Privacy Policy - Smartcom

SMARTCOM OFFICIAL PRIVACY POLICIES

Last modified: April 3, 2023

Introduction

Smartcom Mobility Solutions, Inc. (“Smartcom” or “the Company” or “We”) provides wearable and other devices (the “Device”), Platform as a Service, applications (“Device Apps”) installed on other select mobile devices (“Other Devices”), applications (the “App”) that support a Device’s or Other Device’s paired mobile or another device (the “Paired Device”) (the “App”) and websites (collectively, the “Platform”) designed to assist caregivers/parents/guardians and other authorized users in communicating with, monitoring, and tracking or locating their valuables and loved ones (the “Services”).

Smartcom respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes:

The types of information we may collect or that you may provide when you access or use the Platform, and
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect through the Platform and any other electronic communications sent through or in connection with the Platform.

This policy DOES NOT apply to information that we collect offline or that you provide to or is collected by any third party (see “Third-Party Information Collection”). These other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not access, register with, or use the Platform or Services. By accessing, registering with, or using the Platform or Services, you agree to this privacy policy. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of the Platform and the Services after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Our Policies for Children

While some of our Devices and Device Apps are designed to be worn or used by a child, our customer is the applicable parent or guardian over 18 years of age who has registered to use the Platform and the Services. Smartcom allows parents and guardians to set up select Devices and Device Apps to be used or worn by their child. Children’s use of the Platform, and Device, Device App, and Services are subject to a separate Privacy Policy for Children Under 13 which explains what information about your child we collect to set up your account, what information we collect about and from a child’s use of our Platform and the Services, and how we use and share that information. Parents or guardians must provide consent in accordance with applicable law in order to create an account.

Persons under the age of 13 are not permitted to create accounts unless their parent or guardian has consented in accordance with applicable law. If we learn that we have collected or received the personal information of a child under the relevant minimum age without verification of parental consent, we will take steps to delete the information. Parents and guardians who believe that their child has submitted personal information to us and would like to have it deleted may contact us at dpo@smartcom.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your California Privacy Rights” for more information.

Information We Collect and How We Collect It

We collect information from and about users of our Platform:

Directly from you when you provide it to us.
Automatically when you use the Platform.

Information You Provide to Us

When you create and register an account, we may ask you to provide:

Information by which you may be personally identified, such as name, email address, your child’s birthdate (optional), phone number of Device and the Paired Device, (“Personal Information“), as well as the Personal Information of your child. We may also collect a photo of you and your child. (“Personal information” also includes, among other things, any identifier by which you may be contacted online or offline; information such as unique device IDs; photos, videos, and audio files that contain a user’s image or voice; a child’s geolocation information, and information about a child or the parents of the child that the Platform collects online from the child and combines with any identifier mentioned above).
Information about other users that you specifically authorize to be added to your account and with whom you authorize us to share you and your child’s Personal Information, (“Guest Users”) (including the Guest User’s name, relationship, and email address). Please note that if you authorize Guest Users, you do so at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of Guest Users or other third parties with whom you may choose to share your or your child’s Personal Information. Therefore, we cannot and do not guarantee that Personal Information you or your child chooses to share with Guest Users and other third parties will not be viewed by unauthorized persons.
Emergency contact information and instructions (including emergency contact names, phone numbers, and email addresses).
We may also request additional information from you about you and/or your child. We specify whether the information is required or optional when we request it.
That is about you but individually does not identify you.

This information includes:

Information that you provide by filling in forms on the Mobile App. This also includes information provided at the time of registering to use the Platform, providing parental consent, and requesting further services. We may also ask you for information when you report a problem with the Platform, or you request additional information from us.
Records and copies of your correspondence (including name, email address, and message), if you contact us.

Automatic Information Collection and Tracking

When you download, access, and use the Platform, it may use technology to automatically collect:

Usage Details. When you access and use the Platform, we may automatically collect certain details of your access to and use of the Platform, including traffic data, logs, time and usage habits, number of Devices, Paired Devices, and Other Devices used, the number of calls made or messages sent through the Device or Device App, communication data and the resources that you access and use on or through the Platform.

Device Information. We may collect information about your Device, Paired Device, Other Device, and an internet connection, including the Device, Paired Device, and Other Device’s unique identifiers; Device, Paired Device, and another Device type/ model/ manufacturer, and telephone numbers; Device and Other Device’s settings, operating system, browser type, and mobile network information; Device and Other Device’s configurations and battery level. The exact type of information collected from each device will vary depending on the product type.
Location Information. Due to the nature of the Services, the Platform necessarily collects real-time information about the location of the Device(s) or Other Devices and movement data from the Device or Device App. The Device or Device App automatically and constantly collects information about physical locations. This location information is acquired through numerous methods, including GPS, cell towers, and Wi-Fi hotspots, which are enhanced over time as we follow the Device(s) or Other Devices, collect more information, and improve our tracking. You are not able to disable location-based data collection from the Device(s) or Device App except by unpairing the App from the Device/Device App or deleting your account.
Other Metrics. The Device or Device App may also collect data to estimate a variety of metrics like the number of steps taken, the distance traveled, heart rate, sleep stages, oxygen levels, and other biometric data. The data collected varies depending on which product you use.
Calls/Audio/Texts/Video. Depending on the product you use, chat content, texts, messages, photos, sounds, voice, and video recordings sent directly from and to a Device may be collected and stored for a limited time by Smartcom. You can access and delete this data by sending us an email at dpo@smartcom.com. You may also delete this data by deleting the App or unpairing the Device. Smartcom is not responsible for lost data.
Depending on the product, some Devices and/or the App may allow a user to enter and save personal information, including that related to medications or other matters, for their own use.
Emergency Calls. In the event an emergency call is placed from the Device or Other Device, network providers may record the audio of the conversation between the Device/Other Device and the recipient of such call. In such cases, please refer to the network provider’s Privacy Policy.

If you do not want us to collect this information, do not use the Platform and do not download the App or you can delete the App or unpair the Device or Device App. To unpair the Device or Device App from the Mobile App, click on the ‘delete account’ button in the App settings. This will delete all data we maintain. For more information or to request manual deletion, you can email us at dpo@smartcom.com For more information, see How We Use and Disclose Your Information. Note that opting out of the Platform’s collection of information by deleting the App or unpairing the Device or Device App will disable the use of the Platform and the Device or Device App.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include automatic information from sensors or technologies within the Device or Other Devices.

Third-Party Information Collection

When you use the Platform or its content, certain third parties may use automatic information collection technologies to collect information about users or your Device, Other Device, and your Paired Device. These third parties may include:

Analytics companies.
Companies who manufacture, distribute, or sell the Device or Other Devices.
Your mobile device manufacturer.
Your mobile service or network provider.
The wifi access point provider and the hosting provider (Amazon Web Services (AWS))

These third parties may use tracking technologies to collect information about users when users use the Platform.

We do not control these third parties tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Your Choices About Our Collection, Use, and Disclosure of Your Information”.

In addition, we are not responsible for the practices employed by websites, apps, or services linked to or from the Platform, nor the information or content contained therein. Please remember that when you use a link to go from the Platform to another website or app, our Privacy Policy does not apply to third-party websites, apps, or services. Your browsing and interaction on any third-party website, service, or app, including those that have a link on our Device or Other Device, are subject to that third party’s own rules and policies. Please read over those rules, privacy notices, and policies before proceeding.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Information, to:

Provide you with our Services and use of the Platform and its contents, and any other information, products, or services that you request from us.
To respond to your inquiries or requests.
Fulfill any other purpose for which you provide it.
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
Notify you when Platform updates are available and of changes to any products or services we offer or provide through it.

The usage information we collect helps us to improve our Platform and our Services and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.
Recognize you when you use the Platform.
To troubleshoot and protect against errors; perform data analysis and testing, and develop new features and services.

We use location information and other metrics to provide our Services through the Platform.

If you do not want us to use your information in this way, please email us at dpo@smartcom.com. For more information, see “Your Choices About Our Collection, Use, and Disclosure of Your Information”.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or Device, Other Device, or Paired Device, without restriction.

In addition, we may disclose Personal Information that we collect or you provide:

To the account holder.
To Guest Users.
To our subsidiaries and affiliates.
To our clients who manufacture, distribute, or sell the Device or Other Device, only when the client is bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To our cloud service provider (AWS).
To contractors, service providers, and other third parties we use to support our business, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Smartcom’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Smartcom about our Platform users is among the assets transferred.
To fulfill the purpose for which you provide it. For example, we may provide geolocation information, metrics, and other Personal Information we collect or you provide to Guest Users that you have authorized us to disclose.
For any other purpose disclosed by us when you provide the information.
With your consent.
To comply with any court order, law, or legal process, including responding to any government or regulatory request.
To enforce our rights arising from any contracts entered into between you and us.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Smartcom, our customers, clients, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

Tracking Technologies. If you do not want to allow the use of tracking technologies, you can delete your account or unpair the App from the Device or Device App. To unpair the Device or Device App from the App, click on the ‘delete account’ button in the App settings. Please note, if you unpair the Device or Device App from the App, the Platform will become inaccessible.

Location Information. You cannot choose whether or not to allow the Platform to collect and use real-time information about your Device or Other Device’s location. If you do not want to allow the Platform to collect and use real-time information about your Device or Other Device’s location, do not use the Platform and do not download the App or you can delete your account or unpair the App from the Device or Device App. To un-pair, the Device or Device App from the App, click on the ‘delete account’ button in the App settings. This will delete all data we maintain. For more information or to request manual deletion, you can email us at dpo@smartcom.com. If you unpair the Device or Device App from the Mobile App, the Platform will become inaccessible and your data will be permanently deleted.

Guest Users. You can revoke the access of a Guest User by logging onto the Mobile App and deleting the specific individual as an approved Guest User or by sending an email to dpo@smartcom.com.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” for more information.

Accessing and Correcting Your Personal Information

We keep your account information, like your name, email address, password, picture, phone number, device identifiers, and your Child’s name and picture, if applicable, for as long as your account is active because we need it to operate your account. If a user has not logged in during a two (2) year period, his/her account, and the associated account information, will be deleted. We automatically delete other information after the following periods:

Message data (audio, images, video, and text) – 60 days
Location history – 60 days
All notifications – 60 days
Status History (battery, power on/off, etc.) – 60 days
Logs on the Server side – 60 days
Steps/activity history – 60 days
Tasks/Rewards – 60 days

You can review and change some of your Personal Information by logging into the App and visiting your account page. Other items of Personal Information and other information collected through the use of the Platform or provided by you, including but not limited to location information, frequency of use, and emergency contact information is generally not available to users for their own, direct access, outside the normal use of the Platform. You may send us an email at dpo@smartcom.com with questions regarding access to, correction of, or deletion of any Personal Information that you have provided to us. We cannot delete your Personal Information without also deleting your user account. Also, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Please note, if your account or information is deleted or you unpair the Device or Device App from the App, copies of your Personal Information may remain viewable in cached and archived pages or might have been copied or stored by a Guest User. Additionally, other information such as medication information and other user-generated information may remain on the Device, Other Device, or Paired Device.

California residents may have additional personal information rights and choices. Please see “Your California Privacy Rights” for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, see our CCPA Privacy Policy for California residents.

European Privacy Disclosures

If you live in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, please review these additional privacy disclosures under the European Union’s General Data Protection Regulation (“GDPR”). See our Privacy Policy for the EEA, UK, and Switzerland.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All Personal Information will be encrypted using encryption Secure Sockets Layer (“SSL”) protocol and Transport Layer Security Technology (“TLS”).

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We also urge you to be careful about giving access to other users as they may view Personal Information, including the location of the person using/wearing the Device or Other Devices.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect Personal Information, we cannot guarantee the security of Personal Information transmitted through our Platform. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ Personal Information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify your service provider by email (who may notify the primary email address specified in your account). Your continued use of the Platform following the posting of any changes to this Privacy Policy means you accept such changes.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and periodically visiting this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: dpo@smartcom.com.

For customers located in the United States of America (USA), our servers, provided by AWS (https://aws.amazon.com/), are maintained in the United States of America. By using Smartcom’s Services and Platform, you freely and specifically give us your consent to store your personal information in the USA and to store and use it in the USA as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA such as Children’s Online Privacy Protection Rule (‘COPPA’), California Consumer Privacy Act (‘CCPA’), etc.

For customers located in Europe, our servers, provided by AWS (https://aws.amazon.com/), are maintained in Dublin, Ireland, Europe. By using Smartcom’s Platform and Services, you freely and specifically give us your consent to store your personal information in Dublin and to store and use it as specified in this Privacy Policy. You understand that data stored in Dublin may be subject to lawful requests by the courts or law enforcement authorities of the European Commission: General Data Protection Regulation(‘GDPR’).

Privacy Policy for Children Under the Age of 13

The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this section, “parents“) about our practices for collecting, using, and disclosing personal information from children under the age of 13. It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

This policy notifies parents of:

The types of information we may collect from children.
How we use the information we collect.
Our practices for disclosing that information.
Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
All operators that collect or maintain information from children through the Platform.

This policy only applies to children under the age of 13 (“Children“) and supplements our general Privacy Policy. Only our general Privacy Policy applies to teens and adults. California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights for more information.

Information We Collect from Children

While some of our Devices and Device Apps are designed to be worn or used by a child, our customer is the applicable parent over eighteen (18) years of age who has registered to use the Platform and the Services. Smartcom allows parents to set up selected Devices or Device Apps to be used by their children. Smartcom does not knowingly collect personal information from children under the age of 13 without consent of a parent or guardian in accordance with applicable law, and the Platform and Services are intended to be used by children under 13 only with significant parental involvement and approval. If Smartcom learns that we have inadvertently collected the personal information of a child without parental consent, we will take appropriate steps to delete this information. If you are a parent and discover that your child under the age of 13 has a registered account with us without your consent, please alert us immediately by emailing dpo@smartcom.com so that we may delete that child’s personal information from our systems.

Some content and features require us to collect certain information, including personal information, from and about children. In addition, we use certain technologies, such as location tracking technologies, to automatically collect information from our users (including children) when they use the Platform. We only collect as much information about a child as is reasonably necessary for the child’s use of the Platform and the Services, and we do not condition his or her participation in the disclosure of more Personal Information than is reasonably necessary.

If you do not want us to collect this information, do not use the Platform or the Services and do not download the App or you can delete the App or unpair the Device or Device App. To unpair the Device or Device App from the App, click on the ‘delete account’ button in the App settings. This will delete all data we maintain. For more information or to request manual deletion, you can email us at dpo@smartcom.com. Note that opting out of the Platform’s collection of information by deleting the App or unpairing the Device or Device App will disable the use of the Platform and the Device or Device App.

Information We Collect Directly

As further described in our general Privacy Policy, we collect various types of Personal Information from all users of the Platform and Service. Please review the section of our general Privacy Policy called “Information We Collect and How We Collect It” to learn more.

When you create an account, we may collect the following personal information about your child from you: name, email address, birthdate (optional), gender, phone number of Device or Other Device, and picture. We may also request additional information from you about your child. We specify whether the information is required or optional when we request it. By creating an account and permitting your child to use the Platform, Device, Device App, and Services, you expressly agree to the practices described in this Privacy Policy for Children Under the Age of 13 and you consent to the collection, use, and disclosure of your child’s personal information as described herein.

A parent may authorize specific other individuals to be added to your account and with whom you authorize us to share your child’s personal information, including geolocation information, chat content, phone number, emergency contact information, steps taken, and photo (“Guest Users”). Your child may also be able to communicate with these Guest Users, and depending on the specific Device or Other Device, other non-authorized third parties, through chat, text, and call features located on the Device or through third-party applications on Other Devices (”Social Features”). The nature of these Social Features allows children to disclose personal information about themselves. We do not monitor or review this content, and we do not control the actions of Guest Users or other third parties with whom your child shares his or her information. We encourage parents to educate their children about the safe use of the internet, the Social Features, and the Device and Other Devices and to monitor their children’s use of the Device and Other Devices, including any Social Features

Depending on the product, chat content, texts, messages, photos, sounds, voice, and video recordings sent directly from and to a Device used by a child may be collected and stored for a limited time by Smartcom. See Accessing and Correcting Your Personal Information. You can access and delete this data by sending us an email at DPO@smartcom.com. You may also delete this data by deleting the App or unpairing the Device. Smartcom is not responsible for lost data.

Other Devices may also allow a child to take photographs, videos, and voice and audio recordings, make calls, or send messages through third-party applications located on the Other Device. This information/content is governed by such third-party’s privacy policies and is not collected by Smartcom or transferred to Smartcom’s servers.

Automatic Information Collection and Tracking

We use technology to automatically collect information from our users, including children when they access the Platform and use certain of its features. The information we collect through these technologies includes:

Information that identifies a Device’s location (geolocation information). Due to the nature of the Services, the Platform necessarily collects real-time information about the location of the Device(s) or Other Device and movement data. While paired with the App, the Device and Device App automatically and constantly collects information about the physical location of the Device and Other Devices. This location information is acquired through numerous methods, including GPS, cell towers, and Wi-Fi hotspots, which are enhanced over time as we follow the Device(s) and Other Devices, collect more information, and improve our tracking. You are not able to disable location-based data collection from the Device and Other Device except by unpairing the App from the Device or Device App.
When your child accesses and uses the Device or Device App, we may automatically collect certain details of their access to and use of the Platform, including traffic data, location data, logs, time and usage habits, the number of calls made or messages sent through the Device or Device App, communication data and the resources that your child accesses and uses on or through the Platform.
We may also collect information about the Device, Other Devices, and internet connection, including the unique Device and Other Device identifiers, Device, and another Device type/ model/ manufacturer; IP addresses, mobile network information, settings, operating system, browser type, and telephone numbers, configurations, and battery level. The exact type of information collected from each device will vary depending on the product type.
In the event an emergency or other call is placed from the Device, a network provider may record the audio of the conversation between the Device and the recipient of such call. In such cases, please refer to the network provider’s privacy policy.

We may combine the non-personal information we collect through these technologies with personal information about you or your child that we collect online.

For information about our automatic information collection practices, including how you can opt out of certain information collection, see the Automatic Information Collection and Tracking and Choices About How We Use and Disclose Your Information sections of our general Privacy Policy.

How We Use Your Child’s Information

We use the personal information we collect from and about your child to:

Set up your account;
Set up the Device or Device App;
Provide the Services;
Fulfill any other purpose for which you provide it;
Provide location-based Services to the parent/guardian and Guest Users;
Respond to your inquiries or requests;
Send information about Smartcom’s services (such as maintenance or security information);
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve our Platform and Services and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns.
Recognize the child when they use the Platform.
To troubleshoot and protect against errors; perform data analysis and testing, and develop new features and services.

We use geolocation information and other metrics we collect to provide the Services through the Platform.

If you do not want us to use your information in this way, please email us at dpo@smartcom.com. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users, and information that does not identify any individual Device or Other Device.

In addition, we may disclose children’s Personal Information:

To the account holder, parents, and Guest Users to provide our location-based and other Services.
To our subsidiaries and affiliates.
To our cloud service provider.
To our clients who manufacture, distribute, or sell the Device or Other Device and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
To third parties we use to support the internal operations of our Platform and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
If we are required to do so by law or legal processes, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Smartcom, our customers, or others, including to:
- protect the safety of a child;
- protect the safety and security of the Platform or Service; or
- enable us to take precautions against liability.
To law enforcement agencies or for an investigation related to public safety.

In addition, if Smartcom is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Smartcom’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Social Features

Depending on the product, the Device, and Other Devices may offer Social Features, including chat, texting, and calls that enable children to communicate with parents, Guest Users, and other third parties. We do not control the types of information your child can communicate, send or post through them. We encourage parents to educate their children about safety online and to carefully monitor their children’s use of Social Features, Devices, Other Devices, and Device Apps to ensure they do not disclose their Personal Information through them.

Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s Personal Information maintained by us, require us to correct or delete the Personal Information, and/or refuse to permit us to further collect or use the child’s Personal Information.

You can review and change some of your child’s Personal Information by logging into the App and visiting your account page. Other items of your child’s Personal Information and other information collected through the use of the Platform, including but not limited to location information, is generally not available to users for their own, direct access, outside the normal use of the Platform. You can review or change your child’s Personal Information that is maintained by us by:

Logging into your account.
Sending us an email at dpo@smartcom.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

You can delete your child’s personal information by deleting your account or unpairing the App from the Device or Device App To un-pair the Device or Device App from the App, click on the ‘delete account’ button in the App settings. This will delete all data we maintain. For more information or to request manual deletion, you can email us at dpo@smartcom.com. If you unpair the Device or Device App from the App, the Platform will become inaccessible.

Operators That Collect or Maintain Information from Children

The following are all operators that may collect or maintain personal information from children through the Platform:

Smartcom Mobility Solutions, Inc. | 5755 North Point Parkway #66, Alpharetta, Georgia 30022 | (404) 907-0009 | dpo@smartcom.com

Smartcom Mobility Solutions, Inc. Privacy Policy for California Residents

This Privacy Policy for California Residents supplements the information contained in Smartcom’s general Privacy Policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

This Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

Information We Collect

Our Platform collects information that identifies, relates to, describes, and references that are reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (”personal information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope.

In particular, our Platform has collected the following categories of personal information from

consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Only real name, alias, account name, and email address.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Only real name, alias, account name, and email address.

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO, except for heart rates on certain senior watches

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

I. Professional or employment-related information.

Current or past job history or performance evaluations.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student are maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

K. Inferences are drawn from other personal information.

The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Our Platform obtains the categories of personal information listed above from the following categories of sources:

- - Directly from you. For example, from forms, you complete through the Mobile App, correspondence with us, or products and services you purchase.

Indirectly from you. For example, from technology in the Device or from observing your actions on our Platform.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

- - To fulfill or meet the reason you provided the information. For example, if you share location data with us, we will use that personal information to provide location-based services.

- - To provide, support, personalize, and develop our Platform, products, and services.

- - To create, maintain, customize, and secure your account with us.

- - To process your requests and transactions and prevent transactional fraud.

- - To provide you with support and to respond to your inquiries, including investigating and addressing your concerns and monitoring and improving our responses.

- - To personalize your Platform experience.

- - To help maintain the safety, security, and integrity of our Platform, products, services, databases, and other technology assets, and business.

- - For testing, research, analysis, and product development, including to develop and improving our Platform, products, and Services.

- - To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

- - As described to you when collecting your personal information or as otherwise set forth in the CCPA.

- - To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Platform is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may share your personal information by disclosing it to a third party for business purposes. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. We may also disclose your personal information to the following third parties: other users with whom you elect to share such information (Guest Users). In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We do not sell personal information, and we do not sell personal information about individuals we know are under the age of 16. In the preceding twelve (12) months, the Company has not sold the following categories of personal information. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Personal Information Category

Category of Third-Party Recipients

Business Purpose Disclosures

Sales

A: Identifiers.