourages each user to establish their own methods and rules for evaluating and monitoring the use of video products to ensure that these products are always used properly, thoughtfully and with good will.

For your reference, some areas of focus that are worthy of evaluation and follow-up evaluation include but are not limited to:

1) The necessity and appropriateness of installing and using video products;

2) The minimal need on the processing and use of personal biometric data;

3) The act of clear notification to the affected parties, and the fulfillment of their requests to exercise their lawful rights;

4) Appropriate allocation of the use and managing access of the device;

5) Close attention to changes in the patterns of device use, and corresponding timely updates in its usage assessments.

EZVIZ recommends that you prepare a written document of “Data Protection Impact Assessment (DPIA)” to keep full record of the information about the installation and the use of your video products, which shall state where, for what purpose, and under what conditions and states (including environmental conditions, product function settings, etc.), and particularly why you must use it this way instead of by other means to achieve your purposes.

Tip 4 - Inform your neighbors and property management offices, and understand their opinions

Generally speaking, you, as an individual user, install and use video products for the purpose of personal protection or home security, but this may conflict with certain interests of your neighbors or property owners, such as privacy, public order, etc. In fact, this is the root cause of why privacy concerns with video products arise. Therefore, you should always pay close attention to the opinions of interest parties around you, especially your neighbors and property managers.

Related actions may include the following: Review your property management contract or pledge before installing video products; Report your plan of product installation and using to the relevant parties as required, and obtaining their approval (if necessary); Post clear notices in appropriate areas near your installed video products, to ensure that relevant parties can become fully aware of the recording activities within the specific monitoring zones; When receiving requests from the data subject who want to exercise their rights or object to the use of your products (for example, a request to delete or stop processing their personal data), respond to them within a reasonable amount of time (usually within 1 month).