Insta360 Studio Privacy Policy
[V3.0]
effective date: December 24th, 2024
Arashi Vision Inc. (the “Insta360”, “us” “our” or “we”) and its affiliates recognize the importance of protecting the personal information we may collect from visitors, users and any other individual or entity (collectively, “Users”, “you”, or “your”). We value your interests and fundamental rights and are committed to processing personal information in a professional, lawful and ethical way.
The Insta360 Studio Privacy Policy (this "Privacy Policy") applies to the Insta360 Studio software ("Studio Software") that we provide. Studio Software is a post-processing software for Insta360 cameras. For parts not covered by this policy, the Insta360 Privacy Policy shall prevail. Unless otherwise agreed, terms used in this policy have the same meanings as those in the Insta360 Studio User Service Agreement.
Please read this Policy carefully as it will help you understand what we do with the personal information that we process. Please pay special attention to the important contents of this Policy, which have been highlighted in bold form. By using or continuing to use our Services after we have updated this Policy (and we will promptly notify you of such updates), you agree to the content of this Policy (including the updated version) and to our collection, use, storage and protection of personal information about you in accordance with this Policy.
If you have any other queries regarding this Policy or our use of your personal information, please refer to our contact information at the end of this Policy
This Policy contains:
1.How we collect and use your personal information
2.How we share, transfer, and disclose your personal information
3.How we protect and store your personal information
4.How you manage your personal information
5.How your personal information is transferred globally
6.Protection of personal information of minors
7.Notification and Revision
8.How to contact us
9.Special rules for California residents
10.Special rules for Singapore users
11.Special rules for Hong Kong SAR residents
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.
1.1 Information we collect
When you use our products/services, we need to collect and use your personal information as follows:
a) In order to provide you with basic features and services, we may obtain access to video and photos from computer devices and otherwise connect to computer devices, and may read device related information such as language settings, device manufacturer and model, device identifier, operating system, resolution, and use event tracking to collect user behavior data such as your service usage habits, operating history, crash logs, etc;
b) Insta360 Studio not only allows unregistered users but also supports account registration and login:
i. 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.
ii. You can use a third party account (including 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 our Platform account, so that you can directly register, log in and use our Platform and related services.
c) In order to improve your security and user experience in using our services, we may use event tracking to collect user behavior data such as your service usage habits, operation records, crash logs, etc.;
d) Other information that you send to us in addition to the above information.
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	Purpose of permission	
Device read and write permissions	PC/macOS	Importing files requires reading to disk, exporting files requires writing to disk.	
Network usage permissions	PC/macOS	Update software, upload program logs and operation records, usage habits, etc.	
1.3 How we use the information we collect
We strictly abides 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 provide users with the basic service features of the services and software and hardware of our platform used.
b)To make improved products or offer superior service by analyzing log files we collected.
c)To send you relevant information, such as changes to our Policy terms, conditions and policies regarding the services.
d)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.
e)For auditing, developing new products, analyzing usage trends, improving operational efficiency and promoting promotional purposes.
f)Other uses for which we have your consent.
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.
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. How we share, outsource, transfer and disclose your personal information
2.1. Sharing of personal information
We currently do not share your personal information with third parties. In the event that we need to share your personal information with a third party in the future, we will inform you of the recipient's name, contact information, type of data shared, purpose of sharing, sharing and transmission methods, and rules for protection of personal information through appropriate means in strict accordance with relevant laws and regulations. Please be aware that you have the right to refuse to consent to our sharing of your personal information to third parties, and if you refuse to consent to our sharing of information to third parties, you may not be able to use the corresponding functions. In the future, we may share your personal information in the following circumstances:
2.1.1. Obtain your prior consent or authorization;
2.1.2. In accordance with laws and regulations, administrative and judicial mandatory requirements;
2.1.3. 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;
2.1.4. Enable the core functions of our products and/or services or to provide the services you require;
2.1.5. Handling disputes or controversies between you and others for you at your request;
2.1.6. 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;
2.1.7. Based on academic research;
2.1.8. 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 platforms 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 platforms.
2.2. 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 to process 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	The Link of privacy policy	
Ali cloud	Log files and resource files	Analyze and maintain program usage and update usage resources	http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud201902141711_54837.html?spm=a2c4g.11186623.J_9220772140.83.67061795JZ7gCE 	
Thinking data	Data of event tracking	Analyze user usage preferences	https://docs.thinkingdata.cn/ta-manual/latest/user_guide/privacy_policy.html#%E5%89%8D%E8%A8%80	
Volcengine (Only available under Chinese system)	Crash logs	Analyze the crash issue	https://www.volcengine.com/docs/6256/64902	
2.3. 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.
2.4. 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.
2.5. 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 Platforms, 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. The third-party plug-ins/SDKs accessed by this platform are listed below:
No.	Name of SDK/API	Company	Purpose of use	information Collected	The link of Privacy Policy	
1	AliCloud OSS sdk	Alibaba	Upload file	The file users upload	http://terms.aliyun.com/legal-agreement/terms/suit_bu1_ali_cloud/suit_bu1_ali_cloud201902141711_54837.html?spm=a2c4g.11186623.J_9220772140.83.67061795JZ7gCE	
3. How we protect and store your personal information
3.1. 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.
3.2. Where we store your personal information
Currently, we use Hong Kong database 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.
3.3. 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;
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.
4. 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:
4.1. Right to Access to personal information
If you would like to copy or download the information we have collected from you, you have the right to submit your request by sending an email to service@insta360.com or DPOcontact@insta360.com. We will review your request as soon as possible and respond within fifteen business days upon verifying your identity as a user.
4.2. 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.
4.3. Right to delete personal information
You may make a request to us to delete personal information in the following cases:
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 platforms, we may not immediately delete the corresponding information from our backup systems, but will delete it when the backup is updated.
4.4. 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. Where technically feasible, such as data interface matching, we may also transfer a copy of your personal information directly to a third party designated by you at your request.
4.5. 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.
4.6. 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.
4.7. 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.
4.8. 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.
5. How your personal information is transferred globally
Currently, we use Hong Kong database 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.
6. Protection of personal information of minors
Insta360 Studio service is intended for adults, not directed to minors. We do not knowingly collect personal information from minors. 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.
Although local laws or customs define minors differently (e.g., California in the United States, Singapore defines a child as a minor under the age of 13, Korea under the age of 14, etc.), we treat anyone under the age of 16 as a child. If we find that we have collected personal information from a child without prior verifiable parental consent, we will attempt to delete the relevant data as soon as possible.
7. 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.
8. 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 dpocontact@insta360.com or write to us at the following address: 25Floor, Building 1, Jinlitong Financial Center, 1100 Xingye Road, Haiwang Community, Xin'an Street, Bao'an District, Shenzhen, Guangdong, 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.
9. Special rules for California residents: Do Not Sell My Personal Information
The California Consumer Privacy Act (California Civil Code §§ 1798.100 through 1798.199) and its implementing regulations, as amended or superseded from time to time (the “CCPA”), provide California consumers with specific rights regarding their personal information. This section describes your rights as a California consumer under the CCPA, and if you wish to exercise any of these rights, please e-mail us at dpocontact@insta360.com.
9.1.Your Right to Know
You have the right to know from us:
the categories of personal information we collect, sell, share or disclose;
the purposes for which the categories of personal information we collect are used;
the sources of information from which we collect personal information;
the categories of third parties to whom we disclose personal information;
the specific personal information we collect about you (if any)
9.2.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, you can send us a request by service@insta360.com and we will not sell or share your personal information.
10.Special rules for Singapore users
10.1.Definition of Personal Information
*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.
10.2.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.Special rules for Hong Kong SAR residents
*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.
This version of the Privacy Policy becomes effective on December 24, 2024.