Privacy Policy
LAST UPDATED: June 24, 2019
Deep Sentinel Corp. and its subsidiaries and affiliates (collectively referred to herein as “we,” “us,” “our,” or “Deep Sentinel”), respects your privacy and the importance of the information you entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand the kinds of information we may gather about you when you use the Deep Sentinel website (“Site”) or any of our Services, how we may use and disclose the information, and how you can control, correct and/or update the information. By accessing or using the Site or Services, you are accepting the policies and practices described in this Policy. Each time you visit or use the Site or Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. Any capitalized terms not defined herein shall have the meaning as set forth in the Terms of Service and/or End User License Agreement.
Please note that this Policy does not apply to your use of third-party sites, services, or applications you may access through the Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.
In this Policy, the term Services included all Deep Sentinel Products as well as Deep Sentinel Software (including Deep Sentinel Web Apps and Deep Sentinel Mobile Apps), and Deep Sentinel LiveSentinel services as defined in the Terms of Service. This policy applies in circumstances where we are acting as a data controller with respect to the Personal Information (as defined herein) of Users of our Site and/or Services; in other words, where we determine the purposes and means of the processing of that Personal Information.
INFORMATION WE MAY COLLECT
When you install certain Services, you’ll be asked questions in order to help us create an initial program. For example, we’ll ask for information related to camera location, as well as your address or postal/ZIP code. This information helps us to customize your experience by, for example, retrieving weather information for your neighborhood or by enabling intelligence around products in your home when you leave and when you come back. In addition, and for purposes of providing the Services to you, we collect certain information that can identify you (“Personal Information”), such as your name and contact information (email, address, company affiliation and phone number), as well as financial information such as credit card details. Personal Information also includes, for purposes of this Policy, the definition of personal data as such term is defined in Article 4(1) of the GDPR. We will never sell, rent, trade or use your Personal Information other than as specifically needed to provide the Services specifically requested by you. Deep Sentinel discloses Personal Information only to those of its employees, contractors, affiliated organizations and subcontractors that (i) need to know the information in order to process it on yours and our behalf, and (ii) that have agreed in writing to non-disclosure restrictions at least as strong as those herein.
The following types of information will or may need to be provided:
- Wi-Fi Network Information: To connect devices or sensors to the Services, or to access the Services over the Internet from a computer, a smartphone or a tablet, you will need to connect it to your Wi-Fi network. During setup, Deep Sentinel may ask for your Wi-Fi network name (SSID) and password to connect to the Internet or to connect Deep Sentinel devices together. This information may be saved on the device or in Deep Sentinel’s servers, along with your IP address, so that you can access it and control it from your computer, smartphone or tablet, and so that it can communicate with Deep Sentinel servers and download software updates. Once connected to your account, your devices regularly send the data as provided for herein (excluding your Wi-Fi password) to Deep Sentinel to provide you with the Services.
- Additional Authorized Users: Deep Sentinel may provide you with the ability to enable additional authorized users to access your account or parts of your account. If you do so, the additional authorized users may control and view some or all of your devices and content. An invited user must have or create a Deep Sentinel account, and information about invited users (like email address, name, or changes to product settings) will be stored with their account and will be governed by this Policy as its own account.
- Email Addresses and/or mobile phone: When you create a Deep Sentinel account, we collect and store your email address and/or mobile phone (from here, your “Contact Information”). From that point forward, your Contact Information is used for communications from Deep Sentinel. In addition, Deep Sentinel may provide you with the ability to enable individuals to access your account or to invite other individuals such as friends or family to share access to your content such as recorded video footage. We will ask you for the Contact Information of any such individuals and automatically send an invitation on your behalf. Deep Sentinel stores this information to send this invitation, to register your friend if your invitation is accepted, and to track the success of our invitation services.
- Basic Profile Information: Your account allows you to provide certain basic profile information like your name and profile photo. Names and profile photos may be shown to others in connection with the Services. For example, if you invite someone as an additional authorized user, he or she will be able to see your name and photo. You should only use photos you are willing to make public.
- Mobile location data: You may choose to enable features share location data from your mobile device or from additional authorized users. This data may be processed or combined with data from other products to enhance features for Deep Sentinel.
When you access or use the Site or Services, we automatically collect information about you, including some or all of the following:
- Log Information: We log information about your use of the Site or Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Site or Services. Publicly available tools can sometimes provide the approximate location for IP addresses.
- Device Information: We collect information about the computer or mobile device you use to access the Site or Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information. Also, we collect video and audio signals and data as well as environmental data and technical information from your cameras, sensors and other devices.
- Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored in device memory that help us to improve the Site and your experience, see which areas and features of the Site are popular, and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in the Site or emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon.
We also may collect other types of information in the following ways when you visit or use the Site or Services:
- Details of how you used and interacted with the Site or Services, such as your search queries and how you responded to certain questions.
- Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
- Our server logs automatically collect information, such as your IP address, your browser type and language, and the date and time of your visit, which helps us track your movements around the Site or Services and understand trends.
We may also obtain information from other sources and combine that with information we collect through the Services. For example, we may collect information about you from third parties who provide services on our behalf, such as maintaining and monitoring usage of the Site and Services and processing payment transactions.
USE OF INFORMATION
We may use information about you for various purposes, including the following:
- Provide, maintain, and improve the Site and Services;
- Provide and deliver the products and services you request, process transactions, and send you related information;
- Verify your identity and, if applicable, authorization for you to use the Site and Services;
- Process payment for Services you order;
- Manage your account;
- To prevent or address service, security, technical issues or at your request in connection with customer support matters;
- Respond to your comments, questions, and requests;
- Send you technical notices and other administrative messages;
- Communicate with you about products and services, offered by us or others, and provide news and information we think will be of interest to you;
- Monitor and analyze trends, usage, and activities in connection with the Site and Services;
- Conduct research, analysis, and surveys;
- Personalize and improve the Site and Services and provide content or features that match user profiles or interests;
- Enforce our Terms of Service and End User License Agreement;
- Ask you to participate in surveys;
- Link or combine with information we get from others in connection with the Services; and
- Carry out any other purpose for which the information was collected.
This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with an identifiable User of the Site or Services.
SHARING OF INFORMATION
We may share or transfer information about you as follows or as otherwise described in this Privacy Policy:
- With vendors, consultants, subcontractors and other service providers who need access to such information to carry out work on our behalf. For example, we have service providers who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers for technical problems. These parties only have access to such information as necessary to perform their functions and may not use it for any purpose other than to provide services to us;
- In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
- If we believe your actions are inconsistent with the spirit or language of our Terms of Service or other agreements or policies, or to protect the rights, property, and safety of you, us, or others;
- In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company (we will request a purchaser to treat our data under the privacy statement in place at the time of its collection);
- With your consent or at your direction. One example of this would be if you invite another user to access the Services on your account as an additional authorized user. Another example is if you sign up for programs offered by our partners; if you do this, we may share certain information with the partner, but again only with your explicit consent. 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 Deep Sentinel Products, 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.
PAYMENT INFORMATION
Deep Sentinel may collect credit card or additional payment information from you. However, it’s important to note that we do not store any of this payment information or process any of your payments on our servers, but rather use a third party payment processor that handles such transactions (“Payment Processor”). Therefore, any information regarding your payment processing and security must be verified in Payment Processor’s own Terms of Service Agreement and Privacy Policy. Payment Processor may provide us with unique authentication tokens to make payment requests with. Payment Processor may also provide us with information such as your name, credit card type, expiration date, and the last four digits of your credit card number. This information is used only for the purposes of completing transactions you have initiated through the Services, protecting against or identifying possible fraudulent transactions, and otherwise as needed to manage the Services.
ANALYTICS SERVICES
We may allow others to provide analytics services in connection with the Services. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Site and Services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, personalize the user experience, and better understand your activity.
RETENTION
We will retain your Personal Information for the period of time that is necessary to fulfil the original purposes for which it has been collected. At the end of that retention period, your data will either be deleted completely or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. Please keep in mind that, in certain cases, a longer retention period may be required or permitted by law or to allow us to pursue our business interests, conduct audits, comply with our legal obligations, enforce our agreements or resolve any dispute. We may also retain cached or archived copies of information about you for a certain period.
The criteria used to determine our retention periods include:
- Time needed to provide you with our Services or to operate our business.
- Whether your account with us is active. You may contact us to make your account inactive at any time.
- Legal, contractual, or similar obligations to retain your data, such as mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation, or data that must be retained for the purposes of contract or litigation.
Please note that we are not responsible for storing any information that you provide to us or for any content or information that we provide to you. You are solely responsible for retaining backup files of any information and content that you provide or receive in connection with the Site or Services.
Deep Sentinel has specific data retention policies for the following types of data:
- Video data on your hub. Videos are stored on your hub until space is needed. The Deep Sentinel software running on your hub will intelligently select how long videos will be retained here based on the importance of a video.
- Personal Data on Deep Sentinel Servers. Deep Sentinel generally stores your personal information on Deep Sentinel’s servers until you delete or edit it, or for as long as you remain a Deep Sentinel customer in order to provide you with Deep Sentinel Products or Services. You can access, amend or delete your personal information from Deep Sentinel’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.
- Video Data on Deep Sentinel Servers. Deep Sentinel will retain video data on Deep Sentinel Servers under three types of circumstances:
- To deliver or improve Products. Videos that are being used to improve the Products and Services may be retained for up to 24 months. If you wish to have specific videos removed from this use, simply contact customercare@deepsentinel.com
- Videos reviewed by LiveSentinel guards. Videos that have been viewed by a LiveSentinel guard may be retained for up to 24 months.
- Videos resulting in a LiveSentinel interaction or a request for support from police or another private security firm may be retained up to 24 months, or until the extent of the statute of limitations of any potential legal action, whichever is longer.
SECURITY
We work hard to protect your information and take appropriate commercially reasonable physical, electronic, and other security measures to help safeguard information and data from loss, unauthorized access, alteration, misuse or disclosure. Our security practices include:
- Encrypting many of our Services using SSL;
- Frequent review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
- We secure access to all transactional areas of our websites and apps using ‘https’ technology.
- Access to your Personal Information is password-protected, and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected.
- We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
- Physical safeguards, with locked doors and file cabinets, controlled access to our facilities and secure destruction of media containing your Personal Information
- Technology safeguards, like the use of anti-virus and endpoint protection software, and monitoring of our systems and data centers to ensure that they comply with our security policies
- Organizational safeguards, like training and awareness programs on security and privacy, to make sure employees understand the importance and means by which they must protect your Personal Information
No method of transmission over the Internet or method of electronic storage is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Deep Sentinel does not seek to collect sensitive Personal Information (also known as special categories of data as defined in Article 9 of the GDPR). If we do so we will always collect the data in accordance with applicable data privacy requirements. If you choose to provide us with unsolicited sensitive Personal Information, you will be asked to consent to our processing of such data on a case-by-case basis by using a specific express consent form.
OTHER WEBSITES AND OTHER PRODUCTS
This Privacy Policy applies only to information we collect at and through our Site or Services. The Site and Services may contain links to or embedded content from third party websites. A link to or embedded content from a third party website does not mean that we endorse that third party website, the quality or accuracy of information presented on the third party website or the persons or entities associated with the third party website. If you decide to visit a third party website, you are subject to the privacy policy of the third party website as applicable and we are not responsible for the policies and practices of the third party website. We encourage you to ask questions before you disclose your information to others.
Any data that Deep Sentinel receives from third-parties will be processed and stored by Deep Sentinel and will be treated in accordance with this Privacy Statement. This information may be processed in the same ways as any other data that is a part of your Deep Sentinel account or the Deep Sentinel logs.
If you select an outside party for the purchase, installation, or service of your Deep Sentinel device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you use the Services but purchase your cameras from an independent 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.
DO NOT TRACK
Some web browsers incorporate a “Do Not Track” (DNT) or similar feature that signals to websites that a visitor does not want to have his/her online activity and behavior tracked. If a website operator elects to respond to a particular DNT signal, the website operator may refrain from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus for how companies should respond to "do not track" signals, although one may develop in the future. We do not respond to "do not track" signals at this time; if we do so in the future, we will describe how in this Privacy Policy.
CALIFORNIA PRIVACY RIGHTS
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to customercare@ DeepSentinel.com.
CHILDREN UNDER THE AGE OF 18
The Site and Services are intended for users who are eighteen (18) years of age and older. If you are under the age of eighteen (18), you are not permitted to submit any Personal Information to us.
TRANSFER OF PERSONAL INFORMATION; INTERNATIONAL VISITORS
The Site and Services are provided for access and use by persons located in the United States. If you use the Site and Services from outside of the United States, you do so at your own risk. You are solely responsible for ensuring compliance with the laws of your specific jurisdiction, including the specific laws of your jurisdiction regarding the import, export, or re-export of the Services. If you are outside the United States, you acknowledge that by providing your Personal Information, you are: (a) permitting the transfer of your Personal Information to the United States which may not have the same data protection laws as the country in which you reside; and (b) permitting the use of your Personal Information in accordance with this Privacy Policy.
Protecting your data outside the United States
We may transfer Personal Information that we collect from you to third-party data processors in countries that are outside the United States. For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the United States. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our compliance department. Any transfer of your Personal Information will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
For all non-US customers
By using our services or providing your Personal Information to us, you expressly consent to the processing of your Personal Information by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your Personal Information between countries to enable us to supply the Services you’ve requested. In the ordinary course of business, we may transfer your Personal Information from your country of residence to ourselves and to third parties located in and outside the United States.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your Personal Information outside your country of residence for our ordinary business purposes. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using Deep Sentinel Products in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, you consent to the transfer of your personal data to the United States and other countries where Deep Sentinel operates.
This may occur because our information technology storage facilities and servers are located outside your country of residence, and could include storage of your Personal Information on servers in the United States or in other countries.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your Personal Information in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your Personal Information.
YOUR RIGHTS / OPTIONS
Access and Control of Your Personal Information
You may request updates, corrections or deletions of Personal Information at any time by contacting us at customercare@DeepSentinel.com. Whenever you have given us your consent to use your Personal Information, you have the right to change your mind at any time and withdraw that consent.
- Access to personal information: you have the right to request what Personal Information we hold about you subject to our right to identity verification. If you request a copy of your data, we may charge you a fee, except where this is not permissible under applicable law.
- Correction and deletion: in some jurisdictions, including the EU (according to data protection laws for data subjects in the EU), you have the right to correct or amend your Personal Information if it is inaccurate or needs to be updated. You may also have the right to request the deletion of your Personal Information, however this may not be always possible due to legal requirements and other obligations to keep such data. If we are asked to delete your data, we may keep some minimal information about you to be able to demonstrate that we have fulfilled our obligations.
- Filing a complaint: In some jurisdictions, including according to data protection laws in the EU for complaints issued from subjects in the EU, you have the right to lodge a formal complaint with a data protection authority.
- Marketing preferences: We may send you marketing communications about our services, via different channels such as email, phone, SMS, postal mailings and third-party social networks, in accordance with relevant marketing laws. When required by applicable law, we will obtain your consent before starting these activities.
Third Party Marketing Communications
Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of the Services. If this changes at any point in the future, we will be required to ask you first—but let’s be absolutely clear. We do not plan on making this change, and if we do make this change at some point, you would need to opt-in to such a change. Unless you proactively agree to participate, your information will never be shared by Deep Sentinel with a third party for marketing purposes unrelated to Deep Sentinel Products and Services.
Marketing Communications: Opt Out
You may opt out of receiving marketing communications from us by following the instructions in those communications or by emailing us at customercare@DeepSentinel.com. In such cases, we will retain minimum Personal Information to note that you opted out in order to avoid contacting you again. Please note that even if you opt out from receiving marketing communications, we may still send you administrative communications, such as technical updates for our Services, order confirmations, notifications about your account activities, and other important notices.
PRIVACY POLICY CHANGES
Deep Sentinel reserves the right to change, modify, add, or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt out of such differing uses. Your continued use of the Site or Services after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to review this Policy regularly.
HOW TO CONTACT US
If you have any questions about this Policy, or our information practices, please contact us by email at customercare@DeepSentinel.com.