Privacy Policy

Our sensing and software platform is architected to manage and keep customer data safe and secure. We take this very seriously. We hope you will take the time to read our Privacy Policy carefully.

“We”, “us” or “our” means Whisker Labs, Inc. (“WL”), a Delaware corporation with its corporate offices located at 12410 Milestone Center Drive, Suite 300, Germantown, MD 20876 

You may contact us by email at help@whiskerlabs.com

Last updated: June 7, 2019

The Whisker Labs 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. 
  • Discerns the power quality measurements in 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

The Ting Service is intended to detect micro-arcs and anomalies in an electrical circuit that may present an electrical fire hazard.  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 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.  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.

The Terms of Use Agreement and this Privacy Policy describe our respective rights and obligations related to the Ting Services and describes how we protect and handle the information that you provide. You understand and agree that the Ting Service may include certain communications from Whisker Labs and our distributors and/or our strategic partners, such as service announcements and administrative messages, and that if you continue to use the Ting Service, you may not be able to opt out of receiving these communications without opting out of the Service entirely.

If you have any questions as to how the policy applies to you, please email us at privacy@whiskerlabs.com.

Please read this Agreement carefully. By accessing and/or using any portion of Ting Service, you agree to the provisions of the Terms of Use and this Privacy Policy.

PRIVACY POLICY

1.Communications with You 

The privacy of your personal information is important to us. We use information that you provide only as permitted by our Privacy Policy, your sharing authorizations, and/or applicable law. By accessing and using the Ting Service, (the “Services”), you acknowledge receipt of, and signify your agreement to, this Privacy Policy. You understand and agree that your registration for Services constitutes a purchase, inquiry or application under federal and state CAN-SPAM and Do-Not-Call laws, and thus creates a business relationship between you and us. From time to time, we (or our partners) may contact you by e-mail, SMS message, messages displayed on the Portals, Mobile Apps, or other methods to provide information about Services or to let you know about upcoming features or promotions that might interest you. By virtue of our business relationship, neither the federal nor any state Do-Not-Call Registry or CAN-SPAM laws preclude these communications. To the extent the contact information you provide to us includes one or more wireless devices, your provision of such information represents your permission to contact you by means of that device, and your acknowledgement and agreement that your wireless provider may charge you in connection with receipt of incoming SMS messages and calls or data usage related to use of the Services, Communicating Devices, Portals or Mobile Apps. Our means of contact may include the use of automated messaging equipment.

2. 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 Service Information in connection with your use of the Ting Service and some of this information specifically identifies you or your household. The following sections describe more specific categories of Service Information. All Service Information is combined in order to make Ting Services, and our communications with you more effectively targeted to your interests.

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 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, and does not include personally identifiable information. 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. 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. This data is hereafter referred to as Network Data (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 System program agreement applicable to you.

2.4 Anonymous Service Information. Combination of Account Information and Sensor Information with ALL PII removed.

3. 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 products and 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 personally identifiable 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 (if you purchased the Ting Service online) or collected by one of our distribution partners (such as a home service contractor or insurance company) who will then share that information with us.  In some cases we may have to share Account Information with a professional partner (such as an electrical contractor) to provide diagnostic or mitigation services to you in the event a potential hazard is identified.  In the event that Account Information is collected by others, their use of the information is governed by their own Privacy Policies. 

3.2 Sensor Information. We use Sensor Information (which does not include personally identifiable 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 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.). Sensor Information can also be used to create derivative products and services that we may sell to others.

3.3 Anonymous Service Information. We also “anonymize” Service Information by removing any identifier that can be associated with your personal Contact Information. Anonymous 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.  Anonymous Service Information helps us develop reports and analyses about how our customers use the Services and for other research such as research regarding behavioral inferences. We may share anonymous Service Information and reports and analyses based on anonymous Service Information with other service providers. We also use anonymous Service Information to troubleshoot technical issues with our System and to compile statistics and reports of usage of the Service.

4. Disclosure of Service Information to Third Parties 

We may disclose Service Information, and analyses and reports derived from such information to Contractors and Third-Party Service Providers as more fully described below. If the Service is distributed by one of our distributors or partners (e.g., an insurance carrier or HVAC contractor), they may have the same access to your Service Information as we do. Please review their Privacy Policy for additional information.

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, 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.

4.3 Affiliated Companies. We may share some or all of your Service Information with any parent company, subsidiary, joint venture or other company under a common control with us. If this happens, we will require the related company to comply with this Privacy Policy. If another company acquires us, or acquires our assets that comprise or include your Service Information, we may transfer the Service Information to that acquiring company, which may put in place its own privacy policy with terms that are different from the terms of this Privacy Policy. In that event, the acquiring company will provide you with notice of any such changes using the Contact Information that we have for you.

5. Your Choices Regarding Service Information

5.1 Initial Privacy Settings The initial privacy preferences for your account, summarized below, allow us to collect, use, and disclose Service Information including personally identifiable or anonymous Account Information and/or Sensor Information in manners consistent with this Privacy Policy.

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

5.2 Changing your Privacy Settings: How to Opt-In or Opt-Out.  In all cases we will collect and use your Account Information to enable us to provide the Ting Service . We will also collect and use Sensor Information and ND for the purposes stated in this Privacy Policy. We will provide options to opt-out of providing ND data. You can disable push notifications in the app like any other app. You can also opt out of providing lat/lon by not enabling “locations services” like in any other app. You can opt-out of email communications. You may cancel the Ting Service by sending an email to help@whiskerlabs.com.

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.

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 help@whiskerlabs.com.

6. Our Websites. Like many websites, our websites use “cookies” to recognize you and to help personalize your online experience. A cookie is a small text file that is placed on your hard disk by a web page server. These cookies contain information that can later be read by a web page server in the domain that issued the cookie to you. We use cookies to store information on your computer in order to save you time by eliminating the need to enter repeatedly the same information in order to display personalized content on later visits to the websites. We also use cookies to help us understand which parts of the websites are the most popular; where our users are going and how much time they spend at various locations within the websites. The information we collect through cookies is anonymous and we do not access any of your personally identifiable information through the cookies. You have the ability to decline cookies through your web browser. Additionally, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or visiting the Web site of its manufacturer. If you choose to decline cookies, however, you may not be able to use the features of the websites that depend on cookies. The websites may contain tiny electronic images known as web beacons. We may use web beacons to assist us in delivering cookies on the Websites and to allow us to count users who have visited those pages. We may include web beacons in promotional email messages in order to determine whether messages have been opened and acted upon.

The Ting mobile application uses a technology that embeds a web browser into a shell that runs on iOS and Android. The web browser uses cookies to track sessions and other available technology such as Google Analytics to track app usage and feature usage. This is statistical tracking and not individual user tracking.

7. General

7.1 Amendments to this Privacy Policy. We may occasionally update this Privacy Policy. When we do, we will also revise the “last updated” date at the bottom of the Privacy Policy. If we make changes that are material, as we determine in our sole discretion, we will notify you either by placing a prominent notice on the home page of the Consumer web portal or by sending you a notification directly. We encourage you to review this Privacy Policy periodically to stay informed about how we are helping to protect the Service Information we collect. Your continued use of the Ting Service after such notice constitutes your agreement to this Privacy Policy and any updates. Please be aware that this Privacy Policy and any choices you make on the Service do not necessarily apply to information you may have provided to us in the context of other of our separately operated products or services.

7.2 Technical Problems. Even though we have taken significant steps to ensure that your Service Information is never collected, used, or disclosed by us except as set forth by this Privacy Policy, technical mistakes are possible. If such a mistake takes place, we will take commercially reasonable steps to correct it.

7.3 Contact Us.  Our intention is to be diligent in protecting your privacy by carefully following our Privacy Policy. If you would like to make suggestions or find out more about our privacy practices, please email us privacy@whiskerlabs.com.

7.4 Interpreting this Privacy Policy. Examples listed in this Privacy Policy are provided to assist your understanding of this Privacy Policy and are not intended as exhaustive lists. Section headings are provided for your convenience. This Privacy Policy supplements and is incorporated into the applicable End User License Agreement. YOUR CALIFORNIA PRIVACY RIGHTS Pursuant to California Civil Code Section 1798.83(a), if you downloaded or otherwise received, installed or use any portion of the Service, you may request the following information, which will be provided to you via either a writing or email free of charge: (1) a list of the categories of personal information disclosed by us to third parties for the third parties’ direct marketing purposes during the immediately preceding calendar year and (2) the names and addresses of all third parties that received personal information from us for the third parties’ direct marketing purposes during the preceding calendar year and, if the nature of the third parties’ business cannot reasonably be determined from the third parties’ name, examples of the products or services marketed, if known to us, sufficient to give you a reasonable indication of the nature of the third parties’ business. Consumer requests for this information should be sent to privacy@whiskerlabs.com.