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Cyber Security Statement
Guidelines for Retail Partners
End User License Agreement
Limited Hardware Warranty
Surge Protector Equipment and Connected Equipment Replacement Policy
Partner Code of Conduct
- All other websites that link to this Policy
The sites are operated by us or on our behalf. This policy also covers the use of any of our connected devices and related applications (“Devices”) (including but not limited to, 4Sight, Araknis, Control4, Episode, Luma, Visualint, Wattbox, OvrC, Dragonfly, Triad and SunBrite). We are committed to protecting and respecting your privacy. This policy sets out:
- Information we collect about you
- Cookies and other technologies
- How we use your information
- Our promotional updates and communications
- Who we give your information to
- Where we store your information
- How we protect your information
- How long we keep your information
- Your rights
- Changes to this policy
- How to Contact us
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Snap One, LLC or one of its affiliates or subsidiaries is the data controller, as this term is defined in the GDPR, or any other applicable European Economic Area data protection law (the “European Data Law”), with respect to the data we collect from you. We may also act as a data processor in certain circumstances.
Information we collect about you
As a preliminary matter, we do not process sensitive personal data (called Special Category data in European Data Law) or information about children. We will collect and process the following personal data from you:
Information you give us
This is information about you that you give us directly when you interact with us.
This includes information about you that you give us by filling in forms on our sites or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our sites, register purchases with us, subscribe to our services, search for a product or an independent Dealer, place an order on our sites, participate in discussion boards or other social media functions on or via our sites, enter a competition, promotion or survey, submit a query, and when you report a problem with our sites.
The information you give us may include your name, address, e-mail address and phone number, employer, title/position/role, financial and credit card information, personal description and, login and password details.
We may also ask you to provide details of the products you use (either our products or third party products connected to our products) such as model or serial number. We will also ask you for information about problems with our products or services, related incidents or support needs. You may not be able to configure your device until you have accepted our End User License Agreement and once you have done so we will keep a record of your acceptance.
Information we collect about you from your use of our sites
We will automatically collect information from you each time you visit our sites. This includes technical information and information about your visit.
Technical information may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
Information about your visit may include the full Uniform Resource Locators (URL); clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); methods used to browse away from the page; and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
Information we receive from our products and other sources
If you use our products and services we will collect information about the extent, nature and frequency of your usage as part of our monitoring of the products (to make sure that they continue to be operational and fit for purpose) from third parties we work closely with. Through your use of our products we will collect:
- Model and serial numbers of those products
- Media Access Control (MAC) address of those products
- The version and type of software collected
- Names of third party services and devices with which you integrate, potentially including usernames and passwords you input
- Names you give to rooms/locations where you have connected Devices
- Your location
Information about how you have configured our Devices.
- If you use our products and services we will collect information about how you have configured our Devices, and, if you use our networking products with our remote monitoring capability, similar identifying information, configuration and status information about devices you have connected to your network.
Some Devices may also inform us of:
- When, where and how you use them
- Your Device settings and alterations you make
We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, and search information providers). Our partners (such as the independent Dealers) should have their own privacy policies about how they use your data, that they will make available to you, including with respect to any data they collect and use to remotely monitor and troubleshoot your system.
Cookies and other technologies
Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent automatic acceptance and your help screen or manual will tell you how to do this. We also give you information about how to disable cookies in the section titled ‘Disabling Cookies’ below. However, you may not be able to take full advantage of our sites if you do so.
A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser. Others (including third party cookies) are used to remember you when you return to the site and will last for longer.
We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.
- Strictly necessary cookies. These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our sites, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate interests of improving the way our sites work, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognize you when you return to our sites. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our sites more relevant to your interests. We may also share this information with third parties for this purpose.
We may also work with advertising networks that gather information about the content on our sites when you visit and information on other websites and services. This may result in you seeing our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off, see the section below titled Disabling cookies.
The effect of disabling cookies depends on which cookies you disable. However, in general, our sites may not operate properly if all cookies are switched off.
If you want to disable cookies on our sites we provide visitors with tools to assist with this. You may click here to access our cookie management tool for this site. In addition, we are required by law to give users the option to manage their cookies when they visit our sites. In addition, if you ever want to independently manage cookie usage, you may change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
You can see further details on how to disable cookies for the most popular browsers below:
For Microsoft Internet Explorer:
- Choose the menu “tools” then “Internet Options”
- Click on the “privacy” tab
- Select the setting the appropriate setting
For Google Chrome:
- Choose Settings then Advanced
- Under “Privacy and security,” click “Content settings”.
- Click “Cookies”
- Choose Preferences then Privacy
- Click on “Remove all Website Data”
For Mozilla Firefox:
- Choose the menu “tools” then “Options”
- Click on the icon “privacy”
- Find the menu “cookie” and select the relevant options
- From the “setting” menu Select “Quick Preferences”
- To disable cookies: uncheck “Enable Cookies”
How we use your information
We use information held about you in the following ways:
- Take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between you and us including:
- Provide you with support services and device maintenance that you have signed up for.
- Notify you about changes to our products and services.
- Provide you with information about our products or services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See the section titled ‘Our promotional updates and communications’ of this Policy.
- Ensure in our legitimate interests that:
- Content from our sites is presented in the most effective manner for you and for your computer or device.
- We provide you with the information, products and services (including support services) that you request from us.
Information we collect about you from your use of our sites and connected products and your engagement with emails we send you
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- To keep our sites safe and secure.
- For measuring or understanding the effectiveness of marketing we serve to you and others, and to deliver relevant marketing to you.
- To improve our sites to ensure that content is presented in the most effective manner for you and for your computer or devices.
- To allow you to participate in interactive features of our products or services, when you choose to do so.
- We may use the location of your device to provide location dependent features, such as to determine the sunrise/sunset times or likely temperatures, if you have configured your Devices to require such information e.g. to open blinds or turn on heating.
- Depending upon how you configure your devices, we may use data from some Devices to trigger specific actions from other devices or to provide you notifications (e.g. automatically locking doors when alarms sound or an auto-generated message to you checking whether you meant to lock your doors or leave a window open).
Information we receive from other sources
We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your privacy rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
We may link your account or system to a specific independent Dealer of record, but will allow you to amend this information upon request.
Our promotional updates and communications
Where permitted in our legitimate interest or with your consent, we will use your personal data for marketing analysis and to provide you with promotional update communications by email about our products and services.
You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you.
Who we give your information to
We may give your information to:
- Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, who support our processing of personal data under this policy. If any of these parties are using your information for direct marketing purposes, we will only transfer the information to them for that purpose with your consent.
- Selected third parties.
Our selected third parties may include:
- Organizations who process your personal data on our behalf and in accordance with our instructions and the law (including European Data Law, if applicable). This includes in supporting the services we offer through our sites in particular those providing website and data hosting services, providing fulfilment services, distributing any communications we send, supporting or updating marketing lists, facilitating feedback on our services and providing IT support services from time to time. We require these organizations (which may include third party suppliers, agents, sub-contractors and/or other companies in our group) to only use your information to the extent necessary to perform their support functions.
- An independent Dealer authorized to sell, install, or service our products, but only when we are authorized by you to do so.
- Analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy (this will not identify you as an individual).
- Payment processing providers who provide secure payment processing services.
We will disclose your personal data to third parties:
- If Snap One, LLC or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime (having sought your consent where we are required by law to do so).
- To protect the safety of other users, employees and members of the public and their property.
- If required by an audit.
We only share personal data to the extent necessary to meet a legitimate purpose. Wherever possible we will redact, anonymize or pseudonymize personal data before processing or sharing.
Where we store information collected in the EEA
With respect to information collected inside the European Economic Area (“EEA”), such data may be transferred to, and stored at, a destination outside the EEA that may not be subject to equivalent European Data Law.
We may transfer your personal data outside the EEA:
- In order to store it.
- In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services.
- Where we are legally required to do so.
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
We may transfer your personal data to the following countries and using the following safeguards outside the EEA:
- United States – Transfers will be made pursuant to Standard Contractual Clauses (SCC), as approved by the European Commission.
A note on Standard Contractual Clauses
The European Commission has approved the use of Standard Contractual Clauses to ensure adequate protection when transferring personal data outside of the EEA. By incorporating standard contractual clauses into our agreements between the parties transferring personal data, that information is considered protected when transferred outside the European Economic Area or United Kingdom to the United States.
A note on Privacy Shield
The Privacy Shield was invalidated by the Court of Justice of the European Union on July 16, 2020 so we no longer rely on it to transfer personal data that originated in the European Economic Area or the UK to the U.S. Up until the July 16, 2020 decision, we had formally certified to the Department of Commerce that we adhere to the Privacy Shield Principles. Because the Privacy Shield, was invalidated, we have not recertified for 2021 and have withdrawn from the program; however, we continue to apply the Privacy Shield principles and comply with Privacy Shield obligations related to protecting personal data that we received while participating in the Privacy Shield. To learn more about the Privacy Shield Principles and to view Snap One, LLC’s Privacy Shield certification status, visit https://www.privacyshield.gov.
The following entities were included in Snap One, LLC’s Privacy Shield Certification:
- Sunbrite TV, LLC
- Volutone, LLC
- Remote Maintenance Systems, L.P.
- MyDigitalShield, Inc (OmniNet Inc.)
How we protect your information
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
How long we keep your information
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and provide the services you’ve requested and as reasonably necessary to identify any issues and resolve any legal proceedings or as otherwise required by law. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
You have the right under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned in ‘Our promotional updates and communications’ section;
- to request that your provided personal data be moved to a third party.
Your right to withdraw consent:
Where the processing of your personal data by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us. You can also change your marketing preferences at any time as described in the section titled ‘Our promotional updates and communications’;
Be assured, however, that we do not sell or rent your personal data to any third-party marketers for their own use.
You can also exercise the rights listed above at any time by contacting us at email@example.com. If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (in Europe see see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).
Changes to this policy
Snap One, LLC
Attention: Data Privacy Officer
11734 S. Election Road
Salt Lake City, UT 84020
This policy was last updated February 19, 2021.