SimpliSafe Ltd Privacy Policy

Last updated: March 2019

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. It applies whether the personal data is obtained through our call center, online interfaces (e.g., website and mobile applications) including https://simplisafe.co.uk ("Site"), use of SimpliSafe services 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
Access to Your Personal Data and Choices
Security of Your Personal Data
Retention of Your Personal Data
Changes to Our Privacy Policy
International Transfers
Questions and How Contact Us

Third Party Sites. This Privacy Policy applies only to information we collect through the Site or is otherwise provided to us. Our Site also contains links to third-party sites that are not provided by SimpliSafe. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

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 or activate any other service offerings made available in connection with a SimpliSafe product, their 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.

2. DATA PROTECTION PRINCIPLES

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.

3. INFORMATION WE COLLECT AND WHY WE COLLECT IT

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 center, communicate with our customer service representatives, participate in our contests, surveys, promotions, or activities, or otherwise communicate with us. If you choose, you can visit the Site without providing us with any information about yourself.

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, 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:

  • 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 services include:

  • The number of adults and children living at the location where the alarm will be installed.
  • Whether the location is a house or apartment.
  • Name and telephone number for friends or family you would like to be contracted in the event of an alarm.
  • Information such as your "safe word" and log-in credentials used to verify your identity if you forget your log in 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 you represent that you have obtained their consent to act as a contact in the event of an alarm and for your 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 consent you must not pass on their details to us. If they withdraw this consent you must tell us immediately and provide us with an alternative contact.

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, analyzing 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 were we 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 home that you are using a security camera that is recording audio and/or video. Privacy laws may also require that you site the Device so that it cannot record any activity that does not take place in your home, for example in another person’s garden or home or in in a public place. 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 not 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 use analytics partners to collect certain non-personally identifiable information about how our Site is used. We and our analytics providers use cookies, web beacons, and other technologies to receive and store certain types of 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 computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. 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.)

By using the Site, you consent to the processing of data about you by our analytics partners in the manner and for the purposes set out above. Currently, our analytics partners include, without limitation, Google Analytics, Optimizely, and Crazy Egg. In order to make sure you understand how our analytics partners handle your non-personally identifiable information and how they interact with our Site, you should visit the pages linked below for more information, as SimpliSafe has no ability to control or monitor our analytics partners’ data collection or data use practices with respect to such information. Google Analytics uses cookies to help us understand how visitors use our Site and to compile reports on website activity. For more information regarding Google Analytics please visit http://www.google.com/analytics/terms/us.html. For information on how to opt-out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/. Optimizely is a third party website optimization service that analyzes your use of our Site and our relationship with you, so that we can improve our Site. For more information on the privacy practices of Optimizely, please check https://www.optimizely.com/privacy. You can opt out from Optimizely at any time by following the instruction at http://www.optimizely.com/opt_out. Crazy Egg’s Analysis Service is a web analytics service that gives us data about where users are clicking on our Site. You can visit their privacy policy at: https://www.crazyegg.com/privacy and their opt-out feature at: https://www.crazyegg.com/opt-out).

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 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 behavior 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.

Tell-A-Friend

If you use our "tell-a-friend" feature, we ask for your friend’s name and e-mail address. We use this information only to send the communication you requested and to monitor the effectiveness of our tell-a-friend feature. By providing a name you represent that you have obtained your friend’s permission to do so, that they have given their consent to such use and have accepted this Privacy Policy and that you will inform us immediately if they withdraw their consent.

4. HOW WE USE AND SHARE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so.

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 alarm 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.

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 and editing your profile. You may also opt out of receiving commercial e-mail from us by following the instructions in each e-mail.

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.

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.

We use third parties to assist with providing our products and services to you (including our alarm monitoring services and dispatching emergency responders), host our Site, send out email updates about the Site, provide marketing and advertising services for us, 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.

Advertising. We may use 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 and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior 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. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).

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.

Legal obligations. We may use your personal data where we need to comply with a legal obligation.

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 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, your information would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer.

Where we reasonably need to access, use, preserve or disclose information as reasonably necessary to:

  • Meet any applicable law, regulation, subpoena, legal process or governmental request.
  • 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.
  • Use within the Simplisafe Group. We may share your personal data with our affiliates and group companies.

5. RIGHTS OF ACCESS, CORRECTION, ERASURE AND RECTIFICATION OF YOUR PERSONAL DATA AND CHOICES

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. If you have questions about personal information we have about you can Contact Us or call us at 0800 920 2450. You can opt-out of receiving marketing and promotional e-mails from SimpliSafe by using the opt-out or unsubscribe feature contained in the e-mails.

You can close your online account by calling us at 0800 920 2450.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.
If you have any questions about this privacy notice or how we handle your personal data, please contact us at 0800 920 2450 or via e-mail 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.

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 have a right of data portability.

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

6. SECURITY OF YOUR PERSONAL DATA

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.

7. DATA RETENTION

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 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.

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 data retention policy and applicable law.

8. CHANGES TO OUR PRIVACY POLICY

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.

9. INTERNATIONAL TRANSFERS

Our parent company is located in the United States. We will transfer certain of your personal data to servers located in the United States in accordance with the EU US Privacy Shield Framework, the EU Commission standard contractual clauses or as otherwise permitted by law. Please see our Privacy Shield Statement for more information.

10. QUESTIONS AND HOW CONTACT US

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 920 2420, or contact us by post at the following address:

SimpliSafe LTD
No. 1 Spinningfields,
Quay Street, Manchester MAN M3 3JE
Attention: Privacy Policy Feedback