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HomeLinking Privacy Policy contents

At HomeLinking, we take your privacy seriously.

We pledge to

What information does HomeLinking Smart Light collect?

What additional information does HomeLinking collect and store when a user connects a HomeLinkingProduct to the Internet or creates an account?

How does HomeLinkinguse the information it collects?

In what circumstances does HomeLinkingshare my information?

How long does HomeLinking save my personal information and how can I delete it?

At HomeLinking, we take your privacy seriously.

This Privacy Statement for HomeLinkingProducts and Services (“Privacy Statement”) describes information that HomeLinkingInc. and its subsidiaries and affiliates (collectively, “HomeLinking”) collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information). This document focuses on information related to the operation of HomeLinkingproducts and services, including the HomeLinking Smart Light and other products from HomeLinking(collectively, “HomeLinkingProducts”). In this Privacy Statement, the expression “HomeLinkingProducts” also includes our , Mobile Apps, and Subscription Services as defined in our Terms of Service.

We pledge to

Be transparent about the different types of information we collect and how we use them.

Ask your before sharing your personal information with third parties for purposes other than to provide HomeLinking’s Products, and to do so only when we think they will provide you with a welcome additional service.

Use best-in-class data security tools to keep your data safe and protect the HomeLinkingProducts from unauthorized access.

By using HomeLinkingProducts, you agree to allow us to collect and process information as described below.

What information does HomeLinking Smart Light collect?

HomeLinkingSmart Light collects:

1. Information input during setup

2. Environmental data from HomeLinking Smart Light sensors

3. Video and audio signals and data

4. Technical information from the device

5. Shared content

Information input during setup: When you install HomeLinkingSmart Light, you’ll be asked for certain basic information like your device name, device description, ZIP or postal code, the country where the HomeLinkingSmart Light is located as well as where in your home you’re installing it. This information is used to personalize your experience – for example, to tell you which device is triggering a notification.

Environmental data from the camera’s sensors: We collect data from several sensors built into HomeLinkingSmart Light. These sensors collect data such as ambient light. By recording this information, HomeLinkingSmart Light can know, for instance, whether it’s dark and it should turn on night vision.

Video and audio signals and data: When you enable the recording or streaming features of your HomeLinking Smart Light, we may record and process video and/or audio recordings from the device, subject to your configuration and settings. This may include capturing and emailing to you portions of this data as part of a notification or analyzing the data to identify motion or other events. We may process information from your HomeLinking Smart Light so that we can send you alerts when something happens. In addition, if you have the recording features enabled, we will capture, process and retain video and audio data recordings from your device for the duration of your recording subscription period (for example, 7 days) and you will be able to access those recordings using the Services during that time.

Technical information from the : In order to improve your experience over time and help troubleshoot any problem you may encounter with HomeLinkingSmart Light, we record your HomeLinkingSmart Light model and serial number, software version, and technical information such as Wi-Fi signal strength.

Saved and Shared Content: You may save and may choose to share certain content like video clips, live video streams, images, captions, and comments for other people to access using the Services. We will collect and store information that will allow us to save or share your content as directed by you through the Services.

Data protection and privacy laws in your country may impose certain responsibilities on you and your use of HomeLinkingSmart Light. You (not HomeLinking) are responsible for ensuring that you comply with any applicable laws when you use HomeLinkingSmart Light. For example, you may need to display a notice that alerts visitors to your home that you are using HomeLinking Smart Light. Note in particular that recording and sharing clips that involve other people may affect their privacy and data protection rights.

What additional information does HomeLinking collect and store when a user connects a HomeLinking Product to the Internet or creates an account?

To connect your HomeLinkingProduct to our Services, or to access your HomeLinking Product over the Internet from a computer, a smart phone or a tablet, you will need to connect it to your Wi-Fi network. During setup, the HomeLinking Product will ask for your Wi-Fi network name (SSID) and password to connect to the Internet. It will save this information on the device, along with your IP address, so that you can access it and control it from your computer, smart phone or tablet, and so that it can communicate with HomeLinkingservers and download software updates.

Once connected to your Wi-Fi network, your HomeLinking Product regularly sends the data described in this Privacy Statement (excluding your Wi-Fi password) to HomeLinkingto provide you with the Services.

In addition, HomeLinking Products (such as HomeLinking Smart Light) may broadcast an identifying signal wirelessly. This is used to connect with your devices (such as a smartphone or tablet) in order to deliver features like easy setup (AirLink Auto).

How does HomeLinking use the information it collects?

We may also use this information in an aggregated, non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we use aggregated user information about the number of active thermostat users in a particular state to help us decide what energy companies might be good partners.

We may use the information we have about you – including information about your interests, actions and connections – to select and personalise ads, offers and other sponsored content that we show you. Learn more about how we select and personalise ads, and your choices over the data we use to select ads and other sponsored content for you in the settings.

We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

We may use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. Depending on your location and type of data, HomeLinking may process your personal information on servers that are not in your home country.

We use the information that we have to send you marketing communications, communicate with you about our Products and let you know about our Policies and Terms. We also use your information to respond to you when you contact us.

In what circumstances does HomeLinking share my information?

Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the delivery of HomeLinking Products and services without asking you first. Period. We do not rent or sell our customer lists.

The following are the limited situations where we may share personal information:

1. With your explicit consent: We may share personal information when we have your consent.

One example of this would be if you sign up for programs offered by our partners (e.g., energy or insurance companies). If you do this, we may share certain information with the partner. This could include things like your enrollment information and the activation status of your device. Similarly, when you connect third-party devices and services to your HomeLinking Products through the Works with HomeLinking program, you are shown information about any proposed exchange of data. Your explicit consent is required to allow these exchanges on your behalf and you can change your mind at any time.

2. With your explicit consent: We may share personal information when we have your consent.

These technicians (as well as HomeLinkingemployees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-HomeLinkingpurposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video data.

3. As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred.

We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.

4. For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons.

For example, to respond to legal process, or comply with state and federal laws (or the applicable laws of foreign countries other than the United States).

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish trends about energy use or elevated carbon monoxide levels in the home. This information may also be shared with other users to help them better understand their energy usage compared to others in the HomeLinkingcommunity, raise awareness about safety issues, or help us generally improve our system. We may also share non-personal information with our partners, for example, if they are interested in providing demand-response services or other incentive programs. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.

Your personal information may be collected, processed and stored by HomeLinkingor its service providers in the United States and other countries where our servers reside. As a result, your personal information may be subject to legal requirements, including lawful requirements to disclose personal information to government authorities, in those jurisdictions.

If you select an outside party for the purchase, installation, or service of your HomeLinkingdevice and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a HomeLinkingSmart Light from a retailer, the retailer may collect personal information as part of the transaction. Or the party that installed the device may retain information that you provided to them to assist them in servicing the device if needed. Always check the privacy policies for any company that collects your personal information.

How long does HomeLinkingsave my personal information and how can I delete it?

HomeLinkinggenerally stores your personal information on HomeLinking’s servers until you delete or edit it, or for as long as you remain a HomeLinkingcustomer in order to provide you with HomeLinkingProducts.

As described above, some information is processed and stored directly on the HomeLinkingdevice. All personal information is encrypted as it is transmitted to HomeLinkingand cannot easily be accessed.

You can delete the information on the HomeLinkingdevice by resetting it to the defaults.

You can access, amend or delete your personal information from HomeLinking’s servers through the controls in your account. Because of the way we maintain certain Services, after your information is deleted, backup copies may linger for some time before they are deleted, and we may retain certain data for a longer period of time if we are required to do so for legal reasons.

Please note that this Privacy Statement may change from time to time. We will provide notice of any changes on the website or by contacting you.

HomeLinkingINC. AND THE EU-U.S. and SWISS-U.S. PRIVACY SHIELD

HomeLinkingInc. ("HomeLinking") has certified to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, "Privacy Shield Frameworks") with the US Department of Commerce regarding the collection and processing of personal data from our advertisers, customers or business partners in the European Union and, where a Swiss data controller uses HomeLinkingas a data processor, Switzerland ("Partners") in connection with the products and services described in the Scope section below and in ourcertification. To learn more about the Privacy Shield program, please visit www.privacyshield.gov. Scope: HomeLinkingadheres to the Privacy Shield Principles (as set out in each of the Privacy Shield Frameworks) for the following areas of our business (collectively the "Partner Services"): Workplace Premium: Workplace Premium is a service that allows people to more effectively collaborate and share information at work. Partners (employers or organisations – the data controllers) may submit personal information about their members to HomeLinking, with HomeLinkingIreland as the processor and HomeLinkingInc. as a sub-processor. Whilst Partners and their members decide what information to submit, it typically includes things such as business contacts, customer and employee information, employee-generated content and communications, and other information under the Partner's control. For more information, members may contact the Partner through which they hold a Workplace account and review Workplace's Privacy Policy. Ads and measurement: HomeLinkingoffers ads and measurement products, and through those services, HomeLinkingmay receive personal data from unaffiliated Partners (the data controllers) where HomeLinkingIreland is the processor and HomeLinkingInc. is a sub-processor. This includes things such as contact information and information about individuals' experiences or interactions with the Partners and their products, services and ads. For more information about our ads and measurement products, visit our About Advertising on HomeLinking page and our Data Policy. HomeLinkinguses the personal data provided by our Partners to provide Partner Services in accordance with the terms applicable to the relevant Partner Service and otherwise with the Partners' instructions. HomeLinkingworks with its Partners to ensure that individuals are offered appropriate choices applicable under the Privacy Shield Principles. Access. Within the scope of our authorisation to do so, and in accordance with our commitments under the Privacy Shield, HomeLinkingwill work with its Partners to provide individuals with access to personal data about them that HomeLinkingholds on behalf of its Partners. HomeLinkingwill also take reasonable steps to enable individuals, either directly or in connection with the Partners, to correct, amend or delete personal data that is demonstrated to be inaccurate. Third parties. HomeLinkingmay transfer data within the HomeLinkingfamily of companies and to third parties, including service providers and other partners. In accordance with the Privacy Shield Principles, HomeLinkingis liable for any processing of personal data by such third parties that is inconsistent with the Privacy Shield Principles unless HomeLinkingwas not responsible for the event giving rise to any alleged damage. Legal requests. Personal data that is transferred to us by our Partners may be subject to disclosure pursuant to legal requests or other judicial and government processes, such as subpoenas, warrants or orders. For more information, review the "How do we respond to legal requests or prevent harm?" section of the HomeLinkingData Policy and the "Legal Requests" section of the Workplace Privacy Policy. Enforcement. HomeLinking's compliance with the Privacy Shield Principles is subject to the investigatory and enforcement powers of the US Federal Trade Commission. Questions and disputes. Please contact us with any questions or concerns relating to our Privacy Shield certification. You have the option to resolve any applicable disputes that you have with us in connection with our certification through Beijing Arbitration Commission, an alternative dispute resolution provider based in the CHINA. You can contact Beijing Arbitration Commission through their website. In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles in each of the Privacy Shield Frameworks. Additionally, as part of the Privacy Shield Frameworks, the US State Department Senior Coordinator serves as the Ombudsperson to facilitate the processing of requests relating to national security access to data transmitted from the EU and Switzerland (respectively) to the US.