PRIVACY POLICY

Overview:

  • FiLIP is since late-2016 part of SMARTCOM SAS. With headquarters in Sophia Antipolis, France and Alpharetta (GA), USA. All data is safely hosted by Amazon Web Services (‘AWS’) within two (2) regions: North Virginia (us-east-1) and Ireland (eu-west-1).
  • FiLIP provides a service to help primary caregivers to communicate with, monitor, track and locate their children. This is data-driven service.
  • This service will automatically collect the physical location from the device at all times when activated. FiLIP also receives data about device and application usage..
  • FiLIP will use this information to provide the location-based services and to contact the parents/guardians regarding the service and other information.

By using the FiLIP Service, you expressly consent to the collection and use of information as described in our full Privacy Policy below:

Last updated: June, 2018 – GDPR/COPPA Compliance

FiLIP from Smartcom SAS  (“FiLIP”) provides the website, online service and mobile application (the “FiLIP App”) and supports FiLIP App’s paired/associated mobile device (the “ Device”, collectively the “FiLIP Service”). We have prepared this Privacy Policy so that you understand how data will be collected and used in connection with the FiLIP Service.

IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, YOU MAY NOT ACCESS OR OTHERWISE USE THE FILIP SERVICE.

Personal information collected through the FiLIP App: Through the FiLIP App we may collect your name, email address, date of birth, billing information and other personal information, as well as that of the child who will use the Device associated. We do not collect personal information from you unless you voluntarily provide it to us.

Location-based information collected through the FiLIP Service: FiLIP’s paired Family Wearable Devices automatically and constantly collects information about the physical location of the Device when it is activated. This information is acquired through numerous methods, including GPS, cell towers and wi-fi hotspots, which are enhanced over time as we follow the Device, collect more information and improve our tracking. You may not disable location-based data collection from the Device. We may also collect such location-based information through your use of the FiLIP App.

Calls/audio collected through the FiLIP Service: In the event of an emergency call placed from the Device, Network Provider may record the audio of the conversation between the Device and the recipient of such call. Please refer to Provider’s Privacy Policy. Through FiLIP App’s messaging tool, we store texts and recorded voice messages. Accessible through our Cloud Service. You are able to access and delete this data whenever necessary. At FiLIP we are not responsible for lost data. This data, considered as private, is and will never be shared to Third Parties of any sort.

Non-personal or aggregate information that we collect: We automatically collect non-personal information from your use of the FiLIP Service, such as IP host address, device-specific identifiers, computer or smartphone configurations, pages viewed, time and usage habits on the FiLIP Service and similar data. It is possible at times when collecting non-personal information through automatic means that we may unintentionally collect or receive personal information that is mixed in with the non-personal information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If we do inadvertently collect personal information, we will not intentionally use such personal information as if we had collected it with your consent. We may also aggregate demographic information collected from our users (such as the number of users in a particular State) in a manner which does not identify any one individual.

Information Usage and Third Party Sharing: We will only use your information in a manner consistent with this Privacy Policy, unless you have specifically consented to another type of use, either at the time such information is collected or through other form of consent from you or notification to you. Personal information and location-based information is treated as sensitive information by FiLIP and are subject to a heightened standard for sharing, as opposed to non-personal or de-identified information which may be shared with a limited selected number of parties. Preferably the Network Provider or Wholesaler if our service is offered through them (e.g. AT&T, Telefonica, Ucom, etc.).

Therefore, we may use your information to:

  • respond to your inquiries or requests;
  • send you information about the FiLIP Service (such as promotions, maintenance or security information);
  • send you a limited number of offers for additional products and services that may interest you, but we will not provide your personal information to third parties for them to contact you directly for their own benefit without your consent;
  • permit our vendors and subcontractors to perform services, provided they are under an obligation of confidentiality and do not use the information for their own benefit;
  • comply with applicable law or legal process;
  • provide to a third party for their own use, such as marketing, but only if you have specifically opted-in to such third party sharing (ref. GDPR, COPPA, CPIAPP, etc.);
  • investigate suspected fraud, harassment, danger to persons or property or other violations of any law, rule or regulation, or the terms or policies for the FiLIP Service or our business partners;
  • share with law enforcement and other parties trying to locate a lost child, including sharing the audio content of emergency calls;
  • transfer information in connection with the sale or merger or change of control of FiLIP or the division responsible for the services with which your information is associated;
  • share non-personal or de-identified information with any number of parties, including analytics companies, technology providers, and other business partners; or
  • combine it with data from other sources outside of your use of the FiLIP Service, such as data obtained from wi-fi access points within range of your Device.

Auto-deletion of data: We may automatically delete data from a Device or from the FiLIP App in connection with a returned or terminated account or device, or as necessary to protect against unauthorized access to the data.

Cookies: “Cookies” are pieces of information that may be placed on your device by a service for the purpose of facilitating and enhancing your communication and interaction with that service. To the extent possible depending upon your device, we may use cookies (and similar items such as clear gifs, web beacons, tags, etc…) to customize your experience, to make your visit more convenient or to enable us to enhance the FiLIP Service. We may also use and place cookies on your device from our third party service providers in connection with the FiLIP Service, such as an analytics provider that helps us manage and analyze FiLIP Service usage. You may stop or restrict the placement of cookies on certain devices or flush them from your browser by adjusting your web browser preferences, in which case you may still use our FiLIP Service, but it may interfere with some of its functionality. Cookies and similar items are not used by us to automatically retrieve personal information from your device without your knowledge. Cookies are device and browser specific, so if you make a change to your environment we may reinstall a cookie.

Security: The security of your information is very important to us. We use reasonable efforts internally at FiLIP to protect it from unauthorized access. However, due to the inherent open nature of the Internet and wireless communications, we cannot guarantee that your personal information will be completely free from unauthorized access by third parties, such when transferred over or through systems not within our exclusive control. Your use of our FiLIP Service demonstrates your assumption of this risk. We have put in place reasonable physical, electronic, and managerial procedures to safeguard the information we collect. Only those employees who need access to your information in order to perform their duties are authorized to have access to your personal information. For more information on protecting your privacy, please visit www.ftc.gov/privacy for US customers For EU, please visit www.eugdpr.org.

Personal information from children: While some ofFiLIP’s associated Family Wearable Devices (“Device”) are designed to be worn by a child, our customer is the applicable parent/guardian or other adult over 18 years of age who has enabled the FiLIP Service. By providing the Device to a child, you represent and warrant to FiLIP that you are authorized by such child’s parent or guardian to enable and permit FiLIP to operate the FiLIP Service and collect and use the information from the child as stated herein.

Data retention: We may retain your information for as long as we feel that there is a business need or benefit to do so. This will include retaining location-based information.

Data Access: FiLIP Data collected through use of the Device and/or the FiLIP App, including location information, frequency of use and emergency contact information is generally not available to customers for their own, direct access. Please contact contact@smartcom.com for specific questions about access to any collected data.

Other services: As a convenience to you, Network Providers may provide links to third party services from within our FiLIP Service. We are not responsible for the privacy practices or content of these third party services and such links should not be construed as an endorsement of any such third party services. When you link away from our FiLIP Service, you do so at your own risk.

Changes to this Privacy Policy: We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time. However, if at any time in the future we plan to use personal information or location-based data in a way that materially differs from this Privacy Policy, such as sharing such information with more third parties, we will post such changes here and provide you the opportunity to opt-out of such differing uses. Your continued use of the FiLIP Service following the posting of any changes to this Privacy Policy means you accept such changes.

Opt-Out Process: You may unsubscribe from our marketing messages. All unsubscribe or opt-out requests should be sent to us at contact@smartcom.com and we will process your request within a reasonable time after receipt. However, we are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy or your consent, such as a sponsor. You should contact such third parties directly.

If you no longer want any data collected by FiLIP from the Device, then you will need to deactivate the service.

FiLIP Terms of Service: Use of the FiLIP Service is governed by, and subject to, the Terms of Service. This Privacy Policy is incorporated into such terms.

United States of America: Our servers are maintained in the United States of America. By using the FiLIP Service, you freely and specifically give us your consent to export your personal information to the USA and to store and use it in the USA as specified in this Privacy Policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA: Children’s Online Privacy Protection Rule (‘COPPA’)

Europe: Our servers are maintained in Dublin, Europe. By using the FiLIP Service, you freely and specifically give us your consent to export your personal information to Dublin and to store and use it as specified in this Privacy Policy. You understand that data stored in Dublin may be subject to lawful requests by the courts or law enforcement authorities of the European Commission: General Data Protection Regulation(‘GDPR’).Contact: For questions or concerns relating to privacy, we can be contacted at: contact@smartcom.com.

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