Privacy Statement for Hipcam Products and Services

At Hipcam, we take your privacy seriously.

This Privacy Statement for Hipcam Products and Services (“Privacy Statement”) describes information that Hipcam Global LLC and its subsidiaries and affiliates (collectively, “Hipcam”) collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).

This document focuses on information related to the operation of Hipcam products and services, including the Hipcam indoor Cam, Hipcam outdoor Cam, Hipcam Doorbell, and other products from Hipcam (collectively, “Hipcam Products”). In this Privacy Statement, the expression “ Products” also includes our Web Apps, Mobile Apps, and Subscription Services as defined in our Terms of Service.

We provide additional details about how we collect and use information from our public web sites in our Privacy Policy for Hipcam Web Sites.

Your Permission: Permission for data collection and processing. By using Hipcam Products, you agree to allow us to collect and process information as described in this Privacy Statement.

International data transfers. Your personal information may be collected, processed and stored by Hipcam or its service providers in the United States and other countries where our servers reside. 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 Hipcam Products in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, you agree to the transfer of your personal data to the United States and other countries where Hipcam operates.

What information does Hipcam Protect collect?

Hipcam Protect collects:

• Setup information you provide
• Environmental data from the Hipcam Protect’s sensors
• Technical information from the device

Setup information you provide: When you install Hipcam Protect, you’ll be asked for information like your home address or postal/ZIP code as well as where in your home you’re installing it. This information helps to customize your experience by, for example, enabling Hipcam Protect to inform you where an event is occurring, or to better schedule features like Sound Check to run during certain hours of the day.

Environmental data from Hipcam Protect’s sensors: We collect data from several sensors built into Hipcam Protect. These sensors collect data such as smoke and carbon monoxide (CO) levels, current temperature, humidity and ambient light in the room. They can also sense whether something in the room is moving. By recording this information, Hipcam Protect can do things like detect smoke and CO in your home, and give you alarms and warnings. For example, if Hipcam Protect sees that smoke or CO levels are rising, it will give you a Heads Up before the danger reaches emergency alarm levels and tell you what the danger is. Hipcam Protect 2nd generation also contains a microphone, which enables Hipcam Protect to deliver certain enhanced features. Specifically, Hipcam Protect emits sound samples during Safety Checkup or Sound Check that the microphone will capture to verify that the speaker and horn are functioning.

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with Hipcam Protect, we record your Hipcam Protect model and serial number, software version, and technical information such as sensor status, Wi-Fi connectivity, and battery charge level.

What information does Hipcam Indoor Cam, Hipcam Outdoor Cam, and/or Hipcam Doorbell (collectively, “Hipcam Cam”) collect?

Hipcam Cam collects and enables you to collect:

• Setup information you provide
• Environmental data from Hipcam Cam sensors
• Video and audio signals and data
• Facial recognition data to enable Familiar Face Alerts feature
• Technical information from the device
• Shared content

Information input during setup: When you install Hipcam Cam, you’ll be asked for certain basic information like your camera name, camera description, home address, ZIP/postal code, as well as where in your home you’re installing Hipcam Cam. This information is used to personalize your experience – for example, to tell you which device is triggering a notification.

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

Video and audio signals and data: Hipcam Cam enables you to determine the purpose and the means for which you collect video and audio signals data. When you enable the recording or streaming features of your Hipcam Cam, we may record and process video and/or audio recordings from the device, subject to your instruction, configuration and settings. This may include capturing and emailing to you portions of this data as part of a notification or analyzing the data to identify motion or other events. If you instruct us by setting up your camera and choosing to receive mobile notifications, we may process information from your Hipcam Cam to send you alerts when something happens. In addition, if you have the recording features enabled, we will capture, process and retain video and audio data recordings from your device for the duration of your recording subscription period (for example, 5, 10 or 30 days) and you will be able to access those recordings using the Services during that time.

Facial recognition data to enable Familiar Face Alerts feature: If you choose to use the familiar face alerts feature on your Hipcam Cam, we will process face images and underlying face prints for the purpose of enabling your device to recognize familiar faces and to notify you of familiar and unknown people. Using the app and your account, you control whether this biometric processing occurs. Depending on where you live and how you configure the Products and Services, you may need to get explicit consent to scan the faces of people visiting your home.

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

Saved and Shared Content: Hipcam Cam enables you to determine the purpose and the means for which you save and share content. You may save and may choose to share certain content like video clips, live video streams, images, captions, and comments for other people to access using the Services. We will collect and store information that will allow us to save or share your content at your instruction through the Services.

Hipcam Cam is primarily intended for purely personal or household use. However, data protection and privacy laws in your country may impose certain responsibilities on you and your use of Hipcam Cam. You (not Hipcam) are responsible for ensuring that you comply with any applicable laws when you use Hipcam Cam. For example, you may need to display a notice that alerts visitors to your home that you are using Hipcam Cam and/or obtain their explicit consent depending on the purpose and the means of your processing activities. Note in particular that recording and sharing clips that involve other people, public spaces and/or scans of peoples’ faces may affect individuals’ privacy and data protection rights.

What information does Hipcam Protect (including Hipcam Assist, Hipcam Detect and Hipcam Hipbox) collect?

Hipcam Secure collects:

• Setup information you provide
• Data from device sensors
• Usage and performance information
• Technical information from the device

Information input during setup: When you install Hipcam Protect, you’ll be asked for certain basic information such as home address, ZIP/postal code, the location of where in your home you’ve installed your Assist and Detect devices, and custom labels for those devices. This information is used to personalize your experience—for example, to tell you which device is triggering a notification or an alarm, or by enabling Home/Away Assist to automatically remind you to arm the Hipcam Protect system when you leave the house.

Data from device sensors: We collect data from several sensors built into Hipcam Protect devices. For example, Hipcam Detect can detect motion or whether a window or door is open or closed, depending on how you’ve set up the device in your home. These devices can sense whether something in the room is moving and then sound an alarm and/or send you a notification. Sensors also collect data such as device temperature and ambient light in the room.

Usage and performance information: We collect information about your use of Hipcam Protect, including activities you perform (such as arming or disarming the system or changing settings), activities Hipcam Protect performs (such as sounding an alarm or sending a notification), your responses to our notifications, and which Hipcam Protect products you add to your Hipcam account.

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with Hipcam Protect, we record device model and serial number, software version, and technical information such as sensor status, Wi-Fi connectivity, error logs, power status and battery charge level, and whether product features are working properly.

What information is shared among multiple connected Hipcam Products?

If you have multiple Hipcam Products interfacing with one another, the products will share certain information with each other, such as data on whether something in the room is moving, temperature data, and the occurrence of smoke or CO alarms. This sharing may occur locally among connected devices (both Hipcam and third-party devices). Sharing can also occur between Hipcam Products and your mobile device or application, or among Hipcam's servers.

Hipcam offers a Home & Away Assist feature that uses the information collected from your Hipcam Products and, if you enable it, the location of a paired phone, to determine whether anyone is home or away. You can configure your Hipcam Products to react to the determination of “Home” or “Away” status. For instance, your Hipcam cameras can turn on when you are away and turn off when you are home.

How does my Hipcam Product or account interact with third parties?

If I use Works with Hipcam to connect third-party products and services to Hipcam, will information be shared? When you choose to connect third-party products and services through Works with Hipcam, you are shown details about any proposed exchange(s) of data between Hipcam and the third party that is providing the product or service. Hipcam or the third party will instead (or also) ask for consent to control the products that you have connected. Your consent is required to allow any of these exchanges or requests for control and you will be able to revoke it at any time.

Is information shared with or received from third parties, outside of the Works with Hipcam program? Hipcam may share information with third parties with your permission. For example, when you enroll in a rewards program for Hipcam Products offered by our partners – such as Rush Hour Rewards or Safety Rewards – you may be asked for your permission to share certain data between Hipcam and our partner. Hipcam requires your permission before sharing information in these circumstances. We may also receive information from our partners and other sources and combine that with the information in your Hipcam account. For example, in order to offer rewards programs, we might receive information (such as which of our partners offers services where you live) to determine eligibility and efficacy of our programs.

Additional information about the limited circumstances in which information from your Hipcam account may be shared with third parties is described below in the section titled "In what circumstances does Hipcam share my information?".

Any Hipcam data that you choose to share with a third party is governed by that third party’s privacy policy while in that party’s possession.

Any data that Hipcam receives from third-parties will be processed and stored by Hipcam 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 Hipcam account or the Hipcam logs.

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

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

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

Additional Authorized Users: Hipcam may provide you with the ability to enable additional authorized users to access your account. If you do so, the additional authorized users may control and view all of your devices, content, and Works with Hipcam connections. Invited users may also add additional authorized users to your account, so be careful to add only those you trust. An invited user must have or create a Hipcam account, and information about invited users (like email address, name or changes to product settings) will be stored with your account.

Email Addresses: When you create a Hipcam account, we collect and store your email address. From that point forward, your email address is used for communications from Hipcam. In addition, Hipcam may provide you with the ability to enable individuals to access your account as additional authorized users, 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 email address of any such individuals and automatically send an email invitation on your behalf. Hipcam stores this information to send this email, 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. In addition, if you download the Hipcam Mobile App, we may collect and store your mobile device identifiers (such as IDFA, AAID, or other device identifiers). 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 like Home/Away Assist or device pairing. If you do this, you’ll be asked for permission to share location data from your mobile device. If you grant this permission, the Hipcam app uses standard location services built into iOS and Android. This data may be processed or combined with data from other products to enhance features like Home & Away.

Remember that when you visit our Sites, we collect personal information as described in our separate Privacy Policy for Hipcam Web Services. Like most Internet sites, we routinely record log entries (including information such as your IP address) and technical information (such as your browser type and version) when your browser, mobile device or Hipcam Product contacts our servers.

How does Hipcam use the information it collects?

We use this information to provide, develop and improve Hipcam Products and services, including to make assessments and recommendations about products, safety, or energy use. We may use your contact details to send you this information, or to ask you to participate in surveys about your Hipcam use, and to send you other communications from Hipcam.

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

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

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

In general for purposes of applicable law (e.g., GDPR), Hipcam is a controller of the information collected in connection with the Products and Services. However, in the case of “Video and audio signals and data” and “Facial recognition to enable Familiar Face Alerts feature” you are the controller of these data and Hipcam is a processor.

Our legal bases for processing information

If European data protection law applies to the processing of your information, we process your information for the purposes described in this Privacy Statement, based on the following legal grounds:

When we’re providing a product or service

We process your data to provide and support a product or service you’ve asked for under a contract, including but not limited to delivering our Terms of Service.

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties while applying appropriate safeguards that protect your privacy. This means we process your information for things like:

• Offering and improving Hipcam Products and services
• Developing new products and features
• Understanding how people use our products and services
• Performing research that improves our services for our users and benefits the public
• Sending you direct marketing and other communications from Hipcam
• Protecting against harm to the rights, property, and safety of Hipcam, our users, and the public
• Detecting, preventing or otherwise addressing fraud, abuse, security or technical issues with our services
• Maintaining and improving the integrity of our computing systems, and protecting our users' data security
• Enforcing legal claims, including investigation of potential violations of applicable Terms of Service

When we’re complying with legal obligations

We process your data when we have a legal obligation to do so, for example, if we’re responding to a legal process or an enforceable governmental request.

With your consent We ask for your consent to process your information for certain specific purposes and give you the right to withdraw that consent at anytime.

In what circumstances does Hipcam share my information?

Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of Hipcam Products and services without asking you first. Period. We do not rent or sell our customer lists. The following are the limited situations where we may share personal information:

• With your permission: We may share personal information when we have your permission. One example of this would be if you invite another user to access the Products on your account as an additional authorized user. Another example is if you sign up for programs offered by our partners (e.g., energy or insurance companies); if you do this, we may share certain information with the partner. This could include things like your enrollment information and the activation status of your device. If you connect third-party devices and services to your Hipcam Products through the Works with Hipcam program, you are shown information about any proposed exchange of data. Hipcam or the third party will request your consent to these exchanges on your behalf and you can change your mind at any time. When you use third-party products and services integrated with the Hipcam Products, their own terms and privacy policies will govern your use of those products and services.
• For external processing: We have vendors, service providers, and technicians 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 technicians (as well as Hipcam employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-Hipcam purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to video data.
• As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.
• For legal reasons: We will share personal information with third parties if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process or enforceable government request; (ii) enforce Hipcam policies or contracts, including investigation of potential violations; (iii) detect, prevent or otherwise address fraud, security or technical issues; (iv) protect against harm to the rights, property or safety of Hipcam, our users or the public as required or permitted by law.

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

If you select an outside party for the purchase, installation or service of your Hipcam device and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. Always check the privacy policies for any company that collects your personal information.

What choices do I have and how can I delete my personal information?

Hipcam generally stores your personal information on Hipcam’s servers until you delete or edit it, or for as long as you remain a Hipcam customer in order to provide you with Hipcam Products. In addition, Hipcam may store your personal information to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

As described above, some information is processed and stored directly on the Hipcam device. Personal information from Hipcam devices is encrypted while it is being transmitted to Hipcam.

You can delete the information on the Hipcam device by resetting it to the defaults (using Reset in the Settings menu).

You can access, amend or delete your personal information from Hipcam’s servers through the controls in your account. Hipcam customers can also request their Hipcam data by visiting app.hipcam.com/legal/privacy-policy. Learn more about our data retention practices at www.hipcam.com/data-retention.

How does Hipcam protect my personal information when it is transferred internationally?

When we transfer personal data from the European Economic Area and Switzerland to other countries, including to the United States, we use a variety of legal mechanisms to help ensure your data is appropriately protected.

We may share, as described in this Privacy Statement, information with our affiliates and subsidiaries, and third parties. We may disclose information in response to legal process and lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security.

Minors

Only individuals aged 18 and older are permitted to act as Owners of Hipcam Accounts. Authorised Users must be over the age of 13 (or equivalent minimum age in the jurisdiction where they reside) and may use the Products and Services under the supervision of a parent or legal guardian and only if they agree to be bound by these Terms on your behalf. Hipcam Products and Services do not knowingly collect or store any personal information from anyone under the age of 13.

Can the Privacy Statement be changed?

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

How can I contact Hipcam?

For users in the United States and other countries outside of the European Economic Area: Hipcam Global LLC, 29 S Central Ave, Valley Stream, New York, 11580, USA For users in the European Economic Area: Hipcam Europe Calle Cam Pobla num 4-6, Polígono Industrial Can Roqueta, Sabadell, Barcelona, España. If you have any questions, you may submit an inquiry to our Data Protection Office, led by our Data Protection Officer, by emailing privacy@hipcam.com.