SimpliSafe Ltd Privacy Policy

Last updated: July 2024

1. INTRODUCTION

SimpliSafe Ltd ("SimpliSafe") takes your privacy seriously. We believe in protecting your personal data as well as helping to protect your person and belongings. The purpose of this Privacy Policy is to describe how SimpliSafe collects, uses and shares personal data including information about its customers and users of our services. It applies whether the personal data is obtained through our call centre, online interfaces (e.g., website and mobile applications) including https://simplisafe.co.uk ("Site"), use of SimpliSafe Services and/or Systems and/or Applications (all as defined in the relevant Terms of Service linked below) or is otherwise provided to us.

Please read this Privacy Policy carefully to understand how we process your personal data. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us as described at the end of this policy.

Our Privacy Policy explains:

The Data Protection Principles that we follow

Personal Data We Collect and Why We Collect It

How We Use and Share Your Personal Data

Our Use of Cookies

Information Sharing

Access to Your Personal Data and Choices

Security of Your Personal Data

Retention of Your Personal Data

International Transfers

Changes to Our Privacy Policy

Questions and How Contact Us

Additional Terms. Other terms may also apply to how we process your personal data in addition to this Privacy Policy. Our Terms of Sale will apply to your purchase of our products and use of our Site is subject to our Terms of Use. If you subscribe to SimpliSafe’s monitoring services (including any Emergency Dispatch Services Services) ("Monitoring Services") or activate any other service offerings made available in connection with a SimpliSafe product, this use will be subject to the relevant Terms of Service. We may also ask you for consent to use your personal data for specific purposes in which case any terms that we provide to you as part of the consent process shall also apply.

We will comply with all laws that apply to how we process your personal data. Data protection laws say that the personal data we hold about you must be:

• Used lawfully, fairly and in a transparent way.

• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.

• Relevant to the purposes we have told you about and limited only to those purposes.

• Accurate and kept up to date.

• Kept only as long as necessary for the purposes we have told you about.

• Kept securely.

SimpliSafe collects certain information to enable you to take full advantage of our offerings when you register at our Site, order products or services either through the Site or our call centre, communicate with our customer service representatives, request to receive promotional codes, participate in our contests, surveys, promotions, or activities, or otherwise communicate or interact with us. 

We seek to limit the collection and use of customer information required to deliver service to our customers. We may use this information to advise our customers about our products, services and other opportunities, including sending promotional codes, and to administer our business, where we have your consent or are otherwise permitted to do so by law.

Personal Information You Provide To Us When You Become a Customer. Types of personal information we collect when you become a customer and provide it to us include for example:

• Name

• Address

• Billing address

• Shipping address

• Email address

• Telephone number

• Demographic information about you

• Credit card, debit card and bank account numbers (which we will use solely for payment purposes)

 Personal Information You Provide To Us When You Subscribe to a Monitoring Service. 

Types of personal and other information we collect when you become a subscriber to a Monitoring Service, in addition to the fields directly above, include for example:

• The number of (i) adults and children living at the Premises where a Device will be installed in a domestic or private Premises, or (ii) employees or other individuals in the context of business or commercial Premises.

• Whether the location is (i) a house, apartment or other domestic or private Premises, or (ii) business or commercial Premises.

• Name and telephone number for any secondary contact (e.g. friends, family or an employee) that you would like to be contacted  as a "Responsible Party") in the event of an alarm event at your Premises.

• Information such as your "safe word" and log-in credentials used to verify your identity if you forget your login credentials for your SimpliSafe account.

• Information such as your alarm activity stored in your online account. This activity includes, when the alarm is armed and disarmed, and when an alarm event is triggered.

By providing details of any third party such as your friends and family or employee you represent that you have obtained their permission to act as a contact in the event of an alarm event and for you to disclose their information to us, that they agree to allow us to process their personal data as necessary to perform any Monitoring Service and that you have drawn this Privacy Policy to their attention. If they do not give permission you must not pass on their details to us. If they withdraw this permission you must tell us immediately and provide us with an alternative contact.

Personal Information You Provide To Us When You Choose To Share Your Video Through The “Share with SimpliSafe” experience.

When you choose to share a video with us through the “Share with SimpliSafe” experience on our app, we may use this video by posting it on our social media accounts, for the purpose of marketing SimpliSafe products. You should not upload any videos that contain footage of any other identifiable adults or children, but instead limit the videos to only those that contain footage of approved content such as videos of animals, or videos of yourself only. 

Please be aware that once if video is posted on our social media accounts, the video will no longer be under SimpliSafe’s full control and could be shared by others, therefore we may not be able to remove the video fully once it has been interacted with, other than by taking the video down on our own social media accounts. 

Please note that where your video contains footage of any other individuals, uploading information about other individuals may impinge on their privacy and data protection rights. You are responsible for ensuring that you have obtained the necessary permissions from those individuals before sharing those videos with SimpliSafe.

Personal Information Collected through a Security Camera or other device

When you enable recording or streaming features of a security camera or other recording device (“Device”), we will record, stream, store, transmit and process (together “Record”) video and/or audio recordings from the Device in the manner required to provide our services. What is recorded and when will depend on how you place the Device and configure its settings. Our services may include capturing, analysing and making available to you and our Monitoring Services provider portions of the Recorded data as part of a notification or analysis of the data to identify motion, intrusion, fire or other events. We process and store information recorded in this way from your Device (“Monitoring Data”) so that we can send you alerts when there is an event or make other responses in accordance with any Monitoring Service that we provide to you. This may involve passing Monitoring Data to our response service provider and/or law enforcement and/or other emergency response authorities. You are solely responsible for placement of the Device which will determine what it can and cannot Record and for turning the device on and off. If you have any recording feature enabled during your Device subscription period we will capture, process, and store video and audio recordings from your security camera for 30 days from the date such data is first recorded and stored on our systems. During your subscription period, you will be able to access those recordings for up to 30 days from this date. We will not use the Monitoring Data for any other purpose except where we have your prior express consent or are required by law to retain or disclose Monitoring Data.

NOTE: You acknowledge and agree that privacy and other laws are likely to apply to your use of the Device. You (and not SimpliSafe) will be the controller of all personal data recorded by the Device and you are solely responsible for ensuring that the Recording complies with all applicable laws relating to the Device. For example, you may be required to display a notice (even inside your home) that alerts visitors to your Premises that you are using a security camera that is recording audio and/or video. Privacy laws may also require that you locate the Device so that it can only record activity within the boundary of your Premises and not, for example a neighbouring property, home or garden, shared spaces or a public place not in the boundaries of your commercial Premise, such as a footpath, park, or street. Some countries have laws that prevent recording of conversations without consent or recording of people in areas where they have an expectation of privacy. Please also consider that recording and sharing of video that involves other people may affect their privacy rights. You should refer to publicly available materials to understand your obligations relating to the use of security cameras and recording devices, including those provided by the UK Office of the Information Commissioner at www.ico.org.uk. We may provide further information and alerts with the device or on the Site from time to time. You should read these carefully.

Please note that any Monitoring Service is subject to your agreement of the relevant Terms of Service and payment of an appropriate subscription fee.

Information We Collect Automatically. As is with most websites, we collect certain information automatically as you use our Site, such as

• IP address

• Browser type

• Computer or device type

• Unique device identifiers for mobile devices or tablets

• Operating system version

• The website from where you navigated to our Site

• Time and date of using, accessing, or otherwise interacting with our Site

• The pages on our Site that you view

• The name of your Internet service provider (ISP)

Information Collected Through Cookies and Analytics Partners

We and our analytics providers use cookies, web beacons, and similar device identifying technologies (“Cookies”) to receive and store information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your device when you visit a website. When you visit the website again, the cookie allows that site to recognize your device. Cookies may store unique identifiers, user preferences and other information such as the information set out in ‘information we collect automatically’ above. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you (see, "Advertising" below).  You can find detailed information about our use of cookies in the section “Our use of Cookies” below.

Information Collected From Other Sources

We may also obtain your personal data from other sources, such as business partners and lead generators which provide us with personal data to assist us with engaging with potential or new customers.

No Information From Children or Teens Under Age 18

The Site is not directed to, and we do not knowingly collect any personal data from, children or teenagers under the age of 18. If you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If you are under the age of 18, you may only use this Site under the supervision of your parents or guardians.

Third-Party Sites and Social Media

Our Site may contain links to other websites operated by third parties and may include social media features such as Facebook, Twitter, Instagram, and Pinterest buttons or links. These third-party sites may collect information about you if you click on a link, and the social media sites may automatically record information about your browsing behaviour every time you visit a site that has a social media button. Your interactions with these features are governed by the privacy policy of the company providing the link, not this privacy policy.

Refer-A-Friend

If you use our "refer-a-friend" feature, we may ask for your friend’s e-mail address or we may ask for you to share a link with a friend. We use this information only to send the communication you requested and to monitor the effectiveness of our refer-a-friend feature. By providing an email or sharing a link, you represent that you have obtained your friend’s permission to do so and that you will inform us immediately if they withdraw their permission.

We will only use your personal data when the law allows us to do so.  In particular, we will use your personal data for the following purposes:

To Provide Products, Services, and Information. As described above, we collect information from you so that we can provide products and services that you purchase from us, and to provide information that you request from us. This includes sending you alarm alerts and important service information about your Device and services we provide to you and providing you with any other monitoring or response service. We use your personal information to contact you about your orders, process credit card / debit card transactions, and ship our products to you. We may provide information to third party service providers that help us process orders and fulfill and deliver products and services that you purchase from us. Where you must provide personal data to us to perform a contract or take an action, we may not be able to perform the agreement or take that action without use of such data. We may provide information to partners to confirm products and services that you purchase from us and corresponding event data, such as when you receive a discount on your insurance for having our Monitoring Services we may have to provide personal information and event data to your insurer in order for you to receive that discount.

To facilitate payments.  If you subscribe for Monitoring Services, or make purchases through the Site, your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to provide the Monitoring Services or products. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they have stored, including recurring payments if you become a subscriber, and your card’s type, expiration date, and certain digits of your card number.

To contact you with marketing and offers relating to products and services offered by us and our business partners. We may provide you with information about our products and services where permitted by law or with your consent. We will only use your personal data for marketing in accordance with applicable law. You may opt out of receiving future marketing communications from us by logging into your account via the website and editing your profile. You may also opt out of receiving marketing messages from us, including promotional codes, by following the opt-out instructions in each communication or via the following page https://simplisafe.co.uk/unsubscribe_email. We also work with a third party to participate in a data cooperative with other UK retailers operating in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, home interiors, and travel retail categories or the charity sector. Participating retailers (like SimpliSafe) share information on what customers buy and postal addresses. The third party analyses this pooled information to provide insights into consumers’ wider buying patterns as well as to create postal mailing lists tailored to customers' interests. You can learn more about how the third party we work with processes personal information in its Privacy Policy, available here: https://abacus.epsilon.com/privacy-policy/.

For Advertising. We may use information about how you browse and shop in order to show you ads for SimpliSafe or our advertising partners that are more relevant to your interests. We may use cookies to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behaviour in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our Site or third-party sites not owned by SimpliSafe.

We belong to ad networks that may use your browsing history across participating websites to show you interest-based advertisements on those websites. Our Site does not respond to “do not track” signals or similar mechanisms to indicate you do not wish to be tracked or receive interest-based ads, but you can exercise certain choices in respect to our use of cookies as described in the ‘Our Use of Cookies’ section below. To learn more about interest-based advertisements and your opt-out rights and options, visit the European Interactive Digital Advertising Alliance website (https://www.youronlinechoices.com/uk/).

With Your Consent. We may use and share your personal data (including with companies, organizations or individuals outside of SimpliSafe) when we have your consent to do so.

To comply with our Legal obligations. We may use your personal data where we need to comply with a legal obligation and/or to cooperate with regulators and law enforcement bodies.

To meet Legitimate interests. We may process your personal data where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. These interests may include where we reasonably need to access, use, preserve or disclose information as reasonably necessary to:

• Enforce applicable Terms of Sale and Terms of Service, including investigation of potential violations.

• Detect, prevent, or otherwise address fraud, security or technical issues.

• Protect against harm to the rights, property or safety of SimpliSafe, our users, customers or the public as required or permitted by law.

Other uses. We may also use your personal data in the following situations:

• Where we need to protect your interests (or someone else's interests).

• Where needed in the public interest.

Our website uses cookies and other device identifying technologies ("cookies") to provide our services, to understand how our website is used and for advertising purposes as described above.  

What are cookies?

We use the term 'cookies' to refer to all technologies which store and access information on the device that you use to access our website, such as your computer, tablet or mobile phone.  For example, we use http cookies, which are small data files (typically made up of numbers and letters) that are downloaded when you access our website and allow us to recognise your device.  

We use cookies to enhance the online experience of our website visitors and to better understand how the website is used.  Cookies may tell us whether you have visited the website before or whether you are a new visitor. 

There are different types of cookies, for example:

• Cookies served directly by SimpliSafe ('first party cookies') and cookies served on our behalf, for example by advertisers and data analytics companies ('third party cookies').

• Cookies which endure for different periods of time, including those that last only as long as your browser is open (referred to as 'session cookies') These are deleted automatically once you close your browser. Other cookies are 'permanent cookies', meaning that they survive after your browser is closed. For example, they recognise your device when you open your browser and browse the internet again.  

Which cookies do we use and why do we use them?

Our cookie consent tool provides information on the different categories of cookies that our website uses, the companies that serve them and why we use them. The cookie consent tool is always available at the bottom right hand corner of our website. If you have any questions about our use of cookies you can contact us at the address below. 

How can you exercise your cookies choices?

Cookies help us, our service providers and business partners provide and customise our website and the advertising you see.  Except for strictly necessary cookies, which are essential for the functioning of the Site, to provide the services, or for security, you have the right to choose whether or not to accept cookies. However, if you choose to refuse or remove cookies, this could affect the availability and functionality of the website.  

If you don’t want our website to use cookies other than strictly necessary cookies, please use the cookie consent tool to opt-out in the “manage cookies” section of the tool.  Alternatively, you can opt-out using your browser settings following the instructions set out below.  

Website (Browser) Opt-Out:  

Most browsers accept cookies by default.  You may be able to change the settings to have your browser refuse certain cookies or notify you before accepting cookies.  To do so, please follow the instructions provided by your browser which are usually located within the "Help", "Tools" or "Edit" facility.  Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link and you will be able to find out more about this by visiting the cookies policy of the relevant third party.

We may share your personal information with third parties under the following circumstances:

• Use within the SimpliSafe Group. SimpliSafe Ltd is owned by SimpliSafe, Inc in the United States, so we work closely with SimpliSafe, Inc. to carry on our business. In the normal course of conducting our daily business, we share a variety of information with SimpliSafe, Inc. This may include, but is not limited to, information to provide our products and services to you, to conduct day to day operations, for general business purposes and for marketing purposes and internal reporting. 

• Service providers and business partners. We use third parties to assist with providing our products and services to you including for example to assist with our Monitoring Services and dispatching emergency responders, call management, host our Site, send out email updates about the Site, provide marketing and advertising services for us, in our refer-a-friend program, remove repetitive information from our user lists, and process payments. These service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to help us provide the service. We also employ appropriate security and technological controls and provisions to protect against unauthorised SimpliSafe employee access to the audio and video data collected from your security camera.

• With your insurer.  We may share personal information with your insurer, where the insurer has referred you to us for commercial security monitoring of your business. This information may include your personal information, such as your name and account number, and the information may also include whether you have Monitoring Services, and alarm event details.  The purpose of this data sharing is to confirm for your insurer your active client and active Monitoring Service status and to provide event data to your insurer for their analytical needs.  

• Law enforcement agency, court, regulator, government authority or other third party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

• With Third-Party Sites and Social Media.  We may share your personal information with these parties and the content of any shared videos when you choose to Share Your Video Through The “Share with SimpliSafe” experience, as described above.

• Asset purchasers. Where the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, in which case we may transfer or sell your personal information to the new owner. In such a case, unless permitted or otherwise directed by applicable law, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with the applicable privacy policy in effect at the time of such transfer.

• With your consent or otherwise at your direction.  We may share your information with third parties when you consent to or request such sharing.  

Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on "International Data Transfer" below for more information.

You can access and update certain information we have relating to your online account by logging into your online account and visiting the “monitoring” section to update contact information for your alarm monitoring and dispatch. Under the “log in” section you can update your email address and password. 

You can opt-out of receiving marketing and promotional emails from SimpliSafe by using the opt-out or unsubscribe feature contained in the e-mails. Or you can access the page and unsubscribe here https://simplisafe.co.uk/unsubscribe_email at any time. 

You can close your online account by calling us at 0800 456 1789.  If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information for a period of time reasonably necessary for archival purposes, and to avoid identity theft or fraud.

Please note that you have rights to obtain a copy of your personal data and in certain situations to obtain correction, erasure and restriction of processing of your personal data. You also have a right of data portability. These rights are subject to applicable law. 

Where processing is based on your consent you have a right to withdraw this consent at any time.

If you have any questions about this privacy notice, the personal information we have about you and/or how we handle your personal data, or if you wish to exercise any of the rights described in this section please contact us at 0800 456 1789 or via email at privacy@simplisafe.co.uk. 

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. You can find out more about your rights in relation to your personal data at www.ico.org.uk.

We use commercially reasonable physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will keep some of your personal data for the time during which your account is open (or, if you do not have an account, for a reasonable period) or, if longer, the period required by law. We retain camera footage internally for 30 days. 

To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a customer we will retain and securely destroy your personal information in accordance with our policies and applicable law.

Your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under UK data protection law. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below.

Our Privacy Policy may change from time to time. In particular, we may update this Privacy Policy where required to reflect changes in the functionality of our products, changes to our services, the introduction of new products and services and changes in applicable law.

We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any updated privacy policy on this page and, if the changes are significant, we will provide a more prominent notice as we deem appropriate. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us, call us at 0800-456-1789, or contact us by post at the following address:

SimpliSafe Ltd. 196 Deansgate Manchester M3 3NE

ICO Registration number: ZA762725

You may also contact our Data Protection Officer at privacy@simplisafe.co.uk or by writing to the above address and include Attn: Data Protection Officer.