For ease of reference and for the purpose of this California Privacy Disclosures Notice, we will use the following terms:
- “Whisker Labs”, “our”, “us” or “we” means Whisker Labs, Inc.
- “Whisker Labs Services” or “Services” includes all Whisker Labs and Ting-branded apps, products, devices, and services.
- “Whisker Labs Websites” or “Websites” include WhiskerLabs.com and TingFire.com.
- Personal Information. This means any information that (either in isolation or in combination with other information) can be used to identify you directly or indirectly. Some examples of Personal Information include your name, address, email address, phone number, any ID number, or location data.
- Aggregated Information. Information may be aggregated and/or anonymized. When information is aggregated, it is combined with information about other customers and users. Aggregated information that includes Personal Information is considered Personal Information until it has been anonymized.
- Anonymized Information. When information is anonymized, Personal Information is removed from collected data and the remaining portion of the data is repurposed for internal or external use, such as, for example, to determine how many users of Ting Service experienced an electrical hazard in the past year, or how many users viewed a particular Services video. Such information cannot be used to identify you. Some examples include usage data relating to Whisker Labs Websites and Whisker Labs Services.
In most use cases, data collected when you visit Whisker Labs Websites or use Whisker Labs Services is both aggregated and anonymized; as such, in these cases it does not identify you personally and therefore is not Personal Information.
TYPES OF INFORMATION WE COLLECT AND WHY
You have the right to know what personal information we collect and why.
When you use Whisker Labs Services, we collect a few different types, or “categories,” of information. This information generally falls within three broad categories:
- the information you provide to us,
- the information we collect automatically when you use our services, and
- information we obtain from other sources.
We describe this information and the primary purpose for which it is used, below. The full description of how we use the personal information we collect is also provided below.
Information You Provide To Us
Whisker Labs collects the information you provide to us, including:
- Registration or Account Information. When you register for Service, complete any application form, or share service feedback, we sometimes ask you for your name, phone, email address, postal address, and any preferences that you may have (e.g., which newsletters you would like to receive). We use this to provide certain Whisker Labs Services, to personalize them, and remember your preferences. Importantly, because the Whisker Labs Ting Service protects the home, contact information such as name, address, phone, and email (“Account Information”) are critical and are required for us to perform the Services.
- Billing and Payment Information. When you place an order directly online with us for Whisker Labs Services, we will collect certain payment and identity verification information, including your name, email address, and credit card information. We use this to bill you for your use of the Whisker Labs Services.
- Feedback You Provide Regarding Whisker Labs Services. We collect personal information from you when you provide or post information such as general service feedback, reviews, interviews, feature requests, written and video testimonials, and success stories or case studies, including your first name and commentary. This information is used to improve our Services and help others understand how the Services work.
- Correspondence You Send Us. When you contact us directly by calling our offices or providing feedback, comments, or suggestions, we may collect the information you provide as part of your correspondence to Us. We use this to provide Services to you and to learn about your interests and concerns.
- Information You Provide About Others. Sometimes, you may provide information about others — for example, to refer a friend to certain Whisker Labs Services. We use this to make the Whisker Las Services available to the people you refer.
- Information you Provide Offline. You might also provide personal information to us in person and offline. You may be recorded if you visit our offices (including by security surveillance of our premises, including CCTV), or, if you submit forms or applications to participate in one of our programs by mail or in person. We use this information to provide Services to you, protect our security, and learn about your preferences.
The Information We Collect Automatically When You Use Our Services
Whisker Labs collects information automatically, including:
- Sensor Data. Sensor Data is electromagnetic signal data processed at high speed to assess quality and faults in your home’s electrical system, devices connected to it, and in upstream utility power. This signal data is at the heart of Whisker Labs Services. We use this 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 originating on the electric utility grid.
- Service Information. Service Information allows us to understand the usage of Whisker Labs Services at a variety of levels. Service Information helps us develop reports and analyses about how our customers use Whisker Labs Services. We may use Anonymized Service Information to troubleshoot technical or operational issues with our Services and to compile statistics and reports of usage of the Service.
- Device-Based Tracking. We and our service providers operating on our behalf, other businesses who collect information on our pages, may automatically collect or receive certain information associated with you as part of your use of the Whisker Labs Websites and Services through device-based tracking technologies such as cookies, pixels, tags, beacons, scripts or other technology. This information is used to improve and optimize the Whisker Labs Websites and Services.
- Electrical Hazard Remediation Reports. When we detect an electrical fire hazard within your home, we document the engagement and any corresponding remediation effort. In addition to a written summary, photos and videos are used to document the key elements of the remediation, including electrical panel information and the hazard source, which may include the particular device or component at fault. These reports are required to document the Service event and ensure proper and safe closeout of the electrical fire hazard.
- Location Data. The information we directly collect as part of Whisker Labs Services includes geolocation data that identifies the precise location of your mobile device with the Whisker Labs Ting App at the time of installation or re-installation of a Ting Sensor. This information is required and used solely to confirm Whisker Labs Services registration is associated with the proper structure/home being protected by the Whisker Labs Services. We do not otherwise collect or use location data from your mobile phone.
- Network Data. The information we directly collect as part of Whisker Labs Services includes the use of Bluetooth and WiFi radios to detect the presence of other devices communicating through Bluetooth or on the WiFi network that a Ting Sensor is connected to (“Network Data”, or “ND”). Network Data. We use this data 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). This information does not include personal data or content transmitted by any of the Bluetooth or WiFi devices. The only information available for this purpose includes the type of connected device and in some cases, the device manufacturer.
Information We Obtain From Other Sources
The Whisker Labs Services collect information about you from other sources, such as publicly available databases and other third parties that have the right to share your personal information. The categories of information we get from these other sources include:
- Demographic data, such as age, gender, and income level, used to customize content and advertising, and learn about our audiences;
- Publicly-observed data, such as activities on blogs, videos, and other online postings used to customize content and advertising;
- Employment-related data, including information from a recruitment agency if you are applying for a job with us, used to help us match applicants to open positions;
- We collect information about you through interactive applications (e.g., mobile devices, third-party social networking services, and embedded video platforms where we post videos related to our Services), from co-branded partners and websites (e.g., on our Facebook pages), and from commercially-available sources (e.g., public databases).
HOW WE USE THE INFORMATION WE COLLECT
- Establish and service your account with us, make the Whisker Labs Services available to you, verify your identity when you log in, remember your account settings.
- Ensure the Whisker Labs Services are installed at the proper home/structure and are optimized to ensure expedient identification, notification, localization, and remediation of discovered hazards.
- Bill you for subscription services for which there is a charge, and verify your identity or payment information for your security and protection.
- Respond to questions or concerns about your subscription or the Whisker Labs Services, assist you in the use of Whisker Labs Services, coordinate electrical hazard localization, and professional remediation, if required, and send you alerts, and important updates about your account or the Whisker Labs Services.
- Send you updates and other offers, promotions, or updates for Whisker Labs Services.
- Verify your entry into and eligibility to participate in contests or giveaways and inform you if you’ve won. If your entry information will be used for any other purposes, we will disclose that in the applicable rules governing that contest or giveaway.
- Monitor and improve the operation, delivery, and general accessibility of the Whisker Labs Services.
- Verify delivery and track performance of an advertising campaign and ensure that an ad is only delivered when a real person is visiting the site and that the same users don’t see the same ads too frequently.
HOW WE SHARE YOUR INFORMATION
- Banks or Other Organizations In Connection with a Business Transfer. We may share your information in connection with a substantial corporate transaction, such as the sale of a Whisker Labs Service, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- Regulators, Courts, Law Enforcement, and Other Governmental Authorities. We may disclose information about our users, including contact information, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with other legal obligations. There may be circumstances where the law requires us to disclose the information, or where disclosure is required to prevent a risk to health or safety, or for law enforcement purposes.
- Professional Partners. We may share your information with Whisker Labs Professional Partners who troubleshoot, respond to, or otherwise repair electrical fire hazards faults. Examples include Contractors, Utilities, and First Responders.
Contractors: We may share your information with select Contractors to address suspected electrical fire hazards inside the home that have the potential to cause a fire.
We coordinate this part of our service on your behalf and may share your name and address in arranging the service call. This Contractor engagement is a core piece of the Whisker Labs Services for the homeowner.
Utilities: We may share your information with your electrical utility to respond to suspected grid issues that have the potential to cause hazards and damage inside your home – and in nearby homes located in the proximity of the issue. These suspected issues can also indicate the potential for an ignition event along distribution lines, and the potential for a wildfire. Every such fault is considered to be a safety hazard and a potential fire threat.
Your home address and signal data are needed to help localize the origin of the hazard. In many cases address and signal data from other sensors in homes from the surrounding area will be provided at the same time depending on the nature and scale of the hazard. Importantly, the signal data shared from a home’s sensor is only from grid-oriented events, and not for events occurring within the home.
The electrical utility owns the electrical distribution network, or grid, which extends to your home, up to and including the electric meter, and is solely responsible for repairs to these hazards, which if not addressed can cause a fire or shock hazard inside your home and/or serve as an ignition source outside your home or in the local community and lead to a wildfire.
First Responders: We may share your information with First Responders as needed for situational awareness related to suspected grid events that have the potential to cause wildfires in the community.
We may share your home address or group of addresses in a community location where a potential or actual grid event has been detected.
- Authorized Third-Party Service Providers. We may share your contact information and service information with vendors who help us provide our services using their specialized services. Examples of services include customer support, email and text message deployment, analytics, marketing, accounting, and data processing. Examples of Service Providers 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. These Service Providers are allowed to use your contact information and service information only as necessary to perform the services they are asked to perform and not for any other purpose.
- Non-Profit Professional Organizations and Universities. We may share Anonymized Service Information with non-profit professional organizations or universities to help with research focused on improving fire safety, developing new standards and guidelines, and informing public education campaigns.
- Sponsors and Other Partners for Contests or Giveaways.When you choose to enter a contest or other promotion, and in accordance with the terms and conditions of the promotions, your information may be disclosed to our sponsors and others who help design, administer and implement the promotion, including in connection with winner selection, prize fulfillment and aggregated data analysis. Your information also may be disclosed as required by law, such as on a winners list. Further, by entering a promotion, you are agreeing to the official rules that govern that promotion, including allowing our sponsors to use your name, voice, and likeness in advertising and marketing associated with the promotion in accordance with applicable law. All terms applicable to the particular promotion will be made available to you at the time you enter the promotion.
‘Do Not Sell’
Whisker Labs does not sell your personal data to 3rd parties.
Right to Know
You have the right to ask us what personal information we have collected from you over the past 12 months. You may make such requests up to twice a year.
Right to Delete
You have the right to ask us to delete your personal information. In certain circumstances the law may not require or permit us to delete certain personal information, but if we cannot honor a deletion request, we will tell you.
Note that we cannot provide our Services without specific personal information. If you are Services customer and wish for us to delete your personal information, we must disable your account and the Service. No credits or refunds will be available in this event.
Children’s Personal Information
The Whisker Labs Websites and Whisker Labs Services are not directed to, nor does Whisker Labs knowingly collect Personal Information from, children under the age of 16. If we are informed that we have collected the Personal Information of a child under the age of 16, we will delete that Personal Information from our systems. If you believe we might have inadvertently collected Personal Information from or about a child under the age of 16, please contact us at firstname.lastname@example.org.
We do not offer any financial incentives for consumers to take any action or make any choices in using our services.
Exercising Your Rights
Right to Know and Right to Delete
You may ask us for the personal information we have about you or ask us to delete your personal information, by emailing email@example.com or by calling 877-793-2203. When you make a request online, we will verify your identity by sending you an email and asking you to respond. When you call the toll-free number, you must leave a name, address, and email address we can use to contact you.
If you ask what personal information we have received from you, and we cannot verify your identity, or if providing the information you have requested creates a security risk, we will give you a general description of the type of personal information we have about you.
If you ask us to delete your personal information, and we can’t verify your identity and confirm that you made the request, we will not be able to honor it. Generally, though, if we can confirm your identity and your request, we will delete, de-identify, or aggregate your personal information so it can no longer be associated with you. There are some reasons that the law may require or permit us to keep your personal information, however.
If you are an authorized agent, please follow the instructions available. In general, you will need to provide proof that you are registered with the Attorney General, as required by law, and proof you have written authority to act for the consumer. You shall also provide the email address of the consumer you are representing so we can verify their identity, or provide documentation that you have power of attorney for the consumer pursuant to Probate Code sections 4000-4465. We will not be able to honor requests without sufficient documentation that you are authorized to represent the consumer or that you are registered with the Attorney General.
Requests made on behalf of a “Household”
If you would like to request personal information about your household, please follow the instructions available to make your request. We will need to verify the members of the household, and in some cases, if a request raises security concerns for any household member, we may not be able to honor the request.
CALIFORNIA “SHINE THE LIGHT” LAW AND CALIFORNIA “ERASER” LAW
Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
For all requests under the “Shine the Light” or “Eraser” Law, please contact us. We will accept requests to exercise these rights only through our contact form referenced above with the proper subject line and complete and accurate information.
Should you have any suggestions, questions, or comments about Your California Rights, please email us firstname.lastname@example.org, by phone at 877-793-2203 or by mail at Whisker Labs, Inc., 12410 Milestone Center Drive, Ste 325, Germantown, MD 20876.