Last Updated: April 11, 2023
Introduction and Purpose
In this Policy, we describe how we collect, use, and disclose personally identifiable information (“PII”) that we obtain from:
- visitors to our marketing website: smartrent.com (together, the “Site”);
- users of our mobile application (the “App”) and the services offered by SmartRent at the Property where you visit, park, work or live (collectively, the “Services”).
As some of our Services or the Site collect more PII and non-PII than others, some of the information in this Policy may not be applicable to you.
This Policy consists of the following main sections:
1. Information We Collect
Information that is not PII. This includes, but is not limited to, browser type and version, operating system, referral source, length of visit, page views, demographics, interests, online habits, geographical location, analytical data, temperature settings and leak monitors, security data, motion and broken glass sensors. We may combine this with PII that we have collected about you. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
Please note that we occasionally use the term “information” to refer to both PII and non-PII.
Additional detail about our PII and non-PII collection practices are described below.
Our Site Collects:
- domain name;
- your browser type, session details, telemetry data operating system, and system details;
- web pages you view; links you click; your IP address;
- the length of time you visit our Site; and
- the referring URL, or the webpage that led you to our Site.
- your device’s location information (you may choose to disable this feature, but there may be a loss of some functionality within the Site).
Our App & Services Collect:
- unique identifiers; session details, system details, telemetry data, device name and model; operating system type, name, and version;
- language information;
- Information from third parties;
- activities and information collected by or within the App and Services, such as turning lights on and off, temperature settings, leak monitoring, photographs, 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 (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. Why We Use Your PII
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 fulfill your orders, and for other customer service purposes. We monitor and record calls with SmartRent customer support agents for quality, training, and analytics purposes.
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.
Protecting Rights and Interests: We may use or disclose your PII to protect the safety, property, or security rights, of you, Landlords, SmartRent, the Services, the Site, 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.
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.
Marketing and Communications: We may use your PII 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 information that we learn about you to assist us in advertising our Services on third-party sites.
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 preferences, and for other research and analytical purposes.
3. How We Share Information
At Your Direction. We may disclose your personal information to any third-party with your consent or at your direction.
Affiliates. We may disclose PII we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your PII will be subject to this Policy.
Business Partners: We partner with other companies to integrate our Services and Site with theirs and improve the functionality of our Services and the Site. We may share your information with these partners.
Service Providers. We may disclose PII we collect to third-party vendors, service providers, contractors or agents, such as building maintenance staff 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.
Analytics Providers. While providing the Services, we may share PII with analytics providers as described below in Section 4.
Advertising Providers. In the course of using the Site, we may share PII with advertising providers, including social media, as described below in Section 4.
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 PII to the other company.
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. 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. Where we believe it is necessary to investigate, prevent, or take action regarding illegal activities.
To Protect Our Legitimate Business Interests. Where required by law or where we believe it is necessary to protect our legal rights and interests, such as in connection with legal claims, compliance, regulatory, and audit matters.
Aggregate and De-Identified Information. We share aggregated or de-identified information about users with Landlords and others for research or other purposes.
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 Analytics section.
Cookies. These are 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 gather insight analytics about your use of our Site and Service.
Disabling Cookies. Although most web browsers are automatically set up to accept cookies, if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse certain areas of the Site and Services, but some features may not function.
Other Tracking Mechanisms:
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 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.
5. Third-Party Links
Our Site and Services may contain links to third-party websites. 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. We encourage you to read the privacy policies of these services before connecting to them.
6. Security of Your PII
SmartRent uses reasonable physical, electronic, and administrative security measures to protect PII from unauthorized disclosure.
7. Access to Your PII
If you have an account with us, you may modify your PII by logging into your account and updating your profile. Please note that copies of PII that you have updated, modified or deleted in your profile may remain viewable in cached and archived pages of the Site or App. If you wish to modify or delete PII that you provided to us, but do not have an account, please contact us so we can assist you with your request.
8. Choices You 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.
9. Retention Period
We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods includes: (i) the length of time we have an ongoing relationship with your Landlord for Services; (ii) there is a continued business reason to retain the information; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).
10. Special Notice About Children
Our Services and Site are not designed for children. If we discover that a child has provided us with PII in violation of applicable law, we will delete such information from our systems.
11. Crossborder Transfer
12. Privacy Notice for California Residents
Categories of PII Collected: Below is a summary for the preceding 12 months of the categories of PII that we collected in the course of providing our Services or through the Site.
|Category||Examples||Identify if Processed|
|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.||Yes|
|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.||Yes|
|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).||Yes|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes|
|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.||Yes|
|F. Internet or similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes|
|G. Geolocation data.||Physical location or movements.||Yes|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||Yes|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||Yes|
|J. Non-public education information.||Education records directly related to a student 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 codes.||No|
|K. Inferences drawn from other personal information.||Profile a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes|
Sales of PII to Third Parties. We do not sell personal information collected through our Services or Site. Information collected through our Site may be shared with third parties through advertising cookies on the Site.
Categories Shared. We may use or disclose PII in the following categories in the course of providing our Services and the Site, and as defined by the CCPA (collectively, the “Business Purpose Disclosures” in the table below).
|Category||Category of Third-Party Recipients|
|Business Purpose Disclosures||Sales|
|B. Personal information categories listed in the California Customer Records statute||Yes||No|
|C. Protected classification characteristics under California or federal law.||No||No|
|D. Commercial information.||Yes||No|
|E. Biometric information.||No||No|
|F. Internet or similar network activity.||Yes||No|
|G. Geolocation data.||Yes||No|
|H. Sensory data.||Yes||No|
|I. Professional or employment-related information.||No||No|
|J. Non-public education information.||No||No|
|K. Inferences drawn from other personal information.||No||No|
Right to Request Disclosure. You have the right to request, free of charge, that we disclose information about our collection and use of your PII over the past twelve (12) months, including:
- The categories of PII we collect about you;
- What PII we collect, use, or disclose about you;
- The categories of sources of the PII we collect about you;
- Our business or commercial purpose for collecting the PII;
- For each category of PII, the categories of third parties with whom it was disclosed; and
- The specific pieces of PII we collect about you.
For more information on how to request information about our collection, use, and disclosure of your PII, please see the Submitting CCPA Requests section below.
Submitting CCPA Requests. Once we receive your request and verify your identity, we will review your request to see if an exception allowing us to retain the information applies. We will delete or de-identify PII not subject to an applicable exception from our records and will direct our service providers to take similar action.
Requests to Know or Delete. To exercise your rights to know or delete described above, you may submit a request by visiting our California Consumer Rights form, available at smartrent.com/ccpa, or by contacting us through the Contact Us section below.
Verification of Requests. Only you, or an individual legally authorized to act on your behalf, may make a request to know, delete, or opt-out related to your PII. To designate an authorized agent, or to make a request on behalf of a consumer for whom you are an authorized agent, please submit verification documentation through our California Consumer Rights form, available at smartrent.com/ccpa.
You may only submit a request to know twice within a 12-month period. Your request to know or delete must: (1) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected PII, or that the requestor is your authorized representative; and (2) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We may request information from you in order to verify your identity. Additionally, we may require that authorized agents provide proof of their authorization. We cannot respond to your request or provide you with PII if we are unable to verify your identity, your authority to make a request on behalf of another person, or if we cannot confirm that the PII relates to you. In general, we will verify your request and your identity by matching the information you provided with the information we have in our records.
You do not need to create an account with us to submit a request to know or to delete your PII.
We will only use PII provided in the request to verify the requestor’s identity or authority to make it.
Please note, if we have received your request in our role as a Service Provider, we will refer your request to the Landlord.
Timing. We will use reasonable efforts to respond to your request within 45 days of receipt. If we require additional time, we will inform you of the reason and the extension period in writing.
Exceptions. We may deny your deletion request if retaining the PII is necessary for us to:
- Complete the transaction for which we collected the PII;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Identify and/or repair errors that impair the functionality of our services;
- Make other lawful uses of the PII that are compatible with the context in which you provided it; and
- Comply with a legal obligation.
Content. Any PII we provide you with will only cover the 12-month period preceding our receipt of your request. Once we receive your request, validate your identity (and unless one of the exceptions above apply) we will disclose to you:
- The categories of PII that we collected about you;
- The categories of sources for the PII that we collected about you;
- Our business purpose for collecting that PII and whether it was sold;
- The categories of third parties with whom we shared the PII;
- If we sold or disclosed your PII for a business purpose, we will provide you with information about those sales and disclosures along with the PII categories that were provided and each recipients category; and
- The specific pieces of PII that we collected about you (also called a data portability request, as detailed below).
Data Portability For data portability requests, we will select a data format that is readily useable and should allow you to transfer the PII to another entity without difficulty.
No Charge. We do not charge a fee to process or respond to your PII request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request.
No Discrimination. We will not discriminate against any person for exercising their rights under the CCPA.
Right to Opt Out of Sharing, Disclosure, or Sale of Personal Information. You may have the right to direct us to not share, disclose, or sell your personal information collected through the Site. To exercise this right, you or your authorized representative may submit a request by clicking on the following link: Do Not Sell or Share My Personal Information
13. Changes to this Policy
This Policy is current as of the Effective Date set 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 www.smartrent.com/privacy.
14. Contacting Us
SmartRent Technologies, Inc.
8665 E. Hartford Drive
Scottsdale, AZ 85255