Last Updated: October 23, 2018
We provide Roost Services to our insurance company clients (“Clients”) and individuals that register through the Site and/or App (“Customer”).
Information Related to Data Collected through the Roost application:
Roost collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to third parties that help us provide our services. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Roost acknowledges that you have the right to access your personal information. Roost has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Roost’s Client (the data controller) or to Roost’s Data Protection Officer (firstname.lastname@example.org). If requested to remove data we will respond within a reasonable timeframe, and no longer than one month. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service. Roost acknowledges that you have the right to object to decisions made about the storage of your information. An individual who seeks to object to how their data is stored, processed, or revised, should direct his or her query to Roost’s Client (the data controller) or to Roost’s Data Protection Officer (email@example.com).
We will retain personal data we process on behalf of our user clients for as long as needed to provide services to our user clients. Roost will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
2 A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Roost and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us using the contact information provided above.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Roost is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Roost may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Roost commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Roost at:
Data Protection Officer
1250 Borregas Ave.
Sunnyvale, CA 94089 USA
Roost has further committed to refer unresolved Privacy Shield complaints to JAMS an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.
Under certain conditions, more fully described on the www.privacyshield.gov/welcome, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
4 Types of Data We Collect. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, 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. We collect Personal Data and Anonymous Data, as described below.
We collect Personal Data and Anonymous Data from purchasers and owners of Roost Products who use the Products and Roost Services for their own properties ( “Roost Owners”).
Roost Owners may also invite other users that have registered with the Site and/or app to receive the information about the Roost Owners’ properties and monitor the Roost Owner’s Products through the App (“Monitors”). We collect Personal Data (such as name, email-address and phone number) from Monitors in order to register them on the App and/or Site.
We collect Personal Data and Anonymous Data that you provide to us directly, through your use of the Product, Sites, App and/or Roost Services as a Roost Owner and/or Monitor. We may also collect Personal Data or Anonymous Data automatically, through technologies used on the Product, Sites, App and in the Roost Services, as described below.
5 Information You Provide to Us.
Information We Collect through the Product and Roost Services Related to the Product.
We may collect the following information directly through each Product:
- Information about the Wi-Fi network to which the Product is connected. We may use this information to determine approximate location information for your Products.
- Information about your interactions with the Products, including when you test the Products, when you install or remove the Products and when you replace the Products.
- Information about when an alarm sounds on the smoke detector or carbon monoxide detector into which the Smart Battery was installed (“Device”).
- Information about when an alarm is silenced on a Device and the number of times an alarm is silenced on a Device.
- Humidity and temperature information about your properties and information about water leaks as collected by the Water Leak Detector installed on your properties.
- Information about the status and functionality of the Product during automatic maintenance checks.
- Location information to validate installation and removal or replacement of the Product.
Information We Collect through the App and Roost Services Related to the App.
We may collect the following information that Roost Owners and, in some cases Monitors, provide to us:
For Roost Owners and Monitors:
- We collect Personal Data from you when you register for an account to use the Roost Services as a Roost Owner or Monitor through the App (“Account“). To establish your Account, we collect your mobile phone number(s), email information and the SMS access code that we provide to you during set-up.
- We collect additional Personal Data when you create a Roost Account profile (“Profile”). To establish your Profile, we may collect your first and last name, e-mail address, address, phone number(s) and password.
- When you use the Roost Services on your mobile device through our App, we may collect your phone number and the unique device ID number.
- When connecting to the Roost Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
- We collect geolocation information, as described below.
For Roost Owners Only:
- We collect information about the Wi-Fi network to which you connect the Product, including the name of the Wi-Fi network and Wi-Fi network password. We may use this information to determine approximate location information for your Products.
- We collect information about the Devices into which you’ve installed the Products, including type of Device and the location of each Device within your home or building (e.g., kitchen, hallway), the address of your home or building in which the Device or Product is located and the settings that you specify for each Device or Product.
- Upon your request and with your consent, we access your contacts list in your mobile device and obtain information about your contacts to enable you to select and send invitations to Monitors.
- We collect the names and phone numbers of each of your invited Monitors and the Devices to which each Monitor has been granted access by you.
- We collect the name and phone number for your designated emergency contact.
Information We Collect through the Sites.
We collect the following information from all users of the Sites:
- When you sign up for e-mail notifications, we collect your first and last name and e-mail address.
- When you order a Product through our Sites, we collect your name, phone number, shipping address and e-mail address as well as your payment information to complete your order.
Information We Collect from all users through the Sites or the App.
We collect the following information from all users of the App or Sites:
(a) Personal Data. When you participate in one of our surveys, we may collect additional Personal Data to complete the survey. If you contact us for support regarding the Roost Services, we may collect your name, e-mail address, phone number, as well as your operating system and version, and any communications or correspondence that you send us.
Please note that at all times you are responsible for updating your Personal Data to provide us with your most current contact information, including e-mail address.
(b) Location Information. If you have enabled location services on your mobile device, we will collect geolocation information from Roost Owners and Monitors to determine proximity to a Device in the event of an alarm sounded by that Device. We collect location information from Roost Owners to enable Roost Owners to silence an alarm sounded by a Device. We will only share this information with our mapping provider for the sole purpose of providing you this service.
If you do not want to provide us with your location information, you can deactivate geolocation services on your mobile device.
(c) Information We Receive from Third Parties. We may receive Personal and/or Anonymous Data about you from third party sources, including but not limited to companies that offer their products and/or services on our Site. These third party companies may supply us with Personal Data. We may add this information to the information we have already collected from you and other users via our Site, App or Products in order to improve the services we provide and for purposes of data analytics.
(d) Information for Referrals to the Roost Services. If you choose to invite a friend to use the Roost Services, we will ask you for your friend’s name and mobile number. We will automatically send your friend an invitation text suggesting that your friend visit the Sites and sign up for the Roost Services. Roost stores this information for the sole purpose of sending these invitation texts and tracking the success of our referral program. Your friend may contact us at the contact information listed above to request that we remove this information from our database.
(e) Information Collected Automatically via Technology. Technologies such as cookies may be used by Roost and our partners, affiliates or analytics or service providers. Cookies are small data files stored on the hard drive of your computer or mobile device or website. We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits our Sites; and (2) third party cookies, which are served by service providers on our Sites, and can be used by such service providers to recognize your computer or mobile device when it visits other websites. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.
- Information Collected by Our Servers . To make our Sites and Roost Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer to you, improve marketing and site functionality.
We use this information to analyze trends, administer the Sites, track users’ movements around the Sites, gather demographic information about our user base as a whole, and better tailor our Roost Services to our users’ needs. For example, some of the information may be collected so that when you visit the Sites or the Roost Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.
- Mobile Services . We may also collect non-personal information from your mobile device if you have downloaded our App. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the App, and information about the type of device you use. In addition, in the event our App crash on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our App. We send you push notifications or SMS notifications from time-to-time in order to provide you with Product alerts, such as notifications of water leaks, and update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you may turn them off at the device level or by updating your settings. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.
(f) Third Party Analytics and Tracking.
- How We Respond to Do Not Track Signals . We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Website.
For more information on Google’s privacy practices, please click here: https://www.google.com/intl/en/analytics/learn/privacy.html.
For information about how to opt out of Google Analytics, please click here: https://tools.google.com/dlpage/gaoptout.
6 Use of Your Personal Data
(a) General Use. We use your Personal Data in the following ways:
- To provide you with the Roost Services you request;
- To facilitate the creation and administration of your Account and Profile;
- To send an access code to your mobile device via SMS during the registration process;
- To send you a welcome e-mail;
- To identify you as a user in our system;
- To respond to your inquiries or customer service requests;
- To display the alarm, water leak and activity history and Product status related to each Product for which you are a Roost Owner or Monitor;
- To enable Roost Owners to silence an alarm sounded by a Device;
- To enable Roost Owners and Monitors to receive notifications sent from the Water Leak Detector or Smoke Alarm;
- To enable Roost Owners to select, invite and manage Monitors for a Product;
- To display a Roost Owner’s Monitors for each Product and connect Roost Owners with their Monitors;
- To enable Roost Owners to contact emergency services through the App;
- To determine the proximity of Roost Owners and Monitors to a Device or Product in the event an alarm is sounded by the Device or a notification is sent out by the Water Leak Detector for response purposes;
- To provide improved administration of our Sites, App and the Roost Services;
- To improve the quality of your experience when you interact with our Sites, App and Roost Services;
- To share data collected from you through the App, Site or Products with your insurance companies, solely with your express consent;
- To analyze the data collected from the Products and personal data provided by users to develop insights, trends and probability statistics for the improvement and development of our Products and Services and to share these insights and trends with third parties in an aggregated, non-personally identifiable form;
- To send you administrative e-mail notifications, such as security or support and maintenance advisories;
- To send you reminders and notifications related to the Roost Services;
- To send you newsletters, surveys, offers, and other promotional materials related to the Roost Services and for other marketing purposes of Roost; and
(b) User Testimonials and Feedback About Your Use of the Roost Services. We often receive testimonials and comments from users who have had positive experiences with our Roost Services. We may post user feedback on the Sites from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
(c) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Roost Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.
7 Data Integrity.
Roost will use Personal Data only in ways that are compatible with the purpose for which it was collected or subsequently authorized by you. Roost will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. Roost depends on you to update and correct your Personal Data to the extent necessary for the purposes for which it was collected and subsequently authorized by you.
- 8 Disclosure of Your Personal Data.
(a) Monitors. We will share Personal Data about Roost Owners with the Monitors that the Roost Owners have selected for each Device and/or Product.
(b) Roost Owners. We will share Personal Data about Monitors with the Roost Owners who invited them to act as Monitors for particular Devices and/or Products.
(c) Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Roost Services; facilitate online shopping and process payments for Products; conduct quality assurance testing; facilitate creation of Accounts; provide technical support; and/or provide other services to Roost. These third party service providers are required not to use your Personal Data other than to provide the services requested by Roost.
If you do not want us to share your personal information with these companies, you may contact us at: email@example.com.
(d) Third Party Advertisers. We may share personal data with advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
9 Disclosure to Insurance Companies.
Solely with your express consent, we may share your Personal Data and data collected from the Products installed in your properties, with your insurance providers. We may also collect Personal Data from your insurance provider about you (such as insurance claims information), and combine it with the data we collected from you in order to develop insights, trends and probability statistics for the improvement of our services and to use and share these insights and trends with third parties in an aggregated, non-personally identifiable form.
10 Third Party Websites.
11 Your Choices Regarding Information. You have several choices regarding the use of information on our Roost Services:
- If you decide that you no longer wish to accept cookies from the Roost Services for any of the purposes described above, you can change your browser’s settings, if your browser permits, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Roost Services or all functionality of the Roost Services. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided above.
- Accessing, Changing or Deleting Your Personal Data. Upon request Roost will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. You may change, correct, or update any of your Personal Data in your Account by editing your profile within your Account or by contacting us directly using the contact information above. You may request deletion of your Personal Data by contacting us directly using the contact information above, and we will use commercially reasonable efforts to honor your request. We will respond to your request within a reasonable timeframe. Please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
(d) Applications. You can stop all collection of information by the App by uninstalling the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. To serve ads in our App where cookie technology is not available, Roost hashes users’ device IDs. Users may choose to reset or opt out of anonymous IDs at any time. If users choose to opt out, ads delivered to the App by ad serving technology will not be served on an anonymous ID. You may at any time opt-out from further allowing us to have access to your location data by disabling location services in your smartphone settings.
12 Third Party Shopping and Payment Processor. For online orders and payments, we use the services of Shopify (https://www.shopify.com). Roost does not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://www.shopify.com/legal/privacy.
14 Data Retention. We will only retain your personal data for the period your account is active (until you delete your account) unless a longer retention period is required or permitted by law.
15 Sensitive Personal Data. We ask that you not send us, and you not disclose, any sensitive personal data (e.g. social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Roost Services or otherwise to us.
17 Your Rights.
- Opt-out. You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) any new processing of your personal data that we may carry out beyond the original purpose; or (iii) the transfer of your personal data outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out.
- You may access the information we hold about you at any time by contacting us directly.
- You can also contact us to update or correct any inaccuracies in your personal data.
- Your data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
- Erase and forget. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you can request that we erase your data
If you wish to exercise any of these rights, please contact us at firstname.lastname@example.org. In your request, please make clear: (i) what personal data is concerned; and (ii) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.