Cirrent Privacy Policy

Last Updated May 24, 2018 

This privacy policy describes what information we collect from Connected Products (as defined below) and our websites that display links to this privacy policy, as well as how we use and disclose that information, and your related choices. 

For the purposes of this privacy policy, “Personal Data” means data that, by itself, allows someone to identify or contact you as an individual, including, for example, your name, address, telephone number and e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. Anonymous Data may be aggregated or individualized in a non-identifiable form. 

A Note to Users Outside of the United States. Personal Data may be processed in the country in which it is collected and may be transferred to and processed in other countries, including the United States, where laws regarding processing of personal data may be less protective than the laws in your country. 

A Note to Users Under the Age of 13. We do not intentionally collect Personal Data from users who are under the age of 13. If we discover that we have collected Personal Data from a child under 13, we will attempt to delete the information as soon as possible. This website and its content are directed to people who are at least 18 years of age or older. We do not collect any information from anyone under 18 years of age. If you are under the age of 18, you may not use this Website unless you have the consent of, and are supervised by, a parent or guardian. If you believe that we might have any Personal Data from a child under 13, please contact us at info@cirrent.com. 

Overview of Our Services

Cirrent is a connected-product technology provider to manufacturers, distributors, resellers, retailers and service providers (“Clients“) of commercial and consumer products and services. Our technology and services enable our Clients to connect their products to the Internet so that they and their customer users (“End Users“) can monitor and control them remotely, either directly through mobile or web-based applications or in sync with other Connected Products. We provide the communications technology that is embedded in our Clients’ Connected Products. We also operate the cloud-based services (“Cirrent Cloud“) that collect, hold, manage, and analyze data from Connected Products and enable communications between the Connected Products, our Clients, and Internet service providers (each an “ISP“) whose networks are used to connect the products to the Internet. 

Collection of Information via our Services and Connected Products

To provide our services, we and our service providers receive Anonymous Data from our Clients’ products and related mobile applications (together, the “Connected Products“). This data may include information about the Connected Product such as its make, model, device type (e.g. thermostat, light bulb, smart plug, etc.), unique device identifier (UDID), MAC address, geographic location, and IP address. We may also collect the SSIDs and BSSIDs of Wi-Fi networks that are in range of the Connected Product, network traffic usage patterns, the ISP to which the product is currently connected, its current state of connectivity (for example whether a device is on or off the network), information about other devices on the network, and its connectivity history (for example a record of when the product was first setup and when it was last connected, etc.). 

The Connected Product’s IP address is a number that is automatically assigned to it by an ISP. The UDID (or similar ID) and MAC address are unique identification numbers associated with each Connected Product. Our servers automatically log the IP address, UDID and/or MAC address of each Connected Product whenever it connects to or communicates with the Cirrent Cloud, together with the time(s) of such connection(s) or communications and information about the functions and features within the Cirrent Cloud that were accessed and used. This information is used to identify the product to the product manufacturer and ISP, and to improve the product for consumers. 

Clients and ISPs may collect Personal Data and/or Anonymous Data directly from Connected Products through the related services they provide. We do not control and are not responsible for such data collection by our Clients and ISPs. Please refer to the privacy policy for the manufacturer of any Connected Product you purchase or use and for each ISP whose network is used to connect your device to the Internet to understand their respective data privacy practices. Note that your device may connect to the Internet automatically using the network of an ISP in range of your device that is different from the ISP to which you subscribe. For example, when your Connected Product is first powered on, it may connect automatically to a public Wi-Fi service or to a commercial ISP network that has contracted with us to provide default connectivity for your Connected Product to the Cirrent Cloud. Your Connected Product will continue to connect to the Internet through a default ISP’s network until you change your device’s connection settings. Your Connected Product may also revert to a default network connection if it loses connectivity with the network you have selected or if you move it beyond the range of your selected network. Please refer to the user instructions for your Connected Product or consult with the product manufacturer to learn how to change and otherwise manage the ISP network connections for your device. 

Collection of Information via Our Website

If you create an account on the Cirrent website available at www.cirrent.com, we will collect your first and last name, email address, and company name. 

If you fill out a form to download educational content or sign up for an event on the Cirrent website, we will collect your first and last name, email address, and company name. We will process this information in order to provide you with educational content in the future. 

We also will collect your email address if you subscribe to our newsletter. 

If you apply for commercial credit, purchase a service, or download a software update, we may also collect a variety of Personal Data including, without limitation, your name, job title, employer, work mailing address, work phone number, work email address, contact preferences, and payment card information. 

If you apply for a job through our website, we will collect information such as your name, email address, phone number, and resume. If you choose to provide us with contact or other Personal Information about a prior supervisor, reference or other third party, it is your responsibility to obtain his or her consent to provide this information to us. 

We automatically log information about the computers and devices you use to access our website and view our email messages, as well as information about how you interact with our website and emails. This information may include, without limitation: 

  • Records of the web pages and content you view and links you click on while navigating within our site;
  • Information about your interactions with our video or audio content;
  • Information about your interactions with our email messages, such as the links you click on and whether you open or forward a message, the date and time of these interactions and the device you use to read emails;
  • The time and duration of your visit and information about how long you visited particular pages or features of our site;
  • The site you visited before visiting our website and the site you visited after visiting our website;
  • Your Internet Protocol (IP) address (a numerical address assigned to your computer by your ISP so that other computers connected to the Internet can communicate with your computer online) that can sometimes be used to derive your general geographic area;
  • Search terms you enter using our site or on a referral site;
  • Unique identifiers, including mobile device identification numbers, that can identify the physical location of devices in accordance with applicable law;
  • Your device type, screen size, browser type, language and other settings, memory capacity, plug-ins, Internet domain, TCP configuration parameters, operating system, carrier code, time zone and the names, versions and package IDs of software installed on your device; and
  • Information collected through Cookies, Pixel Tags, Analytics Services, and other tracking technologies (see additional descriptions of these terms below).
 

We do not currently respond to “Do Not Track” signals from web browsers. 

We and our service providers also may log information using Cookies with your express consent via a popup on any page of the Cirrent website. If you do not accept Cookies, you may not be able to use all of the features and functions of our website. “Cookies” are small data files stored on the user’s hard drive by a website. We may use both session Cookies (which expire once your web browser is closed) and persistent Cookies (which stay on your computer until you delete them) to provide users with a more personal and interactive experience on our website. 

When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features. Flash Cookies are different from browser Cookies because of the amount and type of data and how the data is stored. 

We use third-party analytics services (“Analytics Services“), to help analyze how users use our websites. The information generated by the Cookies or other technologies about your use of our websites (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which may include Personal Data and/or Anonymous Data. The Analytics Services may also transfer the Analytics Information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Service’s ability to use and share Analytics Information is restricted by such Analytics Service’s terms of use and privacy policy. By using our website, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of our Analytics Services, please contact us at info@cirrent.com. 

In addition, we use “Pixel Tags” (sometimes also referred to as clear gifs, web beacons, or web bugs). Pixel Tags are tiny graphic images with a unique identifier similar in function to Cookies that are used to track online movements of web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in web pages or email messages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to help ensure that we are sending only messages that are of interest to our users. 

We also collect Personal Data from you at other points on our website that state that Personal Data is being collected. 

Our website may contain links to third-party websites. When you click on a link to any other website or location, you will leave our website and go to another website where another entity may collect Personal Data and/or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Our privacy policy does not apply to these outside websites or the data they collect about you, your computer, or your device. We encourage you to read the privacy policies of every website you visit. The links to third-party websites or locations are provided for your convenience and do not signify our endorsement of the operators of such linked sites or of the products, services and content they provide.

How the Information We Collect is Used

We may use the information we collect as follows:
  • We use the Anonymous Data we receive through our Connected Product services to provide connectivity, control, and feedback for the Connected Product. For example, we may use this data to determine that a Wi-Fi password should be sent down to a particular device.
  • We use the Anonymous Data collected from your Connected Product to help our Clients assign the correct End User account to the product and to prevent unintended users from setting up or controlling your product.
  • We use Personal Data collected from our website to respond to comments and questions, fulfill requests and provide customer service.
  • We use Personal Data collected from our website to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • We use Personal Data collected from our website users, including without limitation, the e-mail and postal addresses registered to your account to send communications about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
  • If you apply for a job through our website, we use the Personal Data you submit to process and respond to your job application, including to assess your skills and interest in job opportunities, conduct reference checks, verify the information provided, and for compliance with corporate governance and legal and regulatory requirements. Personal Data that you submit may also be added to our candidate database for future consideration when job vacancies arise. If you are hired, we may also use the information collected during the application process for other business purposes relating to your employment.
  • We may aggregate individual Anonymous Data records to create new Anonymous Data.
  • We may also create Anonymous Data records, in either individual or aggregate form, from Personal Data by excluding information that makes the data personally identifiable.
  • We use Personal Data and Anonymous Data to operate, maintain, and improve our website, products, and services, including but not limited to, for auditing, data analysis, and research purposes and to help us make sales, marketing, and other business decisions.
  • We use Personal Data and Anonymous Data to protect, investigate, and deter fraudulent, unauthorized, or illegal activity and for loss prevention purposes.

How We Disclose Information

 

We reserve the right to use and disclose Anonymous Data for any purpose in our sole discretion. For example, we may disclose Connected Product data and/or other Anonymous Data to Clients and/or ISPs with which Cirrent has established relationships for their own uses, including, without limitation, for their respective marketing, research, product support, customer service and product development purposes. 

While Cirrent does not share Personal Data with Clients or ISPs in the ordinary course of business, a Client or ISP may combine Anonymous Data we provide with other information that it has collected about you in a manner that would change the Anonymous Data into Personal Data. Such information may be used by the Client or ISP in accordance with the terms of its own privacy policy, which we do not control. For a list of Clients and ISPs that we partner with and to whom we may disclose Anonymous Data, please contact us at info@cirrent.com. 

In addition, we may disclose the information we collect:
  • In any manner for which an individual has provided consent.
  • In order to provide our products and services and fulfill our obligations to our Clients.
  • To service providers who need it to do work for us.
  • If we believe that we have a legal obligation to do so, such as to comply with applicable laws and legal processes.
  • For legal, protection, and safety purposes such as when we believe disclosure is necessary to protect the rights, property, and/or safety of Cirrent, our Clients, End Users, or others.
  • To enforce our agreements, policies, and terms of use.
  • In connection with a business transaction, or negotiation of a business transaction, involving the sale or transfer of all or a part of our business or assets. These deals can include, without limitation, a corporate merger, financing, acquisition, sale of assets, bankruptcy transaction or proceeding, or other similar transaction.

Information Choices for Information Collected from Connected Products

 

Because we do not have direct relationships with End Users and do not collect Personal Information from Connected Products, any request to access, correct, amend or delete inaccurate Personal Data associated with your Connected Product should be directed to the applicable product manufacturer.

User Choices for Information Collected from Our Website

 

If you have subscribed to our electronic newsletter, you can opt out at any time by clicking the unsubscribe link or manage your communication preferences at the bottom of each electronic newsletter we send or by contacting us at info@cirrent.com. 

In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. To exercise these rights, email info@cirrent.com. 

You can opt out of receiving promotional emails from us by emailing info@cirrent.com. If you choose to no longer receive marketing information, we may still communicate with you regarding such things as your security updates, product functionality, responses to service requests, or other transactional, non-marketing/administrative related purposes. 

If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. 

You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area (“EEA”), Switzerland and certain non-European countries (including the US and Canada) are available here. 

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your personal information.

Security of Information

 

We use a variety of security technologies and procedures to help protect the Personal Data that we collect from you from unauthorized access, use, or disclosure. We also require you to enter a password to access your account information on our website. Please do not disclose your account password to anyone. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure and accordingly we cannot guarantee the security of our databases or that information you supply won’t be intercepted while being transmitted to us over the Internet. 

We have no control over, do not review, and cannot be responsible for, Personal Data collected by third parties, including Clients and ISPs.

Updates

 

We reserve the right to modify or update our privacy policy from time to time. If we modify our policy, we will indicate when such terms are effective and will also update the “last updated” date above. We encourage review of this policy periodically to stay informed about how we collect, use, and disclose data.

Contact Information

 

We welcome comments or questions about this privacy policy. You may also contact us at Cirrent, PO Box 809, San Mateo, CA 94401 Attn: Privacy Department or info@cirrent.com.