Privacy Policy

Last Updated: July 06, 2026

Effective Date: July 06, 2026

Data Controller: Shenzhen Hollyland Technology Co., Ltd.

1. Introduction and User Consent

This Privacy Policy is designed to clearly and comprehensively explain to global users how we collect, use, store, and protect your personal data, as well as your statutory rights, when you use the Products and Services provided by HOLLYLAND. The Services are not directed at children, and we do not intentionally offer or design the Services for individuals under the age of 13 or the higher local age threshold as required by applicable law in your jurisdiction.

Please read and fully understand all contents of this Privacy Policy before you first launch the Products and Services or use any related services. When you first launch the Products and Services, we will prompt you with this Privacy Policy through a prominent pop-up window, and we will only process your personal data in accordance with this Privacy Policy after you affirmatively click "Agree". For sensitive permissions such as microphone and camera, and related sensitive personal data, we will separately obtain your explicit consent through a system pop-up window when you use the corresponding functions. You have the right to refuse to provide relevant permissions or information, and refusal will only affect the use of the corresponding functions, not other basic functions of the Products and Services.

Your use or continued use of the Products and Services constitutes your acknowledgment that you have read, understood, and agreed to be bound by all contents of this Privacy Policy. If you do not agree with this Privacy Policy, you must immediately stop using the Products and Services.

If you have any questions, comments, complaints, or need assistance regarding this Privacy Policy, you can contact us at any time via our official email: support@hollyland.com. We will respond to and process your request within 30 days of receipt, or within the timeframe required by applicable law in your jurisdiction.

2. Personal Data We Collect

We strictly adhere to the principles of legality, legitimacy, necessity, and integrity. We only collect personal data necessary for the provision of the services provided under the Products and Services and will not collect personal data unrelated to the Products and Services. We strictly limit the integration of third-party SDKs. The Products and Services do not integrate any third-party SDKs for advertising, user profiling, or other non-essential marketing purposes. Any third-party SDKs used are strictly for necessary operational functions, and are vetted to ensure their data processing practices align with this Privacy Policy. The specific information collected, purposes, and permission descriptions are as follows:

Registration and Login

1. Email Binding and Login: When you actively bind an email address and log in with your email, we will collect your email address and verify your identity via email verification codes to ensure the security of account binding and login operations.

2. Third-Party Account Login: You may register and log in using Google or Facebook third-party accounts. We will only obtain the public information you authorize to generate a bound platform account to help you quickly access the Service. We will not collect or use information related to third-party accounts beyond the scope of your authorization.

2.1. Information and Permissions You Actively Authorize

During the operation of the Products and Services, the following system permissions will be requested. All permissions are necessary for the corresponding functions, and you can independently choose to agree or refuse. Refusal will only make the corresponding functions unavailable:

2.1.1. Microphone Permission

Data Collected: Audio information when you use online voice customer service or voice problem feedback

Purpose of Processing: Enable voice customer service communication and retain voice records for problem verification

Authorization Note: Permission is only requested when you actively open voice customer service or voice feedback. We strictly process only the explicit audio fragments generated during your active interaction; we do not engage in background continuous monitoring or automatic ambient audio collection. Refusal of authorization will disable all voice customer service related functions.

2.1.2. Camera Permission

Data Collected: Optical scan data and specific media captured via the device camera strictly when scanning device QR codes for pairing, scanning codes to log in, or taking photos/videos for problem feedback

Purpose of Processing: Recognize transmission device QR codes for pairing, scan codes to log in accounts, and capture media materials solely for fault feedback submission. The camera interface is executed strictly for localized barcode recognition and active user-triggered problem reporting. We do not engage in background continuous recording, nor do we collect, process, or analyze any facial imagery or biographical biometric data.

Authorization Note: Permission is only requested when you enter the QR scan or photo feedback page. Refusal of authorization prevents you from scanning devices, scanning codes to log in, or uploading feedback photos/videos.

2.1.3. File System/Storage Permission

Data Collected: Specific user-selected 3D LUT files, device configuration files, runtime logs, and App-related media materials (such as live-recorded videos, screenshots or localized photo/video attachments selected for problem feedback).

Purpose of Processing: Save recorded videos and pictures from transmission devices directly to the system gallery; import local user-selectedLUT files to hardware; cache device connection parameters; export logs and selected attachments for technical troubleshooting. Our storage access is strictly limited to managing App-generated content and accessing the specific files you manually select for upload. We do not read, scan, or browse any unrelated personal photos, documents, or private files in your device's gallery.

Authorization Note: Permission is only requested when saving media, reading local files or exporting logs. Refusal of authorization disables reading or saving local media, uploading feedback attachments, and configuration files.

2.1.4. Network Permission

Data Collected: Wi-Fi connection status, and randomized/anonymized online identifiers (such as SSID, BSSID, and local IP address, processed strictly within the local device memory).

Purpose of Processing: Scan transmission devices over the local area network (LAN), connect hardware devices via Wi-Fi,check for necessary software version updates, and synchronize anonymized hardware configurations for device pairing. We solemnly promise that core routing identifiers like SSID and BSSID are subjected to strict local anonymization, are utilized exclusively within the local App interface for device discovery, and are never permanently recorded or transmitted to cloud servers in a personally identifiable form.

Authorization Note: Basic network permission is requested upon App launch. Refusal of authorization will prevent the App from scanning or connecting to transmission devices, logging into accounts, or synchronizing basic configurations.

2.1.5. Device Connection & Location Auxiliary Permission (Wi-Fi Scan)

Data Collected: Nearby Wi-Fi scan list, device MAC address, SN, LAN device information

Purpose of Processing: Scan Wi-Fi signals of nearby HollyView transmission devices for fast pairing and connection; Android system requires location permission to perform Wi-Fi scanning

Authorization Note: We do not record, track, store, or transmit your actual physical geographic location.Permission is only requested when you enter the device search page. Refusal of authorization prevents scanning and discovering nearby transmission hardware.

2.2. Diagnostic Information You Actively Provide

When you encounter issues while using the Products and Services, certain diagnostic information (such as error logs) may be generated and stored locally on your device. We want to emphasize that this information is not automatically collected by us. You may choose to manually upload these diagnostic logs to us only when you actively provide feedback to customer service for troubleshooting purposes. This information is used solely for service optimization and technical support, and will not be used to identify you personally.

3. How We Use Your Personal Data

We use your personal data in strict accordance with the provisions of this Privacy Policy and applicable global laws and regulations, and will not use it beyond the agreed scope. The specific purposes are as follows:

3.1. Provide, operate and maintain the core basic services of the Products and Services, including localized hardware device connection, real-time wireless video transmission, and necessary audio and video data processing;

3.2. Troubleshoot and fix software operation faults, optimize the stability of the Products and Services and user experience, and iterate and update software functions;

3.3. Respond to your customer service inquiries and problem feedback, and provide you with accurate technical support and solutions based on the anonymized information you actively submit;

3.4. Conduct de-identified or anonymized statistical analysis to provide data support for iteration of the Products and Services and service optimization. During this process, we employ technical measures to ensure the data cannot be reasonably linked to a specific individual;

3.5. Fulfill obligations related to applicable laws and regulations, regulatory requirements and judicial procedures, ensure service compliance, and protect your account security and legitimate rights and interests.

If we need to use your information for other purposes not described in this Privacy Policy, we will inform you in advance through a prominent method and obtain your separate explicit consent.

4. Sharing, Transfer and Sale of Your Personal Data

We solemnly promise: We will not sell, rent, or trade your personal data to any third party. We will only share your information in accordance with the law under the following statutory circumstances:

4.1. With your prior explicit consent: Share the corresponding information to the third party you designate after you actively and explicitly consent;

4.2. Statutory mandatory requirements: We will provide your personal data when mandated by applicable laws and regulations, judicial procedures, or the requirements of government or regulatory authorities;

4.3. Corporate restructuring or transaction: In the event of a merger, acquisition, reorganization, bankruptcy, asset sale or similar corporate transaction, your personal data may be transferred to the successor entity. We will ensure the transferee agrees to be bound by this Privacy Policy. If the data processing purposes or scope change materially, we will obtain your separate explicit consent before any such transfer.

5. Storage and Protection of Your Personal Data

5.1. Storage Location and Cross-Border Transfer

For users of our Products and Services, we store and process personal data on servers located outside mainland China, primarily in the United States. We will not transfer or store your personal data in bulk to servers in mainland China. However, for the purposes of providing customer support or troubleshooting technical issues, our authorized personnel, which may include teams from our headquarters in Shenzhen, may require remote access to your data. Any such access is conducted under robust security measures and we utilize applicable cross-border data transfer mechanisms, such as the European Commission's Standard Contractual Clauses (SCCs), to protect your data to a standard required by law. We continuously review and enhance these security measures and compliance frameworks to adapt to evolving threats and regulatory requirements.

5.2. Storage Period

We follow the principle of data minimization necessity, and only store your personal data for the shortest period necessary to achieve the purpose of the Products and Services and the period required by laws and regulations:

• Diagnostic information generated on your device: This information (such as error logs) is stored locally on your device only when issues occur. You can view and manage it independently, and the Products and Services will not upload it automatically.

• Diagnostic logs you actively upload: If you choose to manually upload diagnostic logs to us for troubleshooting, these will be stored for no more than 180 days and will be automatically deleted or de-identified after expiration.

• Recording, screenshots and other files you actively save: Stored locally on your device, we will not upload them to the server, and you can manage and delete them independently;

• Upon receiving your verifiable request for account deletion via the contact channels provided in this Privacy Policy, we will process your request and initiate the deletion or de-identification of your active personal data within 30 days from the date of verification. Due to technical and operational requirements, especially concerning backup and archival systems, the complete removal of all associated data may take up to 90 days. We commit to securely deleting or de-identifyingall your personal data within these periods, unless applicable laws and regulations require longer retention.

• When the Products and Services ceases operation, we will inform you in advance through announcements, pop-ups and other methods, and delete or de-identify all your personal data within the time limit required by regulations.

5.3. Information Security Protection

We adopt industry-standard security technologies and management systems to fully protect the security of your personal data:

• We conduct desensitization processing on personal data, and store desensitized information and identifiable information separately to prevent the re-identification of personal identity;

• We adopt industry-standard security technologies such as SSL/TLS encrypted transmission, encrypted information storage, and hierarchical permission control to prevent risks such as information leakage, tampering, and unauthorized access, and implement multiple encryption protections for sensitive information;

• We have established a complete information security management system and emergency response plan, and regularly conduct security training and emergency drills;

• In the event of an information security incident, we will promptly activate the emergency response plan in accordance with the law, inform you of the details of the incident, disposal measures and prevention suggestions, report to the corresponding regulatory authorities as required, and bear corresponding responsibilities in accordance with the law.

6. Your Rights Regarding Your Personal Data

In accordance with the applicable laws and regulations of your jurisdiction, you have the following statutory rights regarding your personal data. We are committed to facilitating your exercise of these rights and will respond to your requests in accordance with this Privacy Policy and applicable laws.

To exercise any of the rights described below, or for any privacy-related inquiries, you may contact us via our official email: support@hollyland.com. Our dedicated team will verify your identity and process your request within 30 days of receipt, or within the timeframe required by applicable law in your jurisdiction.

6.1. Right to Know and Access: You have the right to understand our information processing rules through this Privacy Policy, and to query the relevant personal data we process about you;

6.2. Right to Rectification: If you find that the personal data we process about you is incorrect or incomplete, you have the right to request us to correct and supplement it;

6.3. Right to Erasure: You have the right to request us to delete your personal data where permitted or required by applicable law, including but not limited to: we process your information in violation of the agreement, you withdraw your consent, you stop using the Products and Services, the processing period expires, etc.

You may log in to the App and go to "Mine - Account Management - Cancel Account" to complete the account cancellation process as prompted. Before cancellation, please unbind all associated third-party accounts. After account cancellation, we will stop providing all Services to you. Upon receiving your verifiable request for account cancellation, we will process your request and initiate the deletion or de-identification of your active personal data within 30 days from the date of verification. Due to technical and operational requirements, especially concerning backup and archival systems, the complete removal of all associated data from backups may take up to 90 days. During this period, we commit to securely isolating your data to ensure it is beyond retrieval or further processing, unless applicable laws and regulations require longer retention. Once fully erased, the deleted data cannot be recovered. If you cannot complete account cancellation by yourself, you may contact us via the customer service email, provide identity verification materials, and we will assist you with the cancellation procedures.

You may unbind your Google or Facebook third-party accounts on the "Mine - Account Management" page within the App, which will clear the localized association data from such platforms. For a permanent and complete erasure of all personal data stored on our servers, you should choose to execute the account cancellation process as described above.

6.4. Right to Data Portability: You have the right to request us to provide you with the personal data you actively provided in a structured, commonly used and machine-readable format, or to transmit it to a third party designated by you where technically feasible;

6.5. Right to Withdraw Consent: You have the right to withdraw the permissions and consents you have granted at any time. You can turn off relevant system permissions such as microphone, camera, storage, and location auxiliary permissions—through your mobile device's System Settings - Privacy & Security, or directly withdraw your consent within the App where applicable. After withdrawing your consent, we will stop processing the corresponding information, but it will not affect the information processing behavior carried out based on your consent before the withdrawal;

6.6. Right to Restriction of Processing and Right to Object: Where permitted or required by applicable law, you have the right to request us to restrict the processing of your personal data, or object to the information processing behavior we carry out based on legitimate interests;

6.7. Right to Complain: If you believe that our information processing behavior violates applicable laws and regulations or the provisions of this Privacy Policy, you have the right to file a complaint through the contact information provided in this Privacy Policy, or to the relevant regulatory authorities in your region.

6.8. Non-Discrimination: Without limiting any of the above rights, we will not discriminate against you for exercising any of your privacy rights under applicable laws, including but not limited to denying access to the Products and Services, charging different prices or rates for services, or providing a different level of service quality.

7. Children's Privacy Protection

We strictly comply with applicable global data protection laws and regulations regarding the protection of children's personal data, including the European Union's General Data Protection Regulation (GDPR). We do not knowingly collect, use, or disclose personal data from children. If we learn that we have collected personal data from a child, we will take steps to delete that information promptly. If you are a parent or legal guardian and believe that a child under the applicable age threshold has provided us with personal data without your consent, please contact us immediately using the contact information provided in this Privacy Policy. Upon verification, we will promptly and permanently delete such personal data.

8. Third-Party Services

To ensure the core functionality and stability of the Products and Services, we may integrate a limited number of essential third-party SDKs. We do not integrate any third-party SDKs for advertising or marketing purposes. If we add any third-party services that process your personal data in future versions, we will revise this Privacy Policy in advance, inform you through a prominent method, clarify the information processing rules of the third party, and obtain your separate explicit consent.

9. Updates and Notices of the Privacy Policy

We may revise the provisions of this Privacy Policy from time to time due to updates in applicable laws and regulations, changes in regulatory requirements, business adjustments, or iteration of the Products and Services' functions. The revised Policy will be published through reasonable means such as in-software pop-ups, announcements on our official website, and other official channels, with the updated date and effective date clearly marked.

If the revised content involves material changes that may substantially affect your rights or interests under this Privacy Policy, we will notify you through prominent methods such as in-software pop-ups, official announcements, and/or emails at least 30 days before the revised Policy takes effect. Your continued use of the Products and Services after the revised Policy's effective date shall constitute your acceptance of and agreement to be bound by all the terms of the revised Policy. If you do not agree with the revised content, you should immediately stop using and uninstall the Products and Services.

10. Regional Supplementary Provisions

10.1. For Users in the European Union/European Economic Area (EEA)

10.1.1. This clause applies supplementarily to users in the EU/EEA, and has the same effect as other clauses of this Privacy Policy; if there is any inconsistency between this clause and other clauses, this clause shall prevail.

10.1.2. The legal bases for our processing of your personal data include: your explicit consent, performance of contractual obligations with you, our legitimate interests, and compliance with legal obligations.

10.1.3. You have the right to lodge a complaint with the data protection supervisory authority in your member state, without first raising an objection to us.

10.2. For Users in the State of California, USA

10.2.1. This clause applies to California residents and supplements this Privacy Policy in accordance with the CCPA/CPRA. We DO NOT sell your personal information and will not discriminate against you for exercising your privacy rights. California residents may use an authorized agent to exercise their rights, subject to our verification of the agent's identity and authorization.

10.2.2. We solemnly promise: We will not sell your personal data, nor will we take discriminatory treatment against you for exercising your rights under this clause.

11. GENERAL PROVISIONS

11.1. GOVERNING LAW & JURISDICTION (DATA PROTECTION MATTERS)

For users in the European Union/EEA

This Privacy Policy and all data processing-related disputes shall be governed by the GDPR and the laws of the EU Member State where you are domiciled. The exclusive competent courts of that Member State shall have jurisdiction over any data protection-related claims. You retain the right to lodge a complaint with the data protection supervisory authority in your Member State at any time.

For users in the State of California, USA

This Privacy Policy and data protection-related disputes shall be governed by the CCPA/CPRA and the laws of the State of California. The state and federal courts located in California shall have jurisdiction over such disputes. Nothing herein shall limit your rights under the CCPA/CPRA, including the right to pursue individual relief in a court of law.

For all other users outside the EU and California

This Privacy Policy shall be governed by the laws of the State of California, regardless of conflict of law rules. Subject to the data protection laws of your jurisdiction, you and HOLLYLAND agree to submit to the personal and exclusive jurisdiction of the state and federal courts located in San Francisco County, California for disputes arising out of or relating to this Privacy Policy.

Mandatory Data Protection Law Precedence

Notwithstanding the above, all data processing activities shall at all times comply with the mandatory provisions of the data protection laws applicable in your jurisdiction (including, without limitation, GDPR and CCPA/CPRA). Any conflict between this section and such mandatory laws shall be resolved in favor of the mandatory data protection laws.

CISG Exclusion

The United Nations Convention on Contracts for the International Sale of Goods (CISG) shall not apply to this Privacy Policy.

11.2. OTHER DISPUTE RESOLUTION

Any disputes unrelated to personal data processing and data protection rights, including but not limited to disputes regarding service usage, contract performance, intellectual property rights and other relevant matters, shall be governed by the provisions on governing law, dispute resolution and arbitration set forth in our separate Terms of Service.

This Privacy Policy does not establish specific resolution rules for non-data protection related disputes.

11.3. ASSIGNMENT

You may not assign this Privacy Policy or any rights granted hereunder, whether by operation of law or otherwise, without the prior written consent of HOLLYLAND. Any attempted assignment without such consent shall be null and void. HOLLYLAND reserves the right to assign its rights and obligations under this Privacy Policy to a third party due to business adjustment, merger, acquisition or other reasons, and will notify you in advance through official channels prior to the assignment.

11.4. SEVERABILITY

If any provision of this Privacy Policy is held to be invalid, unenforceable or illegal by a court of competent jurisdiction, such provision shall be enforced to the maximum extent permitted by applicable law, without affecting the legal validity of the remaining provisions of this Privacy Policy.

11.5. ENTIRE AGREEMENT

This Privacy Policy constitutes the entire agreement between the parties with respect to the subject matter hereof, and supersedes all prior oral or written proposals, understandings, communications and agreements between the parties with respect to such subject matter, unless you have signed a separate written agreement with HOLLYLAND.