Updated May 22, 2020
“We”, “us” or “our” means Whisker Labs, Inc. (“WL”), a Delaware corporation with its corporate offices located at 12410 Milestone Center Drive, Suite 325, Germantown, MD 20876
You may contact us by email at email@example.com
The Ting Service
- Measures electromagnetic data from the home’s electrical network to detect the pre-cursors to potential electrical fire hazards, which are micro-arcs and sparks that develop over time in cords, wires, or faulty devices.
- Measures the power quality delivered to the home and monitors for abnormalities to inform customers of fluctuations in power quality, such as changes in voltage or line frequency which can cause damage to devices and appliances.
- Identifies and monitors the operation of certain devices and appliances, such as the HVAC, to provide performance diagnostics and/or fault prediction.
- Analyzes the data to determine potential problems with the electrical grid “upstream” from the home, such as transformer malfunctions, loose connections or other utility grid faults that could: (1) serve as ignition sources for home electrical fires in the home, (2) present electrical shock hazards, (3) damage home wiring, appliance, electronics and devices, and (4) serve as ignition sources for wildfires.
- We refer to this data collectively as “Sensor Data”.
The Ting Service is intended to detect micro-arcs and anomalies in electrical circuits that may present electrical fire hazards, electrical shock hazards and potentially cause damage to appliances, electronics, and devices in a home. Electricity is a complex phenomenon, and electrical circuitry can be a complex system. In order for the Ting Service to perform effectively, it is important that we have access to data and information about the environment in which Ting is operating, and the environment around it. For example, we ask for and collect location information to better understand where your home is located and to correlate the Sensor Data with weather data to better understand anomalies in the power signals. The information that we ask you for and the data that we collect through the operation of the system is used to enable and improve our analyses and notifications, and to allow us and our professional partners to better serve you.
If a potential electrical fire hazard is detected we will contact you via app notification, text, email, and/or telephone as soon as it is practicable after we determine that the electrical signal may pose a hazard. We may ask for your assistance to help isolate the signal within your building, to help us with diagnosis and to help us determine whether an electrician should be consulted, and we may ask that you contact your electrical utility to notify the utility company to a potentially dangerous grid fault. You agree to provide such assistance as reasonably may be needed in this regard but only to the extent that you are comfortable providing requested assistance and expressly agree to do so.
If you have any questions as to how the policy applies to you, please email us at firstname.lastname@example.org.
- Communications with You
- We Collect and Use Certain Information
We collect information relating to you and your use of the Ting Service in order to provide services and features that are easy to use and responsive to your needs. We collect various categories of information in connection with your use of the Ting Service (“Service Information”) and some of this information specifically identifies you or your household. The following sections describe more specific categories of Service Information.
2.1 Account Information. Account Information is information about you and your account, including your Contact Information, payment information, service term information, and other account-related information that is necessary or useful for us to manage your account. Account Information includes personally identifiable information (PII). Account Information is provided by you for the provisioning of the Ting Service. Contact Information means information that allows someone to identify and/or contact you, including, for example your name, latitude/longitude, address, telephone number, and email address. When you register with the Ting Service, you provide us with Contact Information. We also collect information about your preferences and settings for the Ting Service. We may also collect other information about you, including information about your home or structure available from public databases (such as home profile, home size, age of home). If you purchased Ting online, your credit card information is secured by our third-party e-commerce provider (such as Shopify).
In the event that you contact us for customer support, or we contact you to support the Ting Service, we may also request that you provide additional information relevant to the support effort. If additional information is not provided we cannot guarantee delivery of the Ting Service. We may retain communications relating to customer support, and information drawn from such communications, for statistical and reference purposes.
2.2 Sensor Information. Sensor Information includes information measured, monitored, detected, or otherwise gathered by the Ting sensor. Ting measures electrical voltage at very high frequencies to, among other things, detect potential electrical fire hazards, power quality events, estimate energy use, disaggregate and identify appliances and devices connected to your electrical network, and predict failures and faults in the performance of those appliances or devices. Individual and/or aggregated Sensor Information may also be used to identify potential faults with the electrical utility grid in your area. Ting also utilizes Bluetooth and WiFi radios to detect the presence of other devices communicating through Bluetooth or on the WiFi network that Ting is connected to (“Network Data”, or “ND”). ND is used to support the identification, location and mitigation of electrical fire hazards, to monitor the performance and possible faults of appliances and devices, and to identify appliances or devices that may be damaged by electrical power faults (for example, power surges and sags). We DO NOT see any of the content being delivered by any of the Bluetooth or WiFi devices, only the broadcast information that helps us identify the type of device and in some cases its manufacturer.
2.3 Survey Information. Survey Information is information relating to your experiences and satisfaction with the Services and suggestions relating to the Services provided by you through one of the Survey Sites or by other means, which indicate that such information may be shared publicly unless otherwise provided in the system program agreement applicable to you.
2.4 Anonymized Service Information. Combination of Account Information and Sensor Information with ALL PII removed.
- How We Use Service Information
We use Service Information for a wide variety of purposes, including enhancing the Ting Service, to provide you with customer service and to make a wider range of services available to you. We also use your Service Information in aggregate or individual form to better understand how consumers use the Ting Service.
3.1 Account Information. We use your Account Information to establish and service your account with us, offer new services as available, and assist you in the use of the Ting Service, including customer support. Account Information may be collected directly by us or collected by one of our Distribution/Reseller Partners (such as a home service contractor, utility company, or insurance company) who will then share that information with us. In some cases, we may share Account Information with our Professional Partners – such as a home service contractor, utility company, insurance company and/or fire department/emergency services (“First Responders”) to provide diagnostic or fire safety mitigation services to you and/or to the utility grid. In the event that Account Information is collected by others and not by us, please be aware that their use of the information is governed by their own Privacy Policies.
3.2 Sensor Information. We use Sensor Information to detect potential electrical fire hazards, power quality events, estimate energy use, disaggregate and identify appliances and devices connected to your electrical network, and predict failures and faults in the performance of those appliances or devices, and detect potential problems and faults on the electric utility grid, and ND is used to support the identification, location and mitigation of electrical fire hazards, to monitor the performance and possible faults of appliances and devices, and identify appliances or devices that may be damaged by electrical power faults (power surges and sag, etc.).
3.3 Anonymized Service Information. We also “anonymize” Service Information by removing any identifier that can be associated with your personal Contact Information. Anonymized Service Information may be associated with or include other Account Information or Service Information that does not identify you. It allows us to understand usage of the Services at a variety of levels. Anonymized Service Information helps us develop reports and analyses about how our customers use the Services. We may share Anonymized Service Information and reports and analyses based on anonymous Service Information with other service providers. We also use Anonymized Service Information to troubleshoot technical issues with our System and to compile statistics and reports of usage of the Service.
- Disclosure of Service Information to Third Parties
4.1 Contractors and Third-Party Service Providers. We may use independent contractors to assist with our operations. Such Contractors may include home service contractors, HVAC or electrical contractors, electric utility companies, and First Responders. Third-Party Service Providers may include consultants, billing auditors, attorneys and accountants, potential purchasers of our business, collection agencies, and third parties who provide services necessary for us to provide the Service or conduct legitimate business activities in connection with the Services. Their access to Service Information will be limited to specific tasks. We require these Contractors and Third Parties to protect the confidentiality of your Service Information and to use it only as necessary to perform the services they are asked to perform. These Contractors and Third Parties are responsible and liable if they misuse any Service Information.
4.2 Compliance with the Law: Protection of Our System and Services. Because your privacy is very important to us, we have put in place commercially reasonable technical, physical, and administrative measures to protect the Service Information that we collect. No security system is perfect, however, and we cannot guarantee that your Service Information will not be disclosed to unintended third-party recipients. It is possible that third parties may circumvent our security measures to unlawfully intercept or access your Service Information. In addition, we may be legally obligated to disclose Service Information to the government or third parties under certain circumstances, such as in response to a legal demand issued by a government entity, a subpoena issued in connection with a civil or criminal investigation or litigation, an order from a court or regulatory agency, or to comply with regulatory requirements. We may determine that, notwithstanding the provisions of this Policy, it is necessary or appropriate for us to disclose your Account Information and personally identifiable Usage Information or Communicating Device Utilization Information to comply with the Electronic Communications Privacy Act, the Digital Millennium Copyright Act, and any other relevant laws or regulations, to enforce our applicable End User License and Service Agreement or any other of our policies, to exercise our legal rights or defend against legal claims, to protect the integrity of our operations, to protect our customers, or to prevent a crime.
- Managing Your Information and Privacy Choices
In summary, your default privacy settings are:
- Account Information – Required to Provide Service
- Sensor Information – Required to Provide Service
- Network Data (ND) – Opt-out in Ting App settings
5.3 Effect of Certain Opt-Out Choices. You understand that our ability to gather and use Service Information may be necessary to provide certain personalized services, features, and functions. If we cannot gather certain Service Information (such as specific Sensor Information, or certain Network Information), we may not be able to provide such personalized services, features, and functions. The lack of certain information may negatively impact our ability to properly identify or analyze potential hazards. NOTE: If you opt-out of, or ask us to delete information that is Required to Provide Service, we will disable your account and the Service. No credits or refunds will be available in this event.
5.4 Review and Update of Account Information. You may review your Account Information collected and stored and may ask to change or update this information. If you would like to review your Account Information, you can access it through the Ting mobile application. If certain Account Information is not available in the mobile app, you may request it from email@example.com. If you ask us to shut down your account or delete your information, we will disable your account within a reasonable period of time subject to any agreement between you and us. Please note that we may need to retain some information about you in order to satisfy our contractual, legal, and security obligations. Some of your information may also remain in back-up storage for a period of time even if you ask us to delete it. In some cases, you may be entitled under local laws to access, correct, move, or object to the processing of information that we hold relating to you.
7.5 Your California Privacy Rights. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit our “California Privacy Disclosures” page.