Privacy Policy

Belwith Products LLC., (“SecuRemote®”) provides this “Privacy Policy” to inform our users of our

policies and procedures regarding the collection, use and disclosure of the personal information

that we receive when they visit and use the https://portal.securemote.com site and any

websites owned or operated by Belwith ( the “Site” or collectively, the “Sites”), and when they

use any of SecuRemote® products, services or applications (such as our mobile application). For

ease of reading in this Privacy Policy, the Sites, products, services and applications are referred

to collectively as the “Service” or “Services”. This Privacy Policy applies only to information that

you provide to us when you use the Services.

Your use of our Service indicates your agreement to this Privacy Policy. If you do not agree to

any part of this Privacy Policy, then you should stop accessing the Service.

Changes to Privacy Policy

This Privacy Policy may be updated from time to time to reflect changes to our information

practices. If we make any material changes, we will notify you by means of posting an updated

version of this Privacy Policy on the Site. We encourage you to periodically review this page for

the latest information on our privacy practices. Any modifications to this Privacy Policy will be

effective upon our posting of the new terms and/or upon implementation of the new changes

on the Service. In all of the above cases, your continued use of the Service after any notice or

posted modified Privacy Policy indicates acceptance of the modified Privacy Policy.

Collection of Personally Identifying Information

In the course of using the Services, you may provide and we may collect certain personally

identifying information that can be used to contact or identify you, administer your account

and to provide the Services (“Personally Identifying Information” or “PII”). PII may include, but

is not limited to, your name, photo, phone number, device information, email address, and

postal addresses. You may at any time refuse to provide the PII that we request; however, this

may limit our ability to sell you products or to provide the Services to you.

How We Use Personally Identifying Information

PII is used for the following purposes: (i) to provide, administer and improve our Services, (ii) to

better understand your needs and interests, (iii) to fulfill requests you may make, (iv) to

personalize your experience, (v) to provide Service announcements, (vi) to provide you with

further information and offers from SecuRemote® or third parties; and (vii) to comply with our

legal obligations, resolve disputes with users, enforce our agreements and to protect,

investigate and deter against fraudulent, harmful, unauthorized or illegal activity.

Information Related to the Use of the Services

Our servers automatically record certain information about how a person uses our Services (we

refer to this information as “Log Data”), including both account holders and non-account

holders. Log Data may include information such as a user’s Internet Protocol (IP) address,

location, device and browser type, operating system, the pages or features of our Services to

which a user browsed and the time spent on those pages or features, frequency with which the

Services are used by a user, search terms, the features and links on our Services that a user

clicked on or used, and other statistics. We use this information to administer the Services and

we analyze this information to improve and enhance the Services by expanding their features

and functionality and tailoring them to our users’ needs and preferences.

Service Account Set Up

In order to use an SecuRemote® product, you must download our mobile application and set up

an account. During this process, we will ask you for certain information necessary to establish

and use your account, including your name, telephone number, email address, and profile

photo.

Device and Application Operation

We may record information relating to the setup, general performance, and operation of our

Service, your application and lock (and of other of our locks in your home or business or that

you otherwise may access), including device status, logs of those who lock/unlock the device

and Service, the guests that you invite, and those people who may invite you as a guest, to use

the device and application. We may store this data along with your PII and other information

about your use of our Service. We use this information to allow you (and us) to operate and

monitor your device and our Service.

Mobile Data

When you use certain features of the Service, in particular our mobile applications, we may

receive, store and process different types of information about your location, including general

information (e.g., IP address, zip code) and more specific information (e.g., GPS-based

functionality on mobile devices used to access the Service or specific features of the platform).

If you access the Service through a mobile device and you do not want your mobile device to

provide us with location-tracking information, you can disable the GPS or other location-

tracking functions on your mobile device. See your mobile device manufacturer’s instructions

for further details. Of course, if you do this, Service functionality (such as the Auto-Unlock

feature described immediately above) may not work.

Guest Access

As part of our Services, you may give others (“guests”) permission levels to access your

SecuRemote® device – e.g. to unlock and lock your door (and possibly even to pass this access

along to others). Needless to say, you must be careful of the guests that you invite and the

access that you give them. You are responsible for all uses of your account, so be careful to

secure this information and only give access to people you trust.

Additionally, certain portions of your PII, device and Service information may be shared with

the people that you invite, such as your name and lock location, and the status of the lock (e.g.

locked or unlocked).   We may also collect PII (as required to use the Service as set forth in this

Privacy Policy) about the guests that you invite in order to allow them to have access to your

SecuRemote® device and Service. All such information (including their Service usage

information) is subject to, and will be used and disclosed as set forth in, this Privacy Policy. All

guests expressly consent to such use and disclosure as a user of the Service. If you are a guest

and do not consent to such use, you should stop using the Service. Guests should be aware

that the person(s) providing access to a specific device may be able to see information about

the guest’s usage of the device and our Service and may revoke or limit access rights in their

discretion without notice. Guests should also be aware that their PII and usage information

may be shared with third-party service providers as set forth in this Privacy Policy, including

those service providers selected by the person(s) that invited you to use their lock (see “Your

Third Party Service Providers” below).

In connection with the guest invitation process, we may ask for access to your contact list. We

will only store information for contacts that you add as guests. We will only access and store

such information with your express consent.

If you send us a request (for example via a support email or via one of our feedback

mechanisms), we may use your information to contact you and provide support or a response.

We also reserve the right to publish your request in order to help us clarify or respond to your

request or to help us support other users.

Mailing List and Contact Information

You may choose to submit your email address or other contact information via our Services. We

may use this information to send you news about SecuRemote®-related services, products or

promotions. We may use one or more service providers to administer these messages, but we

do not share your email address with spammers or any other third parties without your

permission. We will give you the ability to opt out of marketing-related e-mails by logging in

and changing your account settings or by clicking on a link in each such e-mail. In some of our

communications, we use tracking means, such as a “click-through URL” linked to content on the

Site. We track this data to help us measure the effectiveness of our customer communications.

Aggregate and non-PII Information

SecuRemote® may collect and analyze non-PII information about the performance of its

Services. From time to time, SecuRemote® may disclose and use aggregate and non-personally-

identifying information for industry analysis, demographic profiling, marketing and advertising,

and other business purposes, e.g., by reporting on trends in the usage of its devices, Sites or

Services.

Disclosure to Third Parties

We do not share or sell the Personal Identifying Information that you provide us with other

organizations without your express consent. Under this Privacy Policy you and your guests

hereby consent to sharing under the following circumstances:

Our Service Providers. We may employ third party companies and individuals to administer and

provide the Services on our behalf, (including, without limitation, maintenance, administration,

support, hosting and database management services). These third parties may have access to

your PII only to perform these tasks on our behalf and are obligated not to disclose or use it for

any other purpose.

Information Shared with Other Users. If you invite a guest to access your device, then we may

share certain elements of your information with them (name, lock location, picture, etc.) in

order for them to understand the invite and access the device.   We may also similarly share

their information with you.

Compliance with Laws and Law Enforcement; Protection of Rights and Safety. SecuRemote®

cooperates with government and law enforcement officials and private parties to enforce and

comply with the law. We will use, and disclose any information about you to government or law

enforcement officials or private parties as we, in our sole discretion, believe necessary or

appropriate to respond to claims and legal process (including but not limited to subpoenas), to

protect the property and rights of SecuRemote® or a third party, to enforce our Terms of

Service, End User License Agreement, and this Privacy Policy, to protect the safety of the public

or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of

being, illegal, unethical, inappropriate or legally actionable.

Business Transfers, Affiliates and Joint Ventures. SecuRemote® may sell, transfer or otherwise

share some or all of its assets, including your PII, in connection with a merger, acquisition,

reorganization or sale of assets or in the event of bankruptcy. We may share your personal

information with our parent company, subsidiaries, joint ventures, or other companies under a

common control that we may have now or in the future, in which case we will require them to

honor this Privacy Policy.

Minors

Our Services are not directed to children under 13 and we do not knowingly collect PII from

children under 13. If we learn that we have collected PII of a child under 13 we will take steps to

delete such information from our files as soon as possible.

Changing or Deleting Your Information

All SecuRemote® users may review, update, correct or delete the PII in their registration profile

by logging into their account. Removing your information may limit our ability to provide the

Services to you. If you completely delete all such information, your account will be deactivated

and you may lose access to the Service and your use of the device. You may also contact us at

support [at] delphiansystems [dot] com if you have additional questions or concerns. We’ll take

steps to modify or delete your information as soon as is practical, but some information may

remain in archived/backup copies for our records or as otherwise required by law.

Links to Other Sites and Services

The Services may contain links to other websites or services. The fact that we link to a website

or service is not an endorsement, authorization or representation that we are affiliated with

that third party. We do not exercise control over third party websites or services. Other

websites and services follow different rules regarding the use or disclosure of the PII you submit

to them. We encourage you to read the privacy policies or statements of the other websites

you visit and services that you use.

Data Retention

We may retain an archived copy of your records as required by law or for legitimate business

purposes. SecuRemote® will retain PII for as long as needed to provide you Services, subject to

this Privacy Policy. SecuRemote® may retain and use this PII as necessary to comply with our

legal obligations, resolve disputes, and enforce our agreements.

Security

The security of your personal information is important to us. We follow generally-accepted

industry standards to protect the PII submitted to us, both during transmission and once we

receive it. However, no method of transmission over the Internet, or method of electronic

storage, is 100% secure. Therefore, we cannot guarantee its absolute security.