People Power Privacy Policy
Introduction
People Power Company provides customer-facing and white label device-management products and related services. These products and services empower people to manage devices and information from remote locations such as smartphones and web console user experiences. To provide you with the benefits of these products and services, we collect certain types of information from you. This privacy policy describes how we collect, protect and handle the information that you provide and that we obtain through our websites, web-based services (the "Services") and related apps or web portals (the "User Experience") and through sensors and devices (collectively, the "Devices"). In this privacy policy, we use the term "System" to refer to the combination of products and services we provide, including the Services, User Experience, the Devices and the People Power Cloud Server ("Cloud Server") that interconnects, via the Internet, the User Experience and the Devices.
Your privacy is very important to us. In this document, we describe the various kinds of information we collect, including your personally identifiable information, and how we treat it below. If you have any questions as to how the privacy policy applies to you, please email us at support@peoplepowerco.com.
Please read this Privacy Policy carefully. By installing and/or using any portion of the System, you agree to the provisions of this Privacy Policy.
1. Information we collect
We use the term "Information" to refer to any personally identifiable or anonymous information relating to you or your use of any portion of our System. We collect various categories of Information in connection with your use of the System and some of this information specifically identifies you or your household. The following sections describe more specific categories of Information:
1.1. Account Information
Account Information is information about your account, including your Contact Information and Service Information (both defined below) and other account related information that is necessary or useful for us to manage your account, your subscription to special features or services offered through the Services and privacy preferences. Account Information does not include any personally identifiable Sensing Information. Account Information may be provided by you or a technology provider, service provider, third party website, merchant involved in the development and/or provision of the functionality of the System, and other third parties with whom we work.
Contact Information means information that allows someone to identify or contact you, including, for example: your name, address, telephone number, mobile telephone number, email address, and payment information.
Service Information means information necessary or useful to us in providing the System to you. Examples of Service Information include your home profile (including ZIP Code and home size), home system configuration (including appliances monitored by the System, schedule, state, mode, automation, rules, and settings), Devices in your home (including types, model numbers and software version numbers), and the level of Service. Certain of the Service Information is collected and transmitted to us whenever a Device is connected to the Cloud Server and by connecting your Devices to the Service you are agreeing to have this information transmitted to us. Such information is treated as described below.
1.2. Sensing Information
Sensing Information is information captured by Devices connected with the System, including the status and diagnostics information from your Devices, as well as the information collected by the Devices, such as open or closed status of windows and doors, temperature and humidity, touch and movement of sensors, motion detection events, power and energy information, and your interaction with Devices. We receive this type of information from your Devices as they connect with the System.
1.3. Digital Media
Our Presence application includes a feature which allows you to use a smartphone or tablet as a video monitoring device. Videos, Audio, and Images are captured locally and automatically by your device when triggered by motion or audio detection events and as set up by you, sent over a secure channel to our server, and then immediately encrypted while being securely stored in our servers for future playback via streaming. Video, Audio, and Images may be archived even if they do not appear in your account interface. Each video has time and date information as well as unique identifier to link it to your account and device. Video and audio is stored in common video file formats such as MOV or MP4 but may change as needed for efficiency or to adapt to emerging standards. Images are typically stored in .jpg format. Unless you select a different permissions or sharing level, then by default all your content is privately stored in encrypted form.
1.4. Location Information
We may collect your exact location (from GPS data for example) or relative location (from Bluetooth Low Energy devices in your proximity for example) if you choose to enable your devices to send us location information. While we do capture Location Information in your account to provide you features and services as we would Sensing Information, we do not make Location Information accessible outside your account to anyone you did not explicitly share that information with. Location Information can be used, for example, to detect if you are Away and automatically turn on your motion detection cameras if your account is configured for that behavior.
1.5. System Use Data
We automatically collect information regarding the actions you take on the System. For example, each time you use the System we automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the pages you view, and the time and duration of your visits to the System. We use this information to help us understand how people use the System, and to enhance the services we offer.
2. Cookies and Web Beacons
Like many websites, our websites use "cookies" to recognize you and to help personalize your online experience. We also use cookies to help us understand which parts of the websites are the most popular, where our users are going and how much time they spend at various locations within the websites. The information we collect through cookies is anonymous and we do not access any of your personally identifiable information through the cookies. A cookie is a small text file that is placed on your hard disk by a web page server. These cookies contain information that can later be read by a web page server in the domain that issued the cookie to you. We use cookies to store information on your computer in order to save you time by eliminating the need to enter repeatedly the same information in order to display personalized content on later visits to the Websites.
You have the ability to decline cookies through your web browser. If you choose to decline cookies, however, you may not be able to use the features of the websites that depend on cookies.
The websites may contain tiny electronic images known as web beacons. We may use web beacons to assist us in delivering cookies on the Websites and to allow us to count users who have visited those pages. We may include web beacons in promotional email messages in order to determine whether messages have been opened and acted upon.
We use Google Analytics on the System to collect System Use Data, to analyze how users use the System, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
3. How We Use Information
We may use Information to provide and enhance the System, to provide you with customer service and to make a wider range of products and services available to you.
3.1. Account Information
We use your personally identifiable Account Information to establish and service your account with us, bill you for Services, offer you new services as available, assist you in the use of the System (including customer support), communicate with you about the System, us, and offers, and other internal business purposes. Your Information in aggregate, anonymous form is used to better understand how consumers use our System, which Services they use and who is likely to be interested in receiving certain other services and for other legitimate business purposes. The Presence store is a collection of relevant merchandise that can enhance the capabilities of the Service. We may collect information about which products or services you may be interested in when browsing our store, and may use your personally identifiable Account Information to offer you discounts or added information about products or services we believe you may find valuable.
3.2. Sensing Information
We use Sensing Information linked to your Account Information to enable us to provide you with feedback about your Devices and the way you use them, to help you set goals or budgets, compare you anonymously with others similar to you, compete you with others, and track your progress and to provide you customized content (such as tips and recommendations for other relevant products or services which you may find interesting). We may also use Sensing Information for customer support, System restoration, to analyze and improve the System, and internal research and development.
If you use the video monitoring services, emails sent to you may have a link to your video in our servers. Unique links are created and included in emails communications to you about motion detection activity or other rules you create. Each request to view a video and aggregate data about the video (file requested, time of request, number of views, device requesting view) will be stored. This will allow us to provide information to you such as ranking and number of views in a given interval (day, week, and month).
3.3. Anonymous Information
We also anonymize Information by removing your personal Contact Information. Anonymous Information may be associated with or include other Account Information that does not allow us or anyone else to identify you. It allows us to understand usage of the System at a ZIP Code level. Anonymous Information helps us develop reports and analyses about how our customers use our System, Services and the Devices and for other research, such as research regarding behavioral inferences. We also use anonymous Information to troubleshoot technical issues with our System. We also use anonymous Information to compile statistics and reports of usage of the System. Anonymous Information may be identified by a random number that is not stored with your personally identifiable Information. This identifier is capable of linking anonymous information to your personally identifiable information. To further protect your privacy, anonymous Information does not include Contact Information or any other information that would identify any specific individual or household, except as described in the last sentence. Our System also allows You to opt-in to share specific Sensing Data anonymously with researchers, such as university researchers who are interested in creating data analytics. When sharing anonymously with researchers, you may annotate the data to provide some context around it, but your personally identifiable Contact Information is not associated with your data and not accessible to researchers.
3.4. Connecting to Other Services
Our Services include several features to help you share media and Content with other people online. For example, you can connect your People Power account to your account on another service such as Twitter, Facebook, Vine and others ("Third Party Services"). We do not retain your address book information after displaying these matches. When you connect your People Power account to Third Party Services, you are able to post your text, photos, videos, and audio ("Content") to those services from the System, both automatically, if you so select, and manually. You may disconnect your People Power account from your Third Party Service accounts at any time. Disconnecting your People Power account will immediately revoke our authorization to cross-post on your behalf or otherwise access that account (other than information that was publicly posted on the System, such as profile information or previously shared Content).
3.5. Finding Friends and Sharing Access
You may discover and connect with friends through the System, by searching for their Contact Information such as a registered email address or phone number. This may be performed quickly by optionally uploading an address book to search for matching friends. People Power will match the information you provide with the contact information of other People Power users. Once connected, You may choose to share specific Devices and alerts generated by those Devices while in specific scenarios, such as Home mode, Away mode, Vacation mode, Sleep mode, or other custom modes. The Devices and Content you share will be visible to the users you share with, until you revoke their permissions by switching modes, deleting the content, or configuring your sharing settings. Friends may share Devices with you, and you may mute the alerts and notifications from their devices at any time, block those people from sharing, and delete those people from your list of friends. To facilitate a network of friends acting in a caregiver capacity, the friends You are connected with may be able to see the last time you logged into the system.
3.6. Content, Following, and other Public Information
Some of the Content and information you provide us can be made public if you choose to share and make it public or to share it on a Third Party Service. This includes not only the Content that you post and data provided with such Content, such as when it was posted, but also the accounts you follow, the Content that you like or comment on, and other public interactions on the Services. Your public information is broadly and instantly disseminated. For instance, your user nickname, and public Content may be immediately delivered to a wide range of users and other services that access Presence by People Power. When you share information or Content via the Services or on Third Party Services, either automatically or manually, you should think carefully about what you are choosing to share publicly.
4. Disclosure of Information to Third Parties
Except as provided in this Privacy Policy or in the applicable Terms of Service, we will not disclose your personally identifiable Information to any third party for marketing or other purposes without your express permission. We may disclose aggregated, anonymous Information, and analyses and reports derived from such information to third parties including utilities, researchers, our service providers, advertisers, merchants, and market research companies and other organizations.
4.1. Contractors and Third Party Service Providers
We may use independent contractors to assist with our operations. Such contractors may include programmers, consultants, billing and other agents, auditors, attorneys and accountants, potential purchasers of our business, collection agencies, and third parties who provide services necessary for us to provide the System or conduct business activities in connection with the System. Some of these contractors will have temporary access to our databases of Information. Their access to such information will be limited to specific tasks. We also use third parties to help with certain aspects of our operations, which may require disclosure of your Information to them. For example, we may use a third party to communicate with you (via telephone, email, or letter) about your account or upcoming features or services, to process and collect payment for your Services via your credit card, to generate demographic profiles based on Information of our customers, and to perform other work as part of or in relation to the System that we may need to outsource. We contractually bind these contractors and third parties to use your Information only as necessary to perform the services they are asked to perform and to use commercially reasonable measures to protect your Information from unauthorized use or disclosure.
4.2. Service Provider Partners
If the System is provided through your utility or service provider, we may share Information with your utility or service provider in accordance with your agreement with such utility or service provider.
4.3. Compliance with the Law: Protection of Our System and Services
We may disclose Information to governmental agencies, regulators or other third parties if legally required to do so, such as in response to a legal demand issued by a government entity, a subpoena issued in connection with a civil or criminal investigation or litigation or a court order. We may also determine that it is necessary for us to disclose your Account Information and personally identifiable Sensing Information to comply with the Electronic Communications Privacy Act, the Digital Millennium Copyright Act and any other relevant laws, to enforce our applicable Terms of Service, End User License and Service Agreement or any other of our policies, to protect the integrity of our operations and to protect our customers or to prevent a crime.
4.4. Affiliated Companies
We may share some or all of your Information with any parent company, subsidiary, joint venture or other company under a common control with us. If this happens, we will require the related company to comply with this Privacy Policy. If another company acquires us, or acquires our assets that comprise or include your Information, we may transfer the Information to that acquiring company, which may put in place its own privacy policy with terms that are different from the terms of this Privacy Policy, but it will provide you with notice of any such changes using the Contact Information that we have for you.
5. Your Choices Regarding Information
5.1. Marketing Information
After registering a user account in our System, you may receive several automated non- marketing emails to confirm your Account Information and to help you get started. Further emails received from People Power are not automated, and may be marketing related. You may opt-out of any marketing emails by clicking the "Unsubscribe" button at the bottom of the marketing email, or by contacting support@peoplepowerco.com to opt-out manually.
5.2. Closing Your Account
To terminate your user account, please send an email to support@peoplepowerco.com.
6. Information from Children
The System is intended for users who are 13 years old or older. We do not knowingly collect personally identifiable Information from children under the age of 13. If we become aware that we have inadvertently received such Information from a child under the age of 13, we will delete such Information from our records.
If you are a school, district or teacher in the United States and want your students who are under the age of 13 to create accounts with People Power, you agree that you are responsible for complying with the U.S. Children's Online Privacy Protection Act ("COPPA"), to the extent applicable, The Family Educational Rights and Privacy Act ("FERPA"), and any other applicable laws. This means you must notify those students' parents/guardians of the personally identifiable information People Power will collect and obtain parental/guardian consent before your students establish accounts or use the Service. When obtaining such consent, you must provide parents/guardians with a copy of our Privacy Policy. You must keep all consents on file and provide them to us if we request them.
California users under the age of 18 may request the removal of their Content or information publically posted on the System by e-mailing us at support@peoplepowerco.com. Please note that most of the user content that appears on the System is stored and controlled by third party providers; thus, complete and comprehensive removal of the content may not be possible.
7. Advertising and Online Tracking
We may allow third-party companies to serve ads and collect certain anonymous information when you visit the System. These companies may use non-personally identifiable information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the System and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. Our systems do not recognize browser "Do Not Track" signals, but several of our service providers who utilize these cookies on the System enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit http://www.networkadvertising.org or http://www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us.
8. Security of Information
Your privacy is very important to us and we have put in place technical, physical and administrative measures to protect the Information that we collect. No security system is perfect, however, and we cannot guarantee that your Information will not be disclosed to unintended third party recipients. Further, third parties may circumvent our security measures to unlawfully intercept or access your Information.
When you contact us by email or phone regarding your account, for your security, we may ask you for certain Account Information to verify your identity before accepting requests to make changes to the account. We take these steps to ensure that only you or a household member who knows your Account Information will be able to access or change your Subscriber Information. We use industry-standard security methods, such as encryption and authentication, to secure the communication of information throughout the System. In addition, we use industry- standard methods of securing our databases that house Information. Except as provided elsewhere in this Privacy Policy, we limit access to Information databases to our personnel who have a business need for such access, including servicing your account, informing you of service news and special offers, or aggregating Account Information or anonymous Sensing Information. However, you should know that no company, including our company, can fully eliminate security risks associated with Information.
Private Sensing Information, Service Information, and Contact Information is all encrypted, and in most cases authenticated during transmission. Streaming Information, such as video and audio streaming, is only generated during the period of time you are actively viewing your audio/video stream remotely and may not be encrypted. Cryptographic tokens are used throughout the system to prevent unauthorized access to user account information and audio/video streams. Highly sensitive Content such as captured videos, audio, and images are encrypted before being stored on disk allocated to your account. Ultimately, the best way to protect your security and privacy is to choose a strong password for both your user account and your WiFi network.
Presence by People Power may automatically or manually share Content of your choosing. When your Content is shared publicly, it is stored unencrypted and made available from a publicly accessible location such as a URL. We identify 3 levels of sharing:
Private: Your Content may be stored encrypted and is only accessible by You or other People Power users or groups that you have explicitly assigned permissions to receive this Private content. We place extra importance on encrypting privately stored Video/Audio information and authenticating access to that information.
Unlisted: Your Content is stored unencrypted and assigned a publicly accessible URL which can be accessed by anyone who has access to the link.
Public: Your Content is stored unencrypted and assigned a publicly accessible URL which can be searched and accessed by anyone.
Communication Information is information relating to you or your use of the System derived from communications sent through the System or entered by you in forums hosted on the System. We cannot protect Communication Information shared in public forums; therefore, you should use care to only disclose that information you wish to share publicly.
9. Information You Make Available to Others
By using the System you may make certain of your Information available to others. For example, you may share Information with other users on the System, to the public, and to the users of Third Party Services. Please be aware that whenever you share information on any public area of the System or elsewhere, that Information may be accessed by others. In addition, please remember that when you share Information in any other communications with third parties, that Information may be passed along or made public by others. This means that anyone with access to such Information can potentially use it for any purpose, including sending unsolicited communications.
10. Processing in Other Jurisdictions
Please be aware that your Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the System, you are agreeing to the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.
11. General
11.1. Amendments to this Privacy Policy
We may occasionally update this privacy statement. When we do, we will also revise the "last modified" date at the top of the privacy statement. We encourage you to review this privacy statement periodically to stay informed about how we are helping to protect the Information we collect. Your continued use of the System constitutes your agreement to this privacy statement and any updates. Please be aware that this privacy statement and any choices you make on the System do not necessarily apply to information you may have provided to us in the context of other of our separately operated products or services.
11.2. Contact Us
If you would like to make suggestions or find out more about our privacy practices, please email us at support@peoplepowerco.com.
11.3. Interpreting this Privacy Policy
Examples listed in this Privacy Policy are provided to assist your understanding of this Privacy Policy and are not intended as exhaustive lists. Section headings are provided for your convenience. This Privacy Policy, as may be amended, supplements and is incorporated into the applicable End User License and Service Agreement.
Last updated: February 10, 2017