Last Updated: February 3, 2016

This Privacy Policy describes the practices of Electric Imp, Inc. (“Electric Imp”, “we”, “us” or “our”) regarding the collection, use and disclosure of information that our customers and/or our customers’ end users (collectively “Customers,” “you,” or “your”) share with us by visiting our Website at www.electricimp.com (the “Site”) or by registering for and using our products, applications and services (the “Service”). You may be a third party developer or manufacturer of a device that is enabled for and connected to our Service (“Customer Device”) or an end user of such Customer Device. By visiting the Site or using the Service, you consent to the collection, transfer, processing, disclosure, and other uses of your information described in this Privacy Policy.

Information We Collect

Personal Information

“Personal information” is information that identifies you as an individual, including your first and last name, email, home address and/or phone number. We only collect your Personal Information when you or someone acting on your behalf provide(s) that information to us either when you: (1) subscribe to our mailing list(s) on the Site; (2) register for and subscribe to our Service; (3) purchase or request a refund/replacement for our hardware product (if purchased directly from us and not a third-party supplier); or (4) request technical support.

Other than this limited collection of Personal Information that you provide to us, we do not knowingly collect, process, or store your Personal Information as part of our Service. We expressly advise our Customers not to share, upload, or store any Personal Information via our Service, and we are not responsible for any Personal Information you may choose to share, upload or store via the Service.

If you are visiting our Site or communicating electronically with us from a country other than the United States, various communications may result in a transfer of information across international boundaries. You acknowledge that the laws concerning privacy and data security that are in effect in the United States may differ from and, in some cases, may provide for a lower standard of protection than are in effect in your jurisdiction of residence. By visiting our Site, using our Service and/or communicating electronically with us, you consent to the collection, use, transfer and transmission of your Personal Information to the United States.

Other Information

If you are subscribed to and use our Service through a Customer Device, our Service will automatically collect other information that relates to your use of the Service but does not reveal your identity (“Device and Usage Data”).  Collection of this information helps us improve our Service and assist you with technical issues. The Device and Usage Data we and/or third party service provider collect includes the following:

• Log Data: When you use our Site or log into our Service, we automatically record log data that may include your browser type, IP address of your computer or hardware, the web page visited before you came to our Site, information you search for on our Site, locale preferences, hardware MAC addresses, device ID number, date and time stamps associated with transactions, system configuration information, firmware and agents, device status data (e.g., power state, WiFi signal strength, power, etc.). Some of the information we collect from a browser or hardware — for example an IP address — can sometimes be used to approximate a Customer’s computer or device location. We may also keep a cached copy of metadata related to the information that passes through our Service (but not the data itself, unless Customer chooses to store such data with us or the Service).

• Cookies: In operating the Service or providing the Site, we may use “cookies.” A cookie is a piece of information a computer or device that hosts our Service or the Site gives to your browser when you access the Service or the Site. Our cookies help provide additional functionality to the Service and the Site and help us analyze the usage of both more accurately. For instance, our Service or the Site may set a cookie on your browser that allows you to access the Service or the Site without needing to enter a password more than once during a visit to the Service or the Site. In all cases in which we use cookies, we will not collect Personal Information except with your permission. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service or Site features.

Our Use of Information

Electric Imp uses all collected Personal Information and Device and Usage Data in a manner that is consistent with this Privacy Policy. If you provide Personal Information for a specific reason, we may use the Personal Information in connection with that reason. We may also use your Personal Information to: (1) provide and improve our Service and Site; (2) administer use of the Service and Site; (3) better understand your needs and interests; (4) personalize and improve your experience; and (5) provide or offer software updates, changes in policy, new product information and product announcements.

Also, if you provide Personal Information in order to obtain access to the Site or the Service, we will use that information to provide you with access to the Service and to monitor your use of the Service in the event you request technical support, or if we suspect that your use of the Service or the Site violates our Terms of Service (https://electricimp.com/terms/).

We may also use your Personal Information to prepare anonymized, aggregate and non-personally identifiable statistic or reports about the overall use of our Service or usage data, and may share such reports or statistic publicly or with interested third parties to help them understand, or to help us improve, the Service.

Electric Imp may also use your Personal Information to contact you in the future to tell you about products or services we believe may be of interest to you (“Marketing Messages”). If we do so, each Marketing Message will contain instructions for “opting out” of receiving future Marketing Messages and other communications from us.

Our Disclosure and Sharing of Information

Electric Imp is not in the business of selling your Personal Information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below:

• Related Companies: We may share your information with our subsidiaries and affiliates (“Related Companies”) consistent with this Privacy Policy. Our Related Companies may also send you Marketing Messages and other communications consistent with this Privacy Policy.

• Trusted Service Providers and Business Partners: We may utilize trusted third party service providers to assist us in delivering the Service. For example, we may use third parties to help host our Service, send out email updates, or process payments. These service providers may have access to your Personal Information for the limited purpose of providing the services we have contracted with them to provide.

• Law Enforcement: Electric Imp may disclose your information, including Personal Information, if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Electric Imp, (iii) act in urgent circumstances to protect the personal safety of users of the Service or the Site or the general public, (iv) to address fraud, security or technical issues; or (v) defend against legal liability.

• In Connection With a Sale, Merger or Change of Control: In the event that Electric Imp undergoes a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, you agree that Electric Imp may transfer your information, including Personal Information, to the successor organization in such transition so that the Service can continue to operate. In the event of such transfer, your information would remain subject to the commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you.

Your Choices

You can visit the Site without providing any Personal Information. In addition, if you are an end user and do not want to provide any Personal Information to Electric Imp, you should not disclose any such Personal Information to the Customer Device manufacturer. If you choose not to provide any Personal Information, you may not be able to use certain features of the Service or parts of the Site. To keep your Personal Information accurate, current, and complete, please contact us as specified at the end of this Privacy Policy. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted via the Service or Site.

Exclusions

This Privacy Policy does not apply to any information about you collected by Electric Imp other than information collected through the Service or the Site. This Privacy Policy also does not apply to any unsolicited information you provide to Electric Imp through the Service, the Site, via email, support links, or any other means. This includes, but is not limited to, information posted on any public areas of the Service or the Site, such as forums or wikis, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Electric Imp shall be free to reproduce, use, disclose, distribute, and otherwise exploit such Unsolicited Information without limitation or attribution. Please do not submit or share any Personal Information via the forums or wikis (or other public locations) that you do not wish others to know, e.g., credit card numbers, email addresses, phone numbers, mailing addresses, etc.

Children

Our Service is not directed to persons under the age of 13. Electric Imp does not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for the Service. If you are under the age of 13, please do not submit any Personal Information through the Service or the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and usage of Customer Devices and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the Service or on the Site without their permission.

Links to Other Web Sites

This Privacy Policy applies only to the Service and the Site. The Service or Site may contain links to other web sites not operated or controlled by Electric Imp (the “Third Party Sites”). The policies and procedures we describe here do not apply to the Third Party Sites. The links from the Service and the Site do not imply that Electric Imp endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Security

Electric Imp takes reasonable steps to protect your Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We follow generally accepted industry standards to protect your Personal Information, both during transmission and once we receive it. In addition, information such as Customer Device activity, and your username and password that we request from you on our Site, through our Service or in the Electric Imp mobile application, utilizes encryption, such as Secured Socket Layer (SSL) protocol, during transmission over the Internet.

While we take reasonable efforts to guard Personal Information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any information once it passes through the Service or Site is maintained at adequate levels of protection to meet specific needs or obligations you may have relating to that information.

Further, we expressly advise our Customers not to store or upload any Personal Information or any other information that Customer may deem sensitive or confidential via our Service and expressly disclaim any liability or responsibility for Personal Information and other information that Customers may choose to upload and store on the servers running our Service.

It is important for you to protect against unauthorized access to your password and to your computer and other devices. Be sure to sign off when finished accessing the Service or Site using a shared computer.

Other Terms and Conditions

Your access to and use of the Service, Site and imp Hardware is subject to the Terms of Service at https://electricimp.com/terms/.

Changes to Privacy Policy

Electric Imp may make changes to this Policy from time to time. Any changes we make to our privacy Policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. When amendments are made, we will revise the “last updated” date at the top of this Policy. Please also feel free to contact us if you have any questions about Electric Imp’s Privacy Policy at info@electricimp.com.