PorchCam Privacy Policy

PorchCam App - Privacy Policy

Last updated: 2/3/2025

Effective date: 2/3/2025

Porch Manager and subsidiaries (“we”,“us”, “our”, “Porch Manager”) are committed to protecting your privacy.This Home Security Privacy Policy (“Policy”) describes our practices inconnection with information protection on Personal Data we process through yourindividual use of the following services, products, and related mobileapplications (collectively, the “Products”).

Before you use our Products, please carefully readthrough this Policy and understand our purposes and practices of collection,processing of your Personal Data, including how we use, store, share andtransfer Personal Data. In the Policy you will also find ways to executeyour rights of access, update, delete or protect your Personal Data.

When you accept this Policy when you register withyourPersonal Data, or if you start to use our Products and does notexpressly object to the contents of this Policy, we will consider that youfully understand and agree with this Policy. If you have any questionr regarding this Policy, please do not hesitate to contact usvia:

Service Department: Call 1-800-241-9224 or email at info@porchmanager.com

Privacy Office: Call 1-800-241-9224 or email atinfo@porchmanager.com

For other branded mobile applications powered by PorchManager, our Clients control all the Personal Data collected through ourProducts. We collect the information under the direction of our Clients and theprocessing of such information shall be limited to the purpose of providing theservice for which our Clients has engaged us. If you are a customer of one ofour Clients and would no longer like to be contacted by one of our Clients thatuse our service, please contact the Client that you interact with directly.

Definitions

In this Policy, PersonalData means information generated,collected, recorded and/or stored, electronically orotherwise, that can be used to identify an individual or reflect theactivity of an individual, either from that information alone, or from that informationand other information we have access to about that individual.

PersonalSensitive Data includes personal biometric information, communicationrecords and contents, health information, transaction information, and preciselocation information. When we collect Personal Sensitive Data from you, wewill generate an explicit notification for your consent before we collectionpersonal sensitive data about you.

SmartDevices refers to those computing devices produced or manufactured byhardware manufacturers, with human-machine interface and the ability totransmit data that connect wirelessly to a network, including: smart homeappliances, smart wearable devices, smart air cleaning devices, etc.

WhatPersonal Data do We Collect

In order to provide our Products to you, we will ask you toprovide necessary Personal Data that is required to provide those Products. Ifyou do not provide your Personal Data, we may not be able to provide you withthe Products.

1.Information You Voluntarily Provide Us.

• Account or Profile Data: When you register an account with us,we may collect your name and contact details, such as your email address, phonenumber, user name, and log-in credentials. During your interaction with ourProducts, we may further collect your nickname, profile picture, country code,language preference or time zone information into your account.

• Feedback: When using feedback and suggestion features in ourProducts, we will collect your email address, mobile phone number and yourfeedback content to address your problems and solve device failures on a timelybasis.

2.Information We Collect Automatically

• Device Information: When you interact with our Product, weautomatically collect device information, such as the MAC address of yourdevices, IP address, wireless connection information, operating system type andversion, application version number, push notification identifier, log files,and mobile network information.

• Usage Data: During your interaction with our Sites andServices, we automatically collect usage data relating to visits, clicks,downloads, messages sent/received, and other usage of our Sites and Services.

• Log Information: When you use our app, the system andexception log may be uploaded.

Please note that one cannot identify a specific individuallyusing Device Information or Log Information alone. However, if thesetypes of non-personal information, combined with other information ,may be used to identify a specific individual, such non-personalinformation will be treated as Personal Data. Unless we have obtained yourconsent or unless otherwise provided by data protection laws andregulations, we will anonymize and desensitize such non-personal information.

• Location Information: When you enable location-based functionsthrough permission settings on your mobile device, we will collect andprocess your location information to enable certain functions, such aspairing with your Smart Devices. Also, we may collect information aboutyour real-time precise or non-precise geo-location when you use certain SmartDevices or relevant services, such as robot cleaner and weather service.

Based on your consent, when you enable the geo-fence feature onthe Products, your location information will be generated and shared withGoogle Map services. Please note that Google has corresponding data protectionmeasures, which you may refer to Google Data Protection Terms for more details:https://privacy.google.com/businesses/gdprservices/. You mayreject such use of your location information by managing the permissionsettings in the Products, upon which we will cease to collect and use yourlocation information.

3.Smart Devices Related Information

• Basic Information of Smart Devices: When you connect yourSmart Devices with our Products or Services, we may collect basic informationabout your Smart Devices such as device name, device ID, online status,activation time, firmware version, and upgrade information.

• Smart Device setting information: when you purchase thesecurity related products and set the name or description, for example,such as a video doorbell, you name it "Welcome doorbell", as well asinformation about changing the location where the security product ispairing, and any adjustments to this setting.

• Information Reported by Smart Devices: Depending on thedifferent Smart Devices you elect to connect with our Products or Services, wemay collect different information reported by your Smart Devices. For example,smart cameras may report images or videos captured by it.

Purposesand Legal Basis for Processing Personal Data

The purposes for which we may process your personal data aboutyou are as follows:

• Provide You Services: We process your account and profile data(including information about the community services), device information, usagedata, location information, and Smart Device related information to provide youwith our Products and Services that you have requested or purchased. The legalbasis for this processing is to perform our contract with you according to ourTerms of Use.;

• Improve Our Services: We process your device information,usage data, location information and Smart Device related information to ensurethe functions and safety of our Products, to develop and improve our Productsand Services, to analyze the efficiency of our operations, and to prevent andtrace fraudulent or inappropriate usage. The legal basis for this processing isto perform our contract with you according to our Terms of Use;

• Non-marketing Communication: We process your Personal Data tosend you important information regarding the Services, changes to our terms,conditions, and policies and/or other administrative information. Because thisinformation may be important, you may not opt-out of receiving suchcommunications. The legal basis for this processing is to perform our contractwith you according to our Terms of Use;

• Marketing Communication: We may process your Personal Data toprovide marketing and promotional materials to you on our Products andServices. If we do so, each communication we send you will contain instructionspermitting you to opt-out of receiving future communications of that nature.The legal basis for this processing is your consent. Additionally, if youconsent to participate in our lottery, contest or other promotions, we may useyour Personal Data to manage such activities;

• Personalization: We may process your account and profile data,usage data, device information to personalize product design and to provide youwith services tailored for you, such as recommending and displaying informationand advertisements regarding products suited to you, and to invite you toparticipate in surveys relating to your use of our Products. The legal basisfor this processing is your consent;

• Legal Compliance: We may process your Personal Data as webelieve to be necessary or appropriate: (a) to comply with applicable laws andregulations; (b) to comply with legal process; (c) to respond to requests frompublic and government authorities (d) to enforce our terms and conditions; (e)to protect our operations, business and systems; (f) to protect our rights,privacy, safety or property, and/or that of other users, including you; and (g)to allow us to pursue available remedies or limit the damages that we maysustain.

If there is any change in the purposes for processing yourpersonal data, we will inform such changes to you via email (specified in your account)and/or a prominent notice on our website of such changes of purposes, andchoices you may have regarding your Personal Data.

Share,Transfer, Disclose Personal Data

Data Sharing

At Your company name, we only share Personal Data in waysthat we tell you about. We may share your Personal Data under the followingcircumstances:

1)Obtain your explicit consent or authorization in the firstplace, or provide information to support for your dispute resolution with otherusers in accordance with your formal request.

2)In accordance with relevant agreements we contracted with you(including electronic agreements and corresponding Term of Use) or other legaldocuments provided;

3)In accordance with applicable laws and regulations, judicialprocedures, and other mandatory administrative or judicial requests;

4)In order to comply with the law, execution orders, or adhereto our Term of Use and other agreements, to the extent permitted by laws andregulations, only by sharing Personal Data can protect the rights, privacy,property or security from damage for Your company name, our affiliates,partners, you or other Your company name users;

5)To protect our facilities, operations and systems and to seekremedies available for this purpose or to limit the damages we may need toprovide;

6)Data sharing for the academic research;

7)Share Personal Data for the public interest in compliance withlaws and regulations.

• To subsidiaries or affiliates within our corporate family, tocarry out regular business activities. We will only share necessaryPersonal Data for said purpose, and our affiliates will also be bound by thethis Privacy Policy. When they change the purposes of processing Personal Data,we will obtain your explicit consent once again so that we can further processyour Personal Data.

• To our third-party service providers who perform certainbusiness-related functions for us, such as website hosting, data analysis,payment and credit card processing, infrastructure provision, IT services,customer support service, e-mail delivery services, and other similar servicesto enable them to provide services to us. In this respect, we share yourPersonal Data in a legitimate, necessary, specific and with defined purposes,meanwhile, we only share your Personal Data which are required to share. In thesame time, the third-party service providers will not access to exact PersonalData about you and have no right to use Personal Data for other processingpurposes which contracted with us.

• To our customers and other business partners who provide you,directly or indirectly, with your Smart Devices, and/or networks and systemsthrough which you access and use our Sites and Services.

Except for the third parties described above, when we decide toshare your Personal Data, only your consent can authorize us toproceed. The third parties we share Personal Data with, are required to bebound with the Non-Disclosure-Agreement, as well as this Privacy Policy toprocess Personal Data according to the defined instruction, security measuresand confidentiality.

Data Transfer

At Your company name, we only transfer Personal Data inways that we tell you about. We may transfer your Personal Data with thefollowing reasons:

1)Obtain your explicit consent or authorization in the firstplace;

2)In accordance with applicable laws and regulations, judicialprocedures, and other mandatory administrative or judicial requests;

3)In accordance with relevant agreements we contracted with you(including electronic agreements and corresponding Term of Use) or other legaldocuments provided;

4)In the event of any reorganization, merger, sale, jointventure, assignment, transfer or other disposition of all or any portion of ourbusiness, assets or stock (including without limitation in connection with anybankruptcy or similar proceedings). In such an event, you will be notified viaemail and/or a prominent notice on our website of any change in ownership,incompatible new uses of your Personal Data, and choices you may have regardingyour Personal Data. Under such circumstances, we will require the third partieswho have been transferred Personal Data to comply with this Privacy Policy,otherwise require them to obtain your consent and authorization to processPersonal Data.

Data Disclosure

We only disclose your Personal Data under the followingconditions and adopt industry-standard security measures:

1)Upon your request and through the way you consent, we willdisclose your Personal Data;

2)Where it is necessary to provide Personal Data in accordancewith laws and regulations, mandatory administrative enforcement or judicialrequirements, we may disclose Personal Data accordingly with the defined typesof data and way of disclosure. Under the premise of complying with laws andregulations, when we receive the above request for disclosure of Personal Data,we will require the corresponding valid legal documents, subpoenas orinvestigation letters. To the extent permitted by laws and regulations, thefiles we disclose are protected by encryption keys.

SecurityMeasures

We use commercially reasonable physical, administrative, andtechnical safeguards to preserve the integrity and security of your PersonalData, including but not limited to the following security measures:establishing strict internal data management systems and processes, encryptionof Personal Data (including transmission, storage and processing),desensitization of the data, segregation of employees roles and duties,conducting security and privacy awareness training for our internal employees,access control and monitoring, etc., to prevent leakage, illegal usage,unauthorized access or infringement of Personal Data.

If you have reason to believe that your interaction with us isno longer secure (for example, if you feel that the security of any account youmight have with us has been compromised), you could immediately notify us ofthe problem by emailing info@porchmanager.com

If a security incident affects the security of your account orPersonal Data, we will promptly notify you through the email address, phonenumber, or Notification Center, etc., that you provided to us, and keep youinformed of any suggestions to reduce or prevent related risks. When necessary,we will immediately take appropriate remedial measures in accordance with theinternal security response plan and report to the relevant authoritiesaccordingly.

IndividualPrivacy Rights

We respect your rights and control over your Personal Data. Youmay exercise any of the following rights:

via the “Me &rt; Personal Center (Portrait) &rt; Accountand Security” or via “Me & rt; FAQ Feedback” in the App;

by emailing us at info@porchmanager.com

You do not have to pay a fee for executing your personal rights.According to different data protection laws, your request of personal rightswill be handled within 15 business days, or within 30 calendar days due todifferent response requirement.

If you decide to email us, please make clear what informationyou would like to have changed in your request, whether you would like to haveyour Personal Data deleted from our database or otherwise let us know whatlimitations you would like to put on our use of your Personal Data. Please notethat we may ask you to verify your identity before taking further action onyour request, for security purposes.

You may:

Request access to the Personal Data that we process about you;

Request that we correct inaccurate or incomplete Personal Dataabout you;

Request deletion of Personal Data about you;

Request restrictions, temporarily or permanently, on ourprocessing of some or all Personal Data about you.

Request transfer of Personal Data to you or a third party wherewe process the data based on your consent or a contract with you, and where ourprocessing is automated;

Opt-out or object to our use of Personal Data about you whereour use is based on your consent or our legitimate interests.

•Withdrawal of consent: We will exercise your privacy right to withdrawconsent through the following approaches:

1) For privacy permissions acquired through device systemsettings, your consent can be withdrawn by changing device permissions,including location, camera, photo album (picture library/video library),microphone, Bluetooth settings, notifications and other related functions.

2) In the marketing communications that you agree to, theinformation we send to you contains instructions that allow you to withdrawyour consent in accordance with the “unsubscribe” method described in the information.

3) Unbind the Smart Device through the app, and the informationrelated to the Smart Device will not be collected.

4) By using product with the visitor mode, we will not collectany personal data about you;

when you withdraw your consent or authorization, we may not beable to continue to provide you with the products or services correspondingly.However, your withdrawal of your consent or authorization will not affect theprocessing of personal information based on your consent before the withdrawal.

About Delete of the Account: You can find the Delete functionthrough “Me &rt; Personal Center (Portrait) &rt; Account and Security&rt; Delete Account”.

InternationalTransfer of Information Collected

Primarily, Porch Manager adheres to DataLocalization Requirement and Minimum Data shall involve International Transfer,while in order to facilitate our operation, we may transfer, store and processyour Personal Data in jurisdictions other than where you live. Laws in thesecountries may differ from the laws applicable to your country of residence.When we do so, we will ensure that an adequate level of protection is providedfor the information by using the following approach:

Include but not limited to the agreement on the basis ofapproved EU standard contractual clauses per GDPR Art. 46. For moreinformation, see

https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en

If you would like further detail on the safeguards we have inplace, you can contact us directly as described in this Privacy Policy.

DataRetention

We process your Personal Data for the minimum period necessaryfor the purposes set out in this Privacy Policy, unless there is a specificlegal requirement for us to keep the data for a longer retention period.

We determine the appropriate retention period based on theamount, nature, and sensitivity of your Personal Data, and after the retentionperiod ends, we will destruct your Personal Data. When we are unable to do sofor technical reasons, we will ensure that appropriate measures are put inplace to prevent any further such use of your Personal Data.

Privacyof Young Children

Protecting the privacy of young children is especially importantto us. According to the different data protection and privacy regulations, theServices are not directed to individuals under the age of eighteen (18), and werequest that these individuals do not provide any Personal Data to us. We donot knowingly collect Personal Data from anyone under the age of eighteen (18)unless we first obtain permission from that child’s parent or legal guardian.If we become aware that we have collected Personal Data from anyone under theage of eighteen (18) without permission from that child’s parent or legalguardian, we will take steps to remove that information.

Changesto the Privacy Policy

We may update this Privacy Policy to reflect changes to ourinformation practices, but at least on an annual basis. Without your explicitconsent, we will not undermine your privacy rights under this Privacy Policy.For any regular updates, we will provide such information in the Policy page,or Notification Center in the Application, or other appropriate channels. Weencourage you to periodically review this page for the latest information onour privacy practices.

If we make any material changes we will notify you by channelsthat you can easily access to, for instance, email or SMS (send to the emailaddress specified in your account) or by means of a notice on this websiteprior to the change becoming effective.

ContactUs

If you have any questions about our practices or this PrivacyPolicy, please contact us as follows:

Porch Manager

Postal Mailing Address: 318 Seaboard Lane STE 300 College Grove,TN 37067.

Email: info@porchmanager.com