Updated February 2022

1. INTRODUCTION

Rocky Mountain Smart Solutions Ltd. ("RMSS") also doing business as SimpleSensor takes your privacy seriously. We believe in protecting your information as well as your person and belongings. The purpose of this Privacy Policy is to describe how RMSS collects, uses and shares information about our customers, whether obtained through our call center or online interfaces (e.g., website and mobile applications) owned and controlled by us, including www.simplesensor.io and www.rockymountainsmart.com (collectively referred to herein as the “Site”). Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us at info@rockymountainsmart.com

Scope; Third Party Sites

This Privacy Policy applies only to information we collect at and through the Site. Our Site may also contains links to third party sites that are not owned or controlled by RMSS. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of any website that collects personal information.

Additional Terms

Please reference our Terms of Sale which apply to your purchase of our products. Please also note that use of our Site is subject to the Website Terms of Use. Moreover, if you subscribe to RMSS’s monitoring services or activate service offerings made available in connection with a RMSS product that do not require a monitoring subscription, use of those services are also subject to the Terms of Service.

RMSS collects certain information to enable you to take full advantage of our offerings when you register at our Site, order products or services either through the Site or through our call center, communicate with customer service representatives, participate in our contests, surveys, promotions, or activities, or otherwise communicate with us. If you choose, you can visit the Site without providing us with any information about yourself.

We seek to limit the collection and use of customer information required to deliver service to our customers, which includes advising our customers about our products, services and other opportunities, for advertising, and to administer our business.

Personal Information You Provide Us When You Become a Customer

• Name

• Address

• Billing address

• Shipping address

• Email address

• Telephone number

• Demographic information about you

• Credit card, debit card and bank account numbers (solely for payment purposes)

Personal Information You Provide When You Subscribe to Monitoring Service:

Types of personal information we collect when you become a subscriber to monitoring services and you provide it to us include:

• Information such as your log-in credentials used to verify your identity if you forget your log in credentials for your RMSS account

• Email address

• Telephone number

• Demographic information about you

• Information such as your activity stored in your online account.

Personal Information Collected through the Device

When you enable the internet or app features of your RMSS products, we may record, store, and process data, info from the device, depending on how you configure the device. This may include capturing and making available to you portions of the recording data as part of a notification or analysis of the data to identify motion or other events.

Non-personally Identifiable Information We Collect Automatically

As is true with most websites, we collect certain non-personally identifiable information automatically as you use our Site, such as:

• IP address

• Browser type

• Computer or device type

• Unique device identifiers for mobile devices or tablets

• Operating system version

• The website from where you navigated to our Site

• Time and date of using, accessing, or otherwise interacting with our Site

• The pages on our Site that you view

• The name of your Internet service provider (ISP)

Non-personally Identifiable Information Collected Through Cookies and Analytics Partners

We use analytics partners to collect certain non-personally identifiable information about how our Site is used. We and our analytics providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you. (See, “Advertising” below.)

By using this Site, you consent to the processing of data about you by our analytics partners in the manner and for the purposes set out above. Currently, our analytics partners include, without limitation, Google Analytics. In order to make sure you understand how our analytics partners handle your non-personally identifiable information and how they interact with our Site, you should visit the pages linked below for more information, as RMSS has no ability to control or monitor our analytics partners’ data collection or data use practices with respect to such information. Google Analytics uses cookies to help us understand how visitors use our Site and to compile reports on website activity. For more information regarding Google Analytics please visit http://www.google.com/analytics/terms/us.html. For information on how to opt-out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout/.

RMSS Product or Account Interaction with Third Parties

If RMSS offers any product or account connections or integrations with third-party products, applications, functionality, or services (collectively, “Third-Party Products and Services”), and you choose to enable or connect to such Third-Party Products and Services through the means authorized and directed by RMSS and/or such third-party partners, you acknowledge and agree that we may share certain information about you with such third parties for account authentication and management, and to enable the activation, connection and integration with and to such Third-Party Products and Services on such third parties’ platforms. For example, when you elect to use Third- Party Products and Services, such as RMSS’s Amazon Alexa Skill, Apple Watch or Google Assistant (as and when each is introduced), you agree that we may provide certain data about you to such partners in order to enable the activation, connection and integration with and to such Third-Party Products and Services you intend to use or otherwise choose to activate. In some cases, RMSS or the third-party partner will instead (or also) ask for permission to control the RMSS products and services and/or Third-Party Products and Services that you have activated and connected to as

contemplated hereunder. Your consent is required to allow any of these exchanges or requests for control and you will be able to revoke or disable it at any time.

In addition, RMSS may share information with such third-party partners with your permission. For example, when you enroll or activate Third-Party Products and Services, you may be asked for your permission to share certain data between RMSS and our partner. RMSS requires your consent before sharing information in these circumstances. We may also receive information from our partners and other sources and combine that with the information in your RMSS account to determine eligibility and efficacy of our programs.

Additional information about the limited circumstances in which information from your RMSS account may be shared with third parties is described below in the section titled "How we Use and Share Your Information".

Any RMSS data that you choose to share with a third party, either directly or by or on behalf of RMSS through the authorizations, integrations and connections permitted hereunder, is governed by that third party<’s privacy policy while in that party’s possession.

Any data that RMSS receives from third parties will be processed and stored by RMSS and will be treated in accordance with this Privacy Policy. This information may be processed in the same ways as any other data that is a part of your RMSS account.

No Information From Children or Teens Under Age 18

This Site is not directed to, and we do not knowingly collect any personal information from, children or teenagers under the age of 18. If you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If you are under the age of 18, you may only use this Site under the supervision of your parents or guardians.

Third-Party Sites and Social Media

Our Site may contain links to other websites operated by third parties and may include social media features such as Facebook, Twitter and Pinterest buttons or links. These third-party sites may collect information about you if you click on a link and the social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button. Your interactions with these features are governed by the privacy policy of the company providing the link, not this privacy policy.

Third Parties

We collect information from third parties, such as service providers that we use, analytics companies, and advertising and marketing partners.

To Provide Products, Services, and Information

As described above, we collect information from you so that we can provide products and services that you purchase from us, and to provide information that you request from us. This includes sending you alerts and important service information about your device and our services. We use your personal information to contact you about your orders, process credit card / debit card transactions, and ship our products to you. We may send you information about our products and services, and new offerings. We may provide information to third party service providers that help us process orders and fulfill and deliver products and services that you purchase from us. You may opt out of receiving future communications (with the exception of alerts and service information) from us by logging into your account and editing your profile. You may also opt out of receiving commercial e-mail from us by following the instructions in each e-mail. To ensure reliability and improve your experience with our mobile app, we share information with Google or Apple or relevant app providers to measure your in-app experience and improve its usability, speed, and reliability; only non-personally identifiable information is shared.

If you subscribe for enhanced services, or make other purchases through the Site, your credit card or debit card information (such as card type and expiration date) and other financial data that we need to process your payment may be collected and stored by the payment processors with which we work. We may also collect some limited information, such as your postal code, mobile number, and details of your transaction history, all of which are necessary to provide the monitoring services or products. In addition, the payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve stored, including recurring payments if you become a subscriber, and your card’s type, expiration date, and certain digits of your card number.

We use third parties to assist with providing our products and services to you (including our monitoring services and dispatching emergency responders), host our Site, send out email updates about the Site, provide marketing and advertising services for us, remove repetitive information from our user lists, and process payments. These service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to help us provide the service. We also employ strong security and technological controls and provisions to protect against unauthorized RMSS employee access to the audio and video data collected from your security camera or other camera-enabled products.

other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our Site or third-party sites not owned by RMSS. The foregoing does not apply to information obtained via short code messaging.

We belong to ad networks that may use your browsing history across participating websites to show you interest-based advertisements on those websites. Our Site does not respond to “do not track” signals or similar mechanisms to indicate you do not wish to be tracked or receive interest-based ads. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).

Your Consent

Except as otherwise provided in this Policy, we will share personal information with companies, organizations or individuals outside of RMSS when we have your consent to do so.

Legal Proceedings

We will share personal information with third party companies, organizations or individuals outside of RMSS if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or governmental request.

• Enforce applicable Terms of Sale and Terms of Service, including investigation of potential violations.

• Detect, prevent, or otherwise address fraud, security or technical issues.

• Protect against harm to the rights, property or safety of RMSS, our users,

  customers or the public as required or permitted by law.

• Under certain circumstances, we may be required to disclose your personal

  information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Transfer in the Event of Sale or Change of Control

If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted or otherwise directed by applicable law, your information would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer.

You can access and update certain information we have relating to your online account by logging into your online account and visiting the “monitoring” section to update contact information for your device. Under the “log in” section you can update your email address and password. If you have questions about personal information we have about you can contact us at info@rockymountainsmart.com You can opt-out of receiving marketing and promotional e-mails from RMSS by using the opt-out or unsubscribe feature contained in the e-mails.

You can close your online account by calling emailing us at info@rockymountainsmart.com If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information for a period of time reasonably necessary for archival purposes, and to avoid identity theft or fraud.

We use commercially reasonable physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice as we deem appropriate. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please email us at info@rockymountainsmart.com or contact us by US postal mail at the following address: RMSS, 3577 Xanthia St., Denver, CO 80238

Attention: Privacy Policy Feedback

Effective: January 1, 2020 CALIFORNIA RESIDENTS

If you are a resident of California, this California privacy notice applies to you and supplements RMSS’s main Privacy Policy. This California privacy notice is intended to provide certain additional information to you as required by the California Consumer Privacy Act of 2018 (“CCPA”).

“Personal information” as used in this California privacy notice applies to information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household such as your real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Personal information does not include publicly-available information and certain other information that is regulated by other applicable laws.

We do not sell or monetize our users’ personal information in the traditional sense (i.e., get paid to share your personal information). However, the CCPA defines the term “sale” very broadly, and it likely includes the sharing of personal information with third parties.

Your Rights

Right to Know

You have the right to request that we provide certain information to you about our collection of your personal information. Such information shall cover the 12-month period preceding our receipt of your request. Upon our receipt of your verified request, we will provide you with the following:

• The categories of personal information we have collected about you

• The categories of sources from which we have collected your personal

  information

• Our business or commercial purpose(s) for collecting or selling your personal

  information

• The categories of third parties with whom we have shared your personal

  information; and

• The specific pieces of personal information we have collected about you

• The categories of personal information we have collected from you

• The categories of personal information we have sold about you and the

  categories of third parties to whom we sold such information, by category or categories of personal information for each category of third parties to whom the personal information was sold; and

• The categories of personal information that we disclosed about you for a business purpose

You may only make a verifiable “Right to Know” request twice within a 12-month period.

Right to Opt-Out

We never monetize your personal information, however, we may share it with certain strategic partners, social media partners, advertising partners and networks, and other third parties that provide offers we think may be of value to you as discussed below, which could be considered a “sale” under the CCPA. You have the right at any time to opt-out of this sharing and the potential sale of your personal information by clicking here.

Right to Delete

You have the right at any time to request that we delete your personal information. However, in some cases we cannot delete all or some of your personal information as required or permitted by applicable laws.

Right to Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA, such as by denying you products and services, charging you different rates or prices, including use of discounts or penalties, or suggesting or providing a different level of service or quality of products to you. However, we may charge a different price or provide a different level or quality of products and services if the price or difference is directly related to the value provided to you by your personal information.

We may from time to time offer you financial incentives, including payments to you as compensation, for collecting, selling, or deleting your personal information. We also may offer a different price, rate, level, or quality of goods or services to the consumer if that price or difference is directly related to the value provided to you by your personal information.

Contact

To submit a request to exercise your “Right to Know” or “Right to Delete” rights provided in this California privacy notice, please email info@rockymountainsmart.com to submit your request. We will evaluate the request and take action where required to do so. If you have a RMSS account, we may direct you to your account in order to fulfill your request where applicable.

Depending on the nature of your request, we may have to verify your identity when you contact us. We may do this by asking you to:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized agent.

• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you.

We endeavor to respond to your request as soon as we can. If we are not able to respond to your request within 45 days, we will let you know that we may require additional time (up to 90 total days).

You may also use an authorized agent to exercise your rights on your behalf. If you wish to use an authorized agent, we require that your authorized agent provide written proof to us that he or she is authorized to act on your behalf, and we may also require your authorized agent to verify his or her own identity. To appoint an authorized agent, please email info@rockymountainsmart.com to submit your request (for Right to Know or Right to Delete requests)

Information We Collect

If You are a Visitor to Our Website or Interact With Us:

• Geolocation data (such as your approximate location based on IP address)

• Inferences (such as creating a profile about your preferences based on your interaction with us and our website)

• Identifiers (such as your login credentials and information about your household. We additionally may collect contact information of users’ family and friends for notification purposes)

• Commercial information (such as your purchase history and information about your product usage)

• Protected classification characteristics (if you respond to our optional customer surveys, we may ask about information such as your ethnicity)

• Financial Information (such as your payment information when you make a purchase)

• Internet or other electronic network activity (such as information about your and your devices’ interaction with our network, your interaction with our website, your visitor identification number, and your product usage)

• Audio, visual, and similar information (if you use our security cameras or other camera-enabled products, we collect information such as audio and video recordings from such devices)

• Inferences (such as a profile based on information reflecting your activity and preferences)

• Our sources for this information:

• We receive this information directly from you when you purchase, setup and use our products and services, and when you communicate with us

• We sometimes combine information that you voluntarily provide to us with information that we automatically collect when you visit our websites or interact with our products and services

• Our business purposes for collecting this information:

• To deliver our products and services to you

• To send you alerts and important service information about your device

  and our services

• To communicate with you about your orders and purchases

• To send you updates about new products and to suggest products and

  services to you that we think you may be interested in

• To provide services to you, if you enable them

• To detect, prevent or otherwise address fraud, security or technical issues

• To operate and improve our business, products and services, website,

  and mobile applications

• Third parties we disclose this information to:

• If you choose to enable account connections or integrations with third- party products such as RMSS’s Amazon Alexa Skill, Apple Watch or Google Assistant, we may share your information with such third-party products. This is only done with your consent, and you can revoke or disable these connections and integrations at any time

• If you subscribe to our monitoring or emergency dispatch services, we disclose your information to third parties to facilitate those services

• Third parties that conduct research surveys, focus groups, and promote contests

• If you request setup assistance, we disclose your information to third parties to assist you with setup services

• In addition to the above, if you are a California resident, then in the last twelve (12) months, we may have collected the following categories of personal information:

• Identifiers (such as your name, email, household information and other identifying characteristics)

• Our sources for this information:

• We receive this information from analytics partners and advertising and marketing companies.

• Our business purposes for collecting this information:

• For advertising and marketing purposes

• For analytics purposes

• To operate and improve our business, products and services,

  website, and mobile applications

• Third parties we disclose this information to: Our service providers, such as our backend hosting provider

Note that in addition to what is disclosed above, we may share your personal information with our service providers in order to operate and deliver our products and services, operate our website, and help us in other areas of our business.

RMSS complies with the EU-U.S. Privacy Shield Framework (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield. RMSS has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such information. While RMSS does not rely on the Privacy Shield principles as the legal basis for the transfer of personal information from the United Kingdom or the European Union, RMSS is committed to protecting personal information from the United Kingdom and European Union in compliance with those principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with Privacy Shield’s principles, RMSS commits to resolve complaints about your privacy and our collection or use of your information transferred to the United States pursuant to Privacy Shield. You may have the right to access the personal information that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. United Kingdom and

European Union individuals with privacy inquiries or complaints should first contact us by email in the United States at info@rockymountainsmartsolutions.com We will work to resolve your issue and will respond within 45 days of receipt of your inquiry. For purposes of compliance with Privacy Shield, RMSS is subject to the investigatory and enforcement authority of the US Federal Trade Commission. In addition, when transferring information to third-parties in accordance with the Privacy Shield, in certain circumstances RMSS may remain liable for the acts of our third-party agents, resellers, licensees, or service providers who perform services on our behalf or on behalf of our customers for their handling of such personal information.

RMSS has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact JAMS or visit the JAMS website for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If, however, you believe that we have not been able to assist with your complaint or concern through the above options, and you are located in the European Union or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority.

If your Privacy Shield complaint cannot be resolved through the above channels, you may have the option to select binding arbitration for the resolution of your complaint under certain circumstances. For more information on binding arbitration, see the US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration) https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

RMSS commits to cooperate with applicable data protection authorities and comply with advice given by such authorities with respect to human resources data transferred from the European Union or the United Kingdom in the context of any employment relationship with a European Union or United Kingdom individual.