Hikvision Transparency Report

January 1 – December 31, 2023

Jan 31, 2024

With the value of tech for good and as a leading global AIOT solution provider, Hikvision Digital Technology Co.,Ltd, its domestic and foreign wholly-owned subsidiaries, holding subsidiaries and branches (hereinafter collectively referred to as "HIKVISION", "Company" ,"we" , "our" or 「us」 ) always respect information security of our customers and their privacy when providing comprehensive and diversified security solutions for them. We specifically state that, without customers』 prior authorization, we will not have access to any video generated during their use of HIKVISION products and platforms.

We may cooperate with government agencies, on condition that they make explicit requests to us in accordance with applicable laws and regulations, to provide respond to their specific requests. Only after our review and we believe that we can provide responses, we will respond to relevant requests and process user information in accordance with law within the necessary limits.

We will strive to achieve greater transparency and data security protection for our customers.

We have never built a so-called "backdoor" or "master key" into any product or service, nor have we ever allowed any government to directly access HIKVISION servers, and never will.

Types of Government Requests Received by HIKVISION

HIKVISION may receive various forms of legal requests seeking information from or actions by HIKVISION, within the limitation of meeting specific administrative, judicial or law enforcement requirements. We receive requests from government agencies (including administrative, judicial and law enforcement agencies) of countries or regions where we provide products and services.

Government requests we receive usually include the following circumstances: when discovering and investigating criminal cases through surveillance video clues, for example, when it is discovered through a public video recording that criminal facts may exist and further verification is needed, investigative agencies will require us to provide technical assistance to identify products owners and users, obtain account information, retrieve usage records, view usage, etc.; when a user's product is stolen, user data is leaked, or hacked, the relevant administrative and judicial agencies will, act on behalf of such user, require us to obtain product or account IP login information, disable specific account, etc.; when a civil dispute occurs, the court and other relevant institutions, at the request of the plaintiff and defendant, will retrieve order records, after-sales record information from the user account; when emergencies that endanger social and public safety occur, administrative or law enforcement agencies may, in accordance with applicable laws and regulations, require us to take action to cooperate with them.

Common types of legal requests we receive are: Legally valid subpoenas, search warrants, Requisition or Judicial Rogatory Letters (France), Solicitud Datos (Spain), Auskunftsersuchen (Germany), Obligation de dépôt (Switzerland), Personal Data Request (UK) etc.

Types of Information HIKVISION will Provide

The customer information collected by HIKVISION is divided into Non-Content Information and Content Information. Non-Content Information refers to customer account registration information, which includes customer company name/personal name, legal representative information (if applicable), email information and telephone information, basic information of HIKVISION hardware products deployed or used by customers or users (product serial number, model), records of customers placing orders directly with HIKVISION to purchase products or services, etc. Content Information mainly refers to the audio and video information, alarm records, access control and attendance records that are transmitted, recorded, and stored when users use HIKVISION software and hardware products.

Without explicit prior consent of the users and without meeting legal requirements, HIKVISION will not directly disclose or provide Content Information to any government. The types of information HIKVISION can support are as follows:

A. User account identity information, including registered user name (user's personal name or company name), mobile phone number or email address, registration time, region information, corporate certification information, representative information and other background information required when any HIKVISION platform users using related functions.

B. Product binding information, including HIKVISION product information bound to the user account, such as product name, model, serial number, binding time, and product sharing status.

C. Usage information, mainly the login or operation logs, including user account login time, IP address, terminal device information (mobile phone model, client version number); device operation logs (online and offline records).

D. Shopping or transaction records, which refer to the order information (time, goods, amount, payment method), purchase or order records, and delivery address (if applicable) when customers use HIKVISION B2B platform and cloud service purchase services.

E. Other information, including questionnaires, ratings, problem feedback submitted by customers, after-sales service records, etc.

Procedures to be Followed when Responding to Government Requests

1. Requests Sending and Receiving Procedures

Government requests shall be sent from official address of relevant government agencies, accompanied by valid certificates, via registered mail to HIKVISION registered office address in corresponding country/region (specific address can be searched on http://www.imgcoffee.com/en/about-us/contact-us/). If there is no local registered HIKVISION office address, please send it to: Hikvision Europe B.V., Dirk Storklaan 3, 2132 PX Hoofddorp, the Netherlands, with its register number of 34359062. Any government requests sent through e-mail shall be from official e-mail address of relevant government agency, accompanied by valid certificates, and sent to: legal.eu@imgcoffee.com.

In order for us to quickly make response, the government agencies making legal requests shall state specific laws and regulations upon which their requests are based, and issue the requests in strict accordance with applicable laws and regulations. Relevant applicable laws and regulations include but are not limited to EU General Data Protection Regulation, EU Digital Services Act, etc.

We reserve the right to charge reasonable fees incurred by any government agency for complying with its lawful requests.

We accept requests from government agencies conform to the following paradigm:

Government Request Form For Information

2. How HIKVISION Manages Various Types of Requests

Hikvision has a centralized and standardized process for receiving, tracking, processing and responding to legal requests from government agencies.

Hikvision will request that government comply with applicable laws and regulations when requesting customer information and data, and HIKVISION will contractually require its service providers to adhere to the same standards. HIKVISION’s team will review received requests to ensure they have valid legal basis. If HIKVISION believes that any request lacks a legitimate and reasonable legal basis, that any request is unclear, inappropriate or too broad, or that it may harm the legitimate interests of any third party, HIKVISION has the right to object, question or reject such request.

HIKVISION will treat the request as an emergency if it is related to a situation involving an urgent and serious threat to personal life/security, national security, or the security of critical infrastructure/installations. HIKVISION will review any requests on an urgent basis if the requesting government agency can prove that their requests involve the aforementioned situations.

If a government agency requests HIKVISION to restrict or delete any account of a customer or user, HIKVISION will require a court order or other equivalent legal instrument (including an injunction, conviction verdict or writ) to prove that such account was used in a way illegal or infringing others』 legitimate rights. If HIKVISION determines that the request does not have a valid legal basis, or if the government agency cannot prove illegal use or infringement of such account, HIKVISION will deny or challenge the request. If HIKVISION receives a qualified court order or other equivalent legal instrument from the government or law enforcement agency, which can prove that the account requested to be restricted or deleted has been illegally used or infringes others』 legitimate rights , HIKVISION will comply with such order or equivalent legal instrument, to take necessary steps to restrict or delete the account, while informing the requesting agency of the process.

When HIKVISION provides customers or users』 account information and basic product information in response to legitimate and valid requests from government agencies, HIKVISION will notify these customers or users as soon as possible, except for the following circumstances: court orders received by HIKVISION and applicable law expressly prohibits the provision of notification; or HIKVISION believes that providing notification would pose a risk of injury or death to an identifiable individual; the cases involve child abuse; or the notification does not apply to the basic facts of the case.

After 30 days, HIKVISION will provide a delayed notice to the involved customers or users regarding emergency information disclosure, except in the following circumstances: providing notice is prohibited by court order or applicable law; HIKVISION believes that providing notice may expose identifiable individuals or the group poses a risk of injury or death; the cases involve child abuse.

If HIKVISION receives any court order requiring a confidentiality period, HIKVISION will provide a notice after the confidentiality period specified in the court order expires, unless HIKVISION believes that providing notification may bring a risk of harm or death to an identifiable individual or group, or the case involves child abuse, or the notification does not apply to the basic facts of the case.

If HIKVISION receives a court order (usually a guilty verdict or writ) proving that the account requested to be restricted/deleted has been used illegally or infringes others』 legitimate rights, HIKVISION will notify the customer or user when it restricts or deletes the relevant account accordingly , unless the following circumstances exist: the legal proceeding itself, a court order received by HIKVISION, or applicable law prohibits the provision of notification; the case involves child abuse; HIKVISION has reason to believe that providing notification will expose an identifiable individual or group to a risk of injury or death; the notice does not apply to the underlying facts of the case.

How HIKVISION Counts and Reports the Government Requests

Starting from February 2024, at the beginning of each year, we will publish and update the transparency report on the official website http://www.imgcoffee.com/en/, disclosing the types and numbers of government requests we received, as well as involved countries/regions in the previous year.

Any request with the same valid legal basis that we process and respond to counts as one request. Any request that we challenge or deny counts as a request. If any request is revised, it counts as a new request. If we are asked to provide multiple pieces of information for a product in the same request, we will treat it as one request. Similarly, if a request requires us to provide multiple pieces of information for the same account, we will treat it as one request.

We classify the requests we receive into the following categories: product requests, account requests, transaction-related requests, and emergency investigation requests.

Currently, we disclose the acceptance and processing of government requests related to Hik-Partner Pro, HikCentral Connect and the Hik-Connect platform, and disclose them according to the following categories.

Worldwide Government Product Requests
Worldwide Government Account Requests
Worldwide Government Transaction Information Requests
Worldwide Government Emergency Requests

If HIKVISION receives legitimate requests from other categories, we will include them in future transparency reports.

Table 1: Worldwide Government Product Requests

Table 1 provides information about product-based requests from governments globally. For example, law enforcement agencies often make data requests when they are trying to trace lost or stolen products as part of investigations. The countries listed are the only ones from which we have received requests.

Country or Region	Product-based Requests Received	Products Specified in Requests	Requests Where Data Provided	Percentage of Requests Where Data Provided	Median Days to Respond
None	0	0	0	0	0






Total	0	0	0	0	0

Note:

Number of Product-based Requests Received

This is the number of product-based requests received from a government agency seeking customer data related to specific product identifiers, such as serial numbers. We count each request received from each country or region and report the overall number of requests received by country or region.

Number of Products Specified in Requests

The number of products specified in the requests. One request may contain one or multiple product identifiers. For example, in a case related to the theft of a batch of products, law enforcement may seek information related to several product identifiers in a single request. We count the number of products identified in each request, received from each country/region, and report the total number of products specified in requests received by country/region.

Number of Product-based Requests Where Data Provided

This is the number of product-based requests that resulted in Hikvision providing data, such as customers associated with products, product connections to Hikvision services, purchase, customer service, or repair information, in response to a valid legal request. We count each product-based request where we provide data and report the total number of such instances by country or region.

Percentage of Product-based Requests Where Data Provided

This is the percentage of product-based requests that resulted in Hikvision providing data. We calculate this based on the number of product-based requests that resulted in Hikvision providing data per country or region, compared to the total number of product-based requests Hikvision received from that country or region.

Table 2: Worldwide Government Account Requests

Table 2 provides information of account-based requests received. For example, law enforcement agencies conduct investigations and collect evidence based on what they suspected to be unlawful use of certain Hikvision accounts. Account-based requests generally seek details of such as Hik-Partner Pro accounts or Hik-Connect accounts, such as phone numbers or IP addresses.

Country or Region	Account –based Requests Received	Accounts Specified in Requests	Requests Where Only Non-Content Data Provided	Percentage of Requests Where Non-Content Data Provided	Median Days to Respond
None	0	0	0	0	0






Total	0	0	0	0	0

Note:

Number of Account-based Requests Received

This is the number of account-based requests received from a government agency seeking customer data related to specific Hikvision account identifiers, such as Hik-Partner Pro IDs or phone numbers. We count each request received from each country or region and report the total number of requests received by country or region.

Number of Accounts Requested

This is the number of accounts specified in the requests. One request may contain one or more account identifiers. For example, in a case related to internet fraud or hacker attack, law enforcement may seek information related to several accounts in a single request. We count the number of accounts identified in each request received from each country or region and report the total number of accounts specified in requests received by country or region

Number of Account-based Requests Where Only Non-Content Provided

This is the number of account-based requests that resulted in Hikvision providing non-content data, such as registration information, login logs, bound products, or transactional information. We count each account-based request where we provide non-content data and report the total number of such instances by country or region.

Percentage of Account-based Requests Provided

This is the percentage of account-based requests that resulted in Hikvision providing noncontent data. We calculate this based on the number of account-based requests that resulted in Hikvision providing non-content data per country or region, compared to the total number of account-based requests Hikvision received from that country or region.

Table 3: Worldwide Government Transaction Requests

Table 3 provides information of transaction-based requests received. For example, law enforcement agencies such as courts collect evidence regarding transaction activities between Hikvision and customers that involved in controversies.Transaction-based requests generally seek details of the controversial transaction, such as that conducted through Hik-Partner Pro.

Country or Region	Transaction-based Information Requests Received	Customer Related Identities Specified in Requests	Requests Where Data Provided	Percentage of Requests Where Data Provided	Median Days to Respond
None	0	0	0	0	0






Total	0	0	0	0	0

Note:

Number of Transaction-based Requests Received
This is the number of transaction -based requests received from government agencies seeking customer data related to specific transactional identifiers, such as purchase order numbers. We count each request received from each country or region and report the total number of requests received by country or region.

Number of Customer Related Identities Specified in Requests
This is the number of customer related identifiers specified in the requests. One request may contain one or more customer related identifiers, for example the customer itself and the logistic service provider. We count the number of financial identifiers identified in each request received from each country or region and report the total number of financial identifiers specified in requests received by country or region.

Number of Transaction-based Requests Where Data Provided
This is the number of transaction-based requests that resulted in Hikvision providing data in response to a valid legal request. We count each financial identifier-based request where we provide data and report the total number of such instances by country or region.

Percentage of Transaction-based Requests Where Data Provided
This is the percentage of transaction-based requests that resulted in Hikviision providing data.We calculate this based on the number of transaction-based requests that resulted in Hikvision providing data per country or region, compared to the total number of transaction based requests Hikvision received from that country or region.

Table 4: Worldwide Government Emergency Requests

Table 4 provides information regarding emergency requests received. Worldwide government agencies may request Hikvision to voluntarily disclose information in accordance with applicable laws and regulations, including customer information and contents of communications, to a government entity if Hikvision believes in good faith that an emergency involving imminent danger of death or serious physical injury to any person requires such disclosure without delay. Examples of such requests are where a person may be missing and law enforcement believes the person may be in danger. Emergency requests generally seek details of customers』 connections to and use of Hikvision services.

Country or Region	Emergency Requests Received	Requests Rejected and No Data Provided	Requests Where No Data Provided	Requests Where Non-Content Data Provided	Percentage of Requests where Data Provided	Median Days to Respond
None	0	0	0	0	0	0






Total	0	0	0	0	0	0

Note:

Number of Emergency Requests Received

The number of emergency requests received from a government agency. We count eachindividual request received from each country/region and report the total number of requests received by country/region.

Number of Requests Rejected and no Data Provided

The number of emergency requests that resulted in Hikvision challenging or rejecting the request based on grounds such as a request is unclear, inappropriate, or fails to demonstrate that it relates to an emergency circumstance; and where no data was provided. We count each emergency request where we challenge or reject it and report the total number of such instances by country/region.

Number of Requests Where No Data Provided

The number of emergency requests that resulted in Hikvision providing no data. For example, instances where there was no responsive data or Hikvision only provides supportive technical services. We count each emergency request where we do not provide data and report the total number of such instances by country/region.

Number of Requests Where Non-Content Data Provided

The number of emergency requests that resulted in Hikvision providing non-content data, such as connections to and usage information of Hikvision services (no record information included), in response to a valid emergency request. We count each emergency request where we provide data and report the total number of such instances by country/region.

Percentage of Requests where Data Provided

The percentage of emergency requests that resulted in Hikvision providing data. We calculate this based on the number of emergency requests that resulted in Hikvision providing data per country/region, compared to the total number of emergency requests Hikvision received from that country/region.

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Hikvision Transparency Report