This Privacy Policy applies to users of our Services in the European Economic Area (“EEA”) and the United Kingdom. It explains how and why we collect and use your personal information, and the rights available to you.

SmartRent Technologies, Inc. (“SmartRent”, “we”, “us”, “our”) provides services that:

• help residents, landlords, property owners or management companies control and monitor functions (such as IoT or ‘smart’ equipment) within an apartment and/or apartment complex (“Property”) (“Resident Services”); and
• facilitate the provision of self-guided tours of Properties for prospective residents (“Self-Guided Tour Services”), together, the “Services”.

In order to provide the Services, we operate the following websites: smartrent.com and control.smartrent.com (together, the “Site”) and SmartRent mobile application (the “App”) and the Services, and how we use and disclose that personal information to support the Services.

By visiting the Site, using or downloading the App, or using any of our Services, you acknowledge that your personal information will be handled as described in this Policy.

Your use of our Site or Services is subject to our Terms of Service, which should be read alongside this Privacy Policy. The Terms of Service for Resident Services can be accessed here, and for Self-Guided Tour Services here.

1. Personal Information We Collect

When we collect and use personal information, we do so as either a ‘controller’ or a ‘processor’. When you create an account and interact with us through your use of the Resident Services, we act as a controller of your information. Where we collect your information in connection with a Self-Guided Tour Service, or where it is otherwise provided to us by a Property owner for a specific purpose, we act as a processor on behalf of that Property owner (or landlord or management company), and you should refer to their privacy notices and contact them in the first instance if you have complaints or queries about how your personal information is used.

Information We Collect Directly From You. We collect personal information directly from you when you register an account or use our Services:

Resident Services

• First and last name
• Email and street address
• Password
• Telephone number

Self-Guided Tour Services

• First and last name
• Email and street address
• Password
• Telephone number
• Estate agent, if any
• Tour date and time, home or community
• Copy of ID (for fraud prevention purposes)
• A photograph of you (for fraud prevention purposes)
• Geolocation data within close proximity to the toured property (for fraud prevention purposes)

Information We Collect From Third Parties. We receive Personal Information from third parties (including your landlord, Property owner or management company):

Resident Services:

• Your landlord, Property owner or management company provides us with your name and telephone number so that we can provide you with an access code to your Property and invite you to use our Services.
• When you have chosen to receive alerts from third parties (such as Ring, Amazon or Google) through our Services, they will provide us your connection data, device ID and IP address, and the nature of the alert. We do not read or store this data or use it in any way, except to allow the alert to be transferred to your account with the relevant third party.
• Your landlord, Property owner or management company may provide us with information to facilitate their provision of services to you. For example, we may receive information about the scheduling of work orders to allow third parties to make repairs in your residential unit.

Information We Collect Automatically. Some personal information may be collected automatically when you use our Services, such as:

Resident Services:

• Access codes and security codes;
• Information about incidents that may require work orders (such as repairs in your residence, or restoration of utility services); and
• Information about your use of smart devices in your Property.

In addition, when you use any of our Services, or when you otherwise visit our Site, we automatically collect information about your use of our Site or Services through cookies, web beacons, and other technologies, including technologies designed for mobile apps. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

Site

• domain name;
• your browser type and operating system;
• web pages you view; links you click; your IP address;
• the length of time you visit our Site and/or use our Services; and
• the referring URL, or the webpage that led you to our Site.
• your device’s location information. With your consent, we will collect location information. We use this information for the purposes described in this Policy, to ensure our Site and Services work and are displayed properly, for security purposes, to send you notifications and for the uses described below or at the time of collection.

Apps & Services

• mobile device & AD IDs; device name and model; operating system type, name, and version;
• language information;
• activities and information collected by or within the App and Services, such as turning lights on and off, temperature settings, leak monitoring, photographs, CCTV, parking, movement throughout the Property, access to public and private areas of the Property, etc.
• the length of time that you are logged into our App or Services; and
• location information: with your consent, we will collect location information from your mobile or other device to enable features or use of our Services. You may choose to disable this feature, but there may be a loss of some functionality within the App and you may not be able to use or access some of our Services if you do so.

2. How We Use Your Personal Information and Lawful Bases for Processing

We process your personal information to provide our Services, improve our products, and comply with legal requirements and our internal policies as detailed below.  Where we act as a controller, we will only process your personal information if we have a lawful basis for doing so. Lawful bases for processing include contractual necessity, pursuit of our legitimate interests or the legitimate interests of others, or compliance with a legal obligation, as further described below.

• Providing and Improving our Services: To provide our Services, to communicate with you and others about your use of our Services, to respond to your inquiries, to fulfil your orders, and for other customer service purposes. Lawful basis: Performing our contract with you.
• Tailoring Content: To tailor the content and information that we may send or display, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services. Lawful basis: Our legitimate interest in offering tailored, relevant Services or, where we rely on non-essential cookies and similar technologies, your consent.
• Marketing and Communications: For marketing and promotional purposes. Once you have registered and subject to your permission, we may use your information, such as your mobile phone number, our App, or your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Services on third party sites. Lawful basis: Your consent or, where your information was collected in the course of selling a product or service and we provide you with an opt-out opportunity, our legitimate interest in promoting our products and services.
• Research and Analytics: To better understand how you access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to your desires and preferences, and for other research and analytical purposes. Lawful basis: Our legitimate interest in understanding how our Services are used so that we can make improvements to them or, where we rely on non-essential cookies and similar technologies, your consent.
• Protecting Rights and Interests: We may use or disclose your personal information to protect the safety, property, or security rights, of you, Landlords, SmartRent, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that SmartRent, in its sole discretion, may consider to be, or pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; to conduct audits; and to enforce this Policy and our Terms of Service. Lawful basis: to comply with legal obligations; our legitimate interest in exercising or establishing legal rights or defending or pursuing legal claims.
• Legal Compliance: To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. Lawful basis: to comply with legal obligations; our legitimate interest in cooperating with regulators, law enforcement, courts or other government bodies.

3. How We Share Your Personal Information and International Transfers

We may share your personal information as follows:

• Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
• Business Partners: We partner with other companies to integrate our Services with theirs, and improve the functionality of our Services. We may share your information with these partners.
• Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents, such as building maintenance staff, landlords, tenants, and other third parties. In addition, in order to facilitate self-guided tours of a Property and to protect against theft or other security incidents, we collect your government-issued ID, as well as a photo that you take of yourself and send to us in connection with any self-guided tour. We transmit the photo from your ID and the photo you take of yourself to our vendor, which compares the information from both photographs to verify your identity and provides us with a conclusion based on that comparison. Our vendor may collect and store biometric identifiers in order to provide us with this service. We do not receive or store any biometric identifiers generated by our vendor, and we do not disclose any biometric identifiers generated by our vendor with any other entity. We instruct our vendors not to store any biometric identifiers collected for longer than necessary, and in no case longer than 3 years.
• Advertising & Analytics Providers. We share your personal information with advertising and analytics providers as described below.
• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• Landlord: If you are a tenant or a guest, we may share information with the landlord, Property owner or management company and other third parties to monitor the condition and safety of the apartment and the Property. Examples of this information include temperature settings and leak monitors, security and other cameras, access controls, motion sensors, or broken glass sensors. If you are a guest or prospective tenant at a Property, we will share your information with the Landlord so that the Landlord can contact you regarding your interest in becoming a tenant and for the Landlord’s other internal business purposes.
• Roommates: If you have a roommate or roommates, we will share information that you input into the App and Services with them, such as temperature control changes, lock/unlock events and security settings.
• In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or the Property, violations of our Terms of Service or this Policy, or as evidence in litigation in which Company is involved.
• Aggregate and De-Identified Information. We may share aggregated or de-identified information about users with Landlords and others for research or other purposes.

The Services are hosted and operated in the United States (“U.S.”) by us and our service providers. You should be aware that data protection laws in the U.S. are not considered to be equivalent to those in Europe. By using the Services, you acknowledge that any personal information about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the U.S. and will be hosted on U.S. servers Transfers of your personal information to the U.S. are made on the basis that they are necessary to perform our Terms of Services or other agreement with you or pre-contractual steps that you have requested, pursuant to Standard Contractual Clauses approved by the European Commission or UK Government entered into with our business partners, or otherwise on the basis of your explicit consent. If you would like further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA please contact us at [email protected].  

4. Our Use of Cookies and Other Tracking Mechanisms

We and our third-party service providers use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).

When you first navigate to our Site, you are asked to provide your consent to non-essential cookies.

As well as using the pop-up consent mechanism, you can control acceptance of cookies by modifying your Internet browser preferences.

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies or limiting tracking on your mobile device); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section.

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service. There are two types of cookies: session and persistent cookies.

• Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
• Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity, and to display advertising both on our Site and on third-party sites.

We use cookies and related technologies for the following purposes:

• Essential – this includes the use of any cookies that are necessary in order to transmit information over an electronic communications network (and therefore make it possible for you to view the Site), as well as any cookies that are strictly necessary in order to make the Site function (for example, remembering information input into a webform during a browsing session). This includes cookies used to comply legal obligations which apply to our website, such as our obligation to take appropriate steps to secure personal information input into the website.It is not possible for you to control our use of essential cookies.
• Personalization – cookies used to remember your preferences (such as login details, language, font size, privacy settings and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the Site or browse from one page to another.
• Analytics – cookies used to collect information about your use of the Site in order to understand how users interact with the Site, and then make changes in order to improve the Site for all users. Our use of analytics cookies includes Google Analytics. For more information, please visit  https://policies.google.com/technologies/partner-sites You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
• Advertising – cookies used to serve advertising based on your internet activity and to track the success of our advertisements across the web. These cookies may also be set through our site by our advertising partners.

In addition, please note the following in relation to our use of cookies:

• Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
• Cookies and Interest Based Advertising Choices.  Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may limit ad tracking of certain mobile ads via their device settings. You may also control interest-based advertising on apps on your mobile device in certain jurisdictions with the AppChoices app. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these and learn about targeted advertising and consumer choice and privacy at www.youronlinechoices.com/,  www.aboutads.info/choices/, youradchoices.ca/choices/ and www.networkadvertising.org/managing/opt_out.asp.
  
  To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. You must separately opt out in each browser on each device. Advertisements on third party websites that contain the AdChoices link and that link to this Policy may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.

5. Third-Party Links

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

6. Security of Your Personal Information

We have implemented commercially reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100 percent security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen or compromised passwords or for any activity on your account via unauthorized password activity.

7. Access to Your Personal Information

You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or App.

8. Your Personal Information Rights

Where we act as a controller, subject to certain exemptions, and in some cases dependent upon the legal basis we rely upon (see Section 2), you have certain rights in relation to your personal information. These include rights:

• To access personal information
• To rectify / erase personal information
• To restrict the processing of your personal information
• To transfer a portable copy of your personal information
• To object to the processing of personal information (where it is based on our ‘legitimate interests’)
• To prevent us from using your personal information for direct marketing purposes – the easiest way to exercise this right is to click on the ‘unsubscribe’ link in our emails
• To obtain a copy of personal information safeguards used for transfers outside your jurisdiction
• To lodge a complaint with your local supervisory authority.

We may ask you for additional information to confirm your identity and for security purposes, before complying with your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

9. What Choices Do I Have Regarding Marketing Messages?

We may send periodic promotional or informational messages to you. You may opt-out of such communications by following the instructions contained in the message. If you opt-out of receiving messages about recommendations or other information we think may interest you, we may still send you transactional or other emails about your account or any Services you have requested or received from us.

10. Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

11. Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site, at smartrent.com/privacy-eea-uk/.