California Resident Privacy Notice
Last reviewed and updated: February 13, 2020
1. Personal Information, Collection, Disclosure, and Sale
For the purposes of this notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
Personal Information does not include information that is:
- Lawfully made available from government records.
- Deidentified or aggregated.
- Otherwise excluded from the scope of the CCPA.
The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or used for business or commercial purposes in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.
|Category||We Collect||We Disclose||We Sell|
Examples: Name, billing and delivery address, unique personal identifier, online identifier, internet protocol address, email address, or other similar identifiers.
|B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)|
Examples: Name, address, telephone number, employment, employment history, bank account number, credit or debit card number, or other financial information.
|C. Characteristics of Protected Classifications under California or Federal Law|
Examples: Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender), sexual orientation, medical condition, genetic information, marital status, or military or veteran status.
|D. Commercial Information|
Examples: Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
|E. Biometric Information|
Examples: Physiological, biological, or behavioral characteristics that can be used to establish individual identity from which an identifier template, such as a faceprint, minutiae template, or voiceprint, can be extracted, or identifying keystroke, gait, sleep, health, or exercise information.
|F. Internet or Other Electronic Network Activity Information|
Examples: Browsing history, search history, or information regarding a consumer’s interaction with an internet website, application or advertisement.
|G. Geolocation Data|
Examples: Precise physical location.
|H. Sensory Information|
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
|I. Professional or Employment-Related Information|
Examples: Job application or resume information, job history, or job performance information.
|J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)|
Examples: Student records maintained by an educational agency or institution or by a party acting for the agency or institution.
|K. Inferences Drawn from Personal Information|
Examples: Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
In the preceding twelve months, we have not sold any California resident’s Personal Information.
2. Use of Personal Information
We collect, use, and disclose your Personal Information in accordance with the business and commercial purposes below.
- To operate and provide you with our Services and fulfill our contract with you. For example, if you make a purchase from us or otherwise use our Services. This may include verifying your identity, taking payments, communicating with you, providing customer support, arranging the delivery or other provision of products and services, better identifying your devices to more accurately represent your devices in the Plume App, providing more accurate security threat identification, providing you with more visibility into your distributed network, providing reports that help you better understand your network bandwidth and the devices that are consuming network resources, scheduling network optimizations, firmware updates and internet freeze for your devices, presenting you with live motion visuals and motion history, providing you with visibility and control over time spent by users on various Internet applications, alerting you of malicious Internet locations or websites and content that has been identified as inappropriate in accordance with the content filters set by the Plume App user, preventing home devices from being hacked, app reporting and analytics, and identifying device behavior that may indicate an anomaly or attack.
- To make purchases from our store. If you pre-order or purchase Plume products from our website, we request that you provide your name, email address, billing and delivery address, credit card information and any other information necessary to complete the transaction. We store this information so we can process your order through our fulfillment partner. If you are logged into your Plume account when you purchase something on our Site, we associate that order with your Plume account. We do not view or store your credit card information: this is handled by our third-party payment processor – Stripe – who will collect and process your credit card details until the delivery of Plume’s product.
- To communicate and respond to your requests. In particular to provide you with our newsletter when you sign up and to send you news about our or third-party products, services and promotions. This may include providing updates and other information relating to our Services, providing information that you request, offering opportunities to participate in contests, giveaways and other promotions, responding to comments and questions, and otherwise providing customer support.
- Product Improvement. In particular to help us analyze, troubleshoot, protect, improve and further develop our Services and other products and services.
- Marketing. In particular to send you marketing messages about our or third-party products and services that may be useful, relevant, valuable or otherwise of interest to you.
- Personalization. In particular to tailor our Services to you.
- Research. For example, to invite you to take part in market research and testing of new features or products and to conduct these activities.
- Deidentification and Aggregation. In particular to de-identify data about your use of our Services to create statistical analysis and aggregated reports to identify trends.
- Fraud Prevention. We may use your Personal Information to prevent fraud (e.g., if you provide a credit or debit card, we may use third parties to check the validity of the sort code, account number and card number you submit).
- Safety Issues and Incident Prevention. We may monitor any customer account to prevent, detect, investigate and/or report security incidents, crime, fraud or misrepresentation, all in accordance with applicable law.
- Debugging. Debugging to identify and repair errors that impair existing intended functionality.
- Transient Use. Short-term, transient use.
- Contracting Vendors. Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Enabling Transactions. Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
- Notified Purpose. For other purposes for which we provide specific notice at the time the information is collected.
3. Collection of Personal Information
In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:
- You and your devices, including network access points running Plume software and end client devices connected to these network access points.
4. Disclosure of Personal Information
- With our affiliates and subsidiaries, such as Plume’s entities in the U.S., Poland, Slovenia, Switzerland and Taiwan.
- With vendors that we have selected to provide us with services and process some Personal Information on our behalf to operate our Services (e.g., internet speed testing, motion detection, order fulfillment, email management, payment processing, data analytics, etc.). These companies are contractually obligated to safeguard any Personal Information they receive from us.
- We may share Personal Information with third parties with your express, affirmative consent. For example, you may give us permission to share Personal Information with others for marketing uses, authorize a third-party web client or application to access your account, or ask us to share your feedback with a business.
- We may share Personal Information with data analytics providers.
- If you acquired your Plume product from your Internet service provider, we may share your Personal Information with that Internet service provider.
- We may share or transfer Personal Information as part of a business deal such as the financing, sale, merger, bankruptcy, sale of assets or reorganization of our company.
- We may share Personal Information with our business customers when we process it on their behalf.
- We may share Personal Information with other third parties for whom we have obtained your permission to disclose your Personal Information.
5. Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please authenticate your account by logging into your account to request that we clear your Plume data history or send you your Plume data logs.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.
Authorizing an Agent. To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via the Contact Information section.
6. Access this Notice in Alternative Formats
If you have a disability or would otherwise like to access this notice in an alternative format, please contact us via the Contact Information section.
7. Do Not Track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
8. Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at email@example.com, call us at 1-844-697-5863, or write to us at Plume Design, Inc., 290 South California Avenue, Suite 200, Palo Alto, CA 94306.