Effective August 10, 2020
We want to help you to understand what information we collect about you, why we collect it, and how you can update, manage and delete your information. To do that, we have created this Privacy Policy. To make this Privacy Policy easier to understand, we have included additional information about certain key terms at the end of this document. We capitalize those key terms throughout this Privacy Policy so that you can more easily identify them as you read through it.We build a range of services that help people to automate, monitor and control their homes. Our services include Sendal apps, sites, and cloud services.
If you have any questions about this Privacy Policy, you can contact us at: info.sendal.io or (617) 302-6530.
INFORMATION SENDAL COLLECTS
We collect information to provide better services to our users, such as providing better insight to you about how you use your home. This may include detecting patterns of usage to suggest home automation tasks, predicting actions and determining which products and ads you will find most useful. The information we collect, and how that information is used, depends on how you use our services.
When you are signed in to a Sendal Account, we collect information about you and your Devices that we store with your Sendal Account, which we treat as Personal Information. These are used for security and fraud detection, remembering your preferences, and providing personalized advertising.
When you’re not signed in, we store the information we collect with Data Tags tied to the browser, app, or Device you are using. This helps us do things like support trigger-based automations and improve our models of your home usage. We also track your device’s location (if you enable location tracking for our app on your device) to build a ‘geofence’ around your home to support automated behaviors when you are home or away.
Information You Provide to Us:
When you create a Sendal Account, you provide us with Personal Information that includes one or more of the following:
• your name
• your email address
• your mailing, residence and other addresses
• a password
• your home’s geolocation (if you enable location tracking for our app on your device)
• phone numbers
• payment Information
You might choose to provide us with information like an email address to receive updates about our services, which you can do without a Sendal Account.
Information We Collect :
We collect and store information using various technologies, including Cookies, Pixel Tags, Web Storage or App Caches, databases, and Server Logs. We may collect information about your activity, your Devices and your Equipment.
Your Activity - We collect information about your activity in our app, which we use to do things like trigger automations, suggest automations, predict Device usage to improve your experience, support third party services you approve and to improve our user experience and features we provide to you. The activity information we collect may include:
• Commands you send to Devices and the success or failure results of those commands
• Preset actions (“scenes”) executed by users or by automated behaviors
• Information on app screens you visit and interact with.
Your Devices - We collect information about the Devices, browsers and other apps you use to access the Sendal services. This helps us to provide automatic updates and to ensure compatibility and correct functionality of our software. The information we collect includes Device type, operating system and app version number, Data Tags, and browser type. We also collect information regarding the settings for your Devices, Equipment and browser. We also collect information about the interaction of your Devices, apps and browsers with our services, including IP Addresses, crash reports, system activity, the date and time, commands executed and app pages visited. We collect this information when a Sendal app on your Device contacts our servers — for example, when our apps check for automatic updates.
Your Equipment - We collect information about the Equipment that you control and manage using our app, which helps us to access the types of Equipment that you monitor and control with our apps. The information we collect includes Equipment type and settings, information from your devices such as reported temperature and humidity settings, current temperature and humidity levels, light on/off state, audio and other media device on/off states. We also collect information about the interaction of your Equipment with our services, including IP Addresses, crash reports, system activity, the date and time and error reports from your Equipment or the Equipment's cloud services. We collect this information when a your Equipment contacts our servers or when Sendal’s cloud service contacts the Equipment’s cloud service — for example, when you identify a new piece of Equipment in our app or you monitor or control your Equipment with our apps. We also collect information about your Equipment to improve Equipment partners’ systems performance and availability and to send information about that Equipment to you and to provide information and offers for other Equipment which you might find useful.
We collect information on your Device’s location (if you enable location information to our app) to support automated behaviors associated with your home or away state.
WHY SENDAL COLLECTS DATA
We use the information we collect from all our services for the following purposes:
To Provide Our Services
We use your information to Deliver our Services, like monitoring and controlling your Equipment and creating predictive behavior models for your home and Equipment to provide autonomous and automated behaviors.Examples of how we use your information to deliver our services include:
• We use Data Tags stored in cookies on your device to help us authenticate you as the person who should have access to your Sendal Account.
• When you purchase services or physical goods from us or our partners, you may provide us information like your shipping address or delivery instructions. We use this information for things like processing, fulfilling, and delivering your order, and to provide support in connection with the product or service you purchase.
• We track when lights are normally on or off to provide automations or detect anomalies (such as when a light or other Equipment is left on by mistake)
• We provide you with a history of activity in your home to help you better understand how you use your home, the Equipment in it, and Sendal’s apps features.
• We use your home’s location to determine sunset/sunrise to support automated activity and to help determine your home/away status to support automated behaviors.
To Maintain and Improve Our Services:
We also use your information to make sure our apps are working properly, such as troubleshooting issues that you report to us. We may also collect information about how you use our apps. We use analyze that information to help us to improve our apps for all of our users. We also continuously monitor our apps to detect problems. This may allow us to fix problems before they arise.
To Develop New Services and Measure Performance
We use the information we collect through our apps and sites to guide new product and feature development and to measure app performance. For example, we optimize our user interface based on popularity of features and determine new features to provide you based on what Equipment is most popular.
To Detect Abuse
We use information to help improve the safety and reliability of our apps, websites and services, including taking efforts to detect and respond to security risks and technical issues that could harm Sendal or our users.To Provide Personalized Services, Content and Advertising.
We use the information we collect to customize our services for you, including providing recommendations for other Equipment we think may be of interest to you and providing information to you that we think you might find to be useful. Depending on your settings, we may also show you Personalized Ads based on your use of our app and the Equipment you monitor and control with it. For example, if you use the app to monitor and control a smart doorbell, you may see an advertisement for smart lighting to augment security when you are away from your home. We don’t share information that personally identifies you with advertisers, such as your name or email unless we have your consent. For example, when you purchase Equipment or software services through the Sendal marketplace we share information to facilitate the purchase or subscription. We never show you personalized advertisements based on personally or politically sensitive information, such as race, religion, sexual orientation, or health.
We collect information about views and interactions with ads so we can provide aggregated reports to advertisers, like telling them whether we served their ad on a page and whether the ad was likely seen by a viewer. We may also measure other interactions, such as how you move your mouse over an ad or if you interact with the page on which the ad appears.
To Communicate with You
We use information we collect to communicate with you. For example, we contact you about your account or to let you know about new services we are offering or changes that we may be making to our apps. If you contact us, we will maintain a record of it so that we can provide a consistent service and try to address any issues you might have.HOW SENDAL PROCESSES YOUR INFORMATION
We use different technologies to process your information for these purposes. We use automated systems and computer programs that analyze your use of our apps and websites to provide you with things like personalized ads or to customize our services for you, including providing recommendations for other Equipment we think may be of interest to you and providing information to you that we think you might find to be useful. We may combine information we collect from your use of our apps and websites and across your Devices for the purposes described in this Privacy Policy. We will ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.
YOUR PRIVACY CONTROLS
You have choices regarding the information we collect and how it's used. This section describes the methods available to you for managing your privacy across our apps and websites.
Managing, Reviewing, and Updating Your Information
When you’re signed in, you can always review and update information by visiting the services you use. Ways to Review & Update Your Information
When you are signed in to our apps or websites, you can manage information associated with those specific apps or websites, including managing your contact information, such as your name, email, and phone number.
Removing & Deleting Your Information
You can also request to remove content from specific Sendal services based on applicable law.
To delete your information, you can:
• Delete specific Sendal apps, including your information associated with those apps.
• Delete your entire Sendal account.
There are other ways to control the information Sendal collects whether or not you’re signed in to a Sendal Account, including:
• Browser settings: You can configure your browser to indicate when Sendal has set a Cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. However, please note that our services rely upon Cookies to function properly.
• Device-level settings: Your device may have controls that determine what information we collect. For example, you can modify location settings on your Android device. SHARING YOUR INFORMATION
When Sendal Shares Your Information
Sendal does not share your personal information with businesses, organizations, or individuals outside of Sendal, except in the following cases:
Equipment Vendors – We share the commands that you want to send to your Equipment (whether manual commands or automated commands that you approve) to the vendors of your Equipment. For example, we collect this information when a your Equipment contacts our servers or when Sendal’s cloud service contacts the Equipment’s cloud service — for example, when you identify a new piece of Equipment in our app or you monitor or control your Equipment with our apps.
When You Provide Consent - We’ll share personal information outside of Sendal when we have your consent. For example, when you purchase Equipment or software services through the Sendal marketplace we share information to facilitate the purchase or subscription. We’ll ask for your explicit consent to share any sensitive personal information.
Account Administrators - Any service providers or builders who manage your account on your behalf will have access to your Sendal Account. They may be able to:
• Access and retain information stored in your account
• Change your account password
• View and change the equipment registered in your Sendal Account
• Suspend or terminate access to your Sendal Account
• Access your account information in order to comply with laws or governmental requests
• Change your privacy settings.
Our Service Providers - We provide your personal information to our affiliates and other service providers so that they may process it for us. This processing is only to be done in accordance with our instructions and in compliance with our Privacy Policy. We require our service providers to keep your information confidential and to maintain appropriate security measures.
To Comply with Law - We will share your personal information with third parties if we have a good-faith belief that those third parties require your information in order to:
• Meet any applicable law, regulation, valid governmental request or legal process.
• Enforce applicable service contracts, including investigation of potential breaches.
• Detect, prevent, or address fraud or security issues.
• Detect, prevent or address technical issues.
• Protect others against harm, including the rights, property or safety of Sendal, our employees, our users and the public, as required or permitted by applicable law.
We may share aggregated or other anonymized information that we have derived from your information publicly and with our suppliers, vendors and other partners. For example, we share information publicly to show trends in the use of different types of Equipment.
If Sendal sells or otherwise transfers its business, such as in a merger, acquisition, or sale of assets, we will continue to keep your information confidential and will notify you before we send your personal information to someone who has a different privacy policy.
HOW WE KEEP YOUR INFORMATION SECURE
We work hard to protect you and Sendal from unauthorized access, alteration, disclosure, or destruction of information we hold, including:
• We restrict access to personal and confidential information to those Sendal employees, contractors, suppliers, partners and agents who need that information in order to process it.
• We encrypt your data to keep it private while in transit.
• We periodically review our information collection, storage, and processing practices, including physical security measures.
DELETING YOUR INFORMATION
You can delete specific Sendal apps, including your information associated with those apps, from your devices. You can also delete your entire Sendal account. Even if your account is deleted, we may retain certain of your information as provided below.
When you delete data, we follow a process to make sure that your data is completely removed from our servers or retained only in anonymized form. This process takes time, so there may be delays between when you delete something and when copies are deleted from our systems.
RETAINING YOUR INFORMATION
We retain the data we collect for different periods of time depending on what it is and how we use it:
• We keep some data until you delete your Sendal Account, such as what type of Equipment you monitor and control using our apps.
• We keep some data for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention or financial record-keeping.
COMPLIANCE
We regularly review this Privacy Policy to ensure that we process your information in ways that comply with it.Our hosting providers maintain servers all over the world. Because of this, your information may be processed on servers located in a country other than where you live. Wherever we process your data, we do so as stated in this Privacy Policy. When we receive formal written complaints about data we take the following steps:
• We contact the person who made the complaint.
• We attempt to work with the owner of the data.
• If we cannot resolve complaints directly, we work with the appropriate legal and regulatory authorities to resolve any complaints.
CCPA (CALIFORNIA) REQUIREMENTS
The California Consumer Privacy Act (CCPA) requires specific disclosures for California residents.This Privacy Policy is designed to help you understand how Sendal handles your information:
• We explain the categories of information Sendal collects and the sources of that information in the section of this Privacy Policy entitled, “Information Sendal Collects.”
• We explain we use information in the section entitled, “Why Sendal Collects Data.”
• We explain when we might share your information in the section entitled, “Sharing Your Information.”
Sendal does not sell your personal information.
The CCPA also gives you the rights to:
• Request information about how we collect, use, and disclose your personal information,
• Access your information,
• Request that we delete your information, and
• not be discriminated against for exercising your privacy rights.
If you have questions or requests related to your rights under the CCPA, you (or your authorized agent) can also contact us as provided above.
The CCPA requires a description of data practices using specific categories. The table below uses these categories to organize the information in this Privacy Policy.
Categories of Personal Information We May Collect
• Identifiers such as your name, phone number, email address and mailing address, as well as Data Tags tied to the browser, app, or device you’re using.
• Demographic information, such as your age, gender and language.
• Commercial information such as your payment information and a history of purchases you make on Sendal’s apps or websites.
• Equipment information such as the types of Equipment that you monitor and control using Sendal’s apps.
• Geolocation data, such as may be determined by GPS, IP address, and other data from sensors on or around your device, depending in part on your device and account settings. You can disable this by changing the permissions in your Device.
• Audio, electronic, visual and similar information, such as voice and audio information when you use audio features.
• Inferences drawn from the above.
Business Purposes for Which Information May Be Used or Disclosed
•Protecting against security threats, abuse, and illegal activity - Sendal uses and may disclose information to detect, prevent and respond to security incidents and for protecting against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, Sendal may receive or disclose information about IP addresses that malicious actors have compromised.
• Auditing and measurement - Sendal uses information for analytics and measurement to understand how our services are used, as well as to fulfill obligations to our partners like publishers, advertisers, developers, or rights holders. We may disclose anonymized information publicly and with these partners, including for auditing purposes.
• Research and development - Sendal uses information to improve our services and to develop new products, features and technologies that benefit our users.
• Use of service providers - Sendal shares information with service providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures. For example, we may rely on service providers to process payments using your payment information.
• Advertising - Sendal processes information, including online identifiers and information about your interactions with advertisements, to provide advertising.
• Legal reasons - Sendal also uses information to satisfy applicable laws, rules or governmental regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement.
Parties with Whom Information May Be Shared
• Third parties to whom you consent to sharing your information, such as services that integrate with Sendal’s services. You can review and manage third party apps and sites who have access to data in your Sendal Account.
• Service providers, trusted businesses or persons that process information on Sendal’s behalf, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
• Law enforcement or other third parties, for the legal reasons described in the section entitled, “Sharing Your Information.”
ABOUT THIS POLICY
When This Policy Applies
This Privacy Policy applies to all of the services offered by Sendal and its affiliates. This Privacy Policy doesn’t apply to services that have separate privacy policies that do not incorporate this Privacy Policy.
This Privacy Policy doesn’t apply to:
• The information practices of other companies and organizations that advertise our services.
• Services offered by other companies or individuals, including products or sites that may include Sendal services or third party services for which links may be provided in our apps and websites.
Changes to This Policy
We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published and we offer access to archived versions for your review. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes).
Key terms
App Cache
An app data cache is a data repository on a device. It can, for example, enable a web app to run without an internet connection and improve the performance of the app by enabling faster loading of content.
Cookies
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies.
Data Tags
A Data Tag is a string of characters that can be used to uniquely identify a browser, app, or device. Different identifiers vary in how permanent they are, whether they can be reset by users, and how they can be accessed.Data Tags can be used for various purposes, including security and fraud detection, syncing services such as your email inbox, remembering your preferences, and providing personalized advertising. For example, Data Tags stored in cookies help sites display content in your browser in your preferred language. You can configure your browser to refuse all cookies or to indicate when a cookie is being sent.
On other platforms besides browsers, Data Tags are used to recognize a specific device or app on that device. For example, a Data Tag such as the Advertising ID is used to provide relevant advertising on Android devices and can be managed in your device’s settings. Data Tags may also be incorporated into a device by its manufacturer (sometimes called a universally unique ID or UUID), such as the IMEI-number of a mobile phone. For example, a device’s Data Tag can be used to customize our service to your device or analyze device issues related to our services.
Device
A device is a computer that can be used to access Sendal services. For example, desktop computers, tablets and smartphones are all considered devices.
Equipment
Equipment includes any hardware and smart devices that you might use the Sendal apps to monitor and control, such as lighting controls, security systems, thermostats, smart speakers, smart door locks, smart doorbells and other home-automation devices.
IP address
Every device connected to the Internet is assigned a number known as an Internet protocol (IP) address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify the location from which a device is connecting to the Internet.
Non-Personally Identifiable Information
This is information that is recorded about users so that it no longer reflects or references an individually-identifiable user.
Personal Information
This is information that you provide to us which personally identifies you, such as your name, email address, or billing information, or other data that can be reasonably linked to such information by Sendal, such as information we associate with your Sendal Account.
Pixel Tag
A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking certain activity, such as views of a website or when an email is opened. Pixel tags are often used in combination with Cookies.
Referrer URL
A Referrer URL (Uniform Resource Locator) is information transmitted to a destination webpage by a web browser, typically when you click a link to that page. The Referrer URL contains the URL of the last webpage the browser visited.
Sendal Account
You may access some of our services by downloading our apps and signing up for a Sendal Account and providing us with some personal information (typically your name, email address, and a password, but you may, at your election, also provide your mailing address and geo-location). This account information is used to authenticate you when you access Sendal services and protect your account from unauthorized access by others. You can edit or delete your account at any time through your Sendal Account settings.
Sensitive Personal Information
This is a particular category of personal information relating to topics such as confidential medical facts, racial or ethnic origins, political or religious beliefs, or sexuality.
Server Logs
Like most websites, our servers automatically record the page requests made when you visit our sites. These “server logs” typically include your web request, Internet Protocol address, browser type, browser language, the date and time of your request, and one or more cookies that may uniquely identify your browser.
Web Storage
Web Storage enables websites to store data in a browser on a device. When used in "local storage" mode, it enables data to be stored across sessions. This makes data retrievable even after a browser has been closed and reopened. One technology that facilitates web storage is HTML 5.
