Last updated: November 8, 2018
This Policy applies to the Plume products and services, including our websites, apps, devices and other software or hardware that we may offer, collectively referred to as our "Services". It only applies to the activities for which Plume is a "data controller" which means that Plume decides why and how Personal Information is processed. We may also process Personal Information as a "data processor" when providing services to our business customers. In that context we process Personal Information on their behalf and they determine why and how the Personal Information is processed. To learn more about this processing of Personal Information, please refer to their respective privacy policies.
- Personal Information We Collect
- How We Use Personal Information
- How We Disclose Your Personal Information
- Data Retention
- Children’s Privacy
- Data Security
- Your Rights and Choices
- Cross-Border Data Transfers
- Changes to This Policy
- How to Contact Us
We collect Personal Information from various sources, which are described below. For the purpose of this Policy, "Personal Information" means any information relating to any identified or identifiable individual. Where applicable, we will indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide your Personal Information, when requested, you may not be able to benefit from our Services if that information is necessary to provide you with them or if we are legally required to collect it.
A. Personal Information Provided by You
When you create a Plume account
You must create a Plume account to set up your Plume network. When you create a Plume account, we ask for some Personal Information, including your name and email address. Your email address will be your Plume account user name, which you will need to use to log in to your account.
When you buy 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.
When you sign up for our newsletter
You may choose to submit your name and email address via a submission form located on our website. Your email address may be used to send you news about our or third party products, services and promotions. We may use one or more service providers to administer these messages, but we do not share your email address with any other third parties without your permission. Each marketing communication we send you will contain instructions permitting you to opt out of receiving future marketing communications.
When you contact us
Whenever you contact Plume for help, we collect your name and email address along with additional information you provide in your request so that we can verify your account, assist you and improve our Services. If you contact us for support when already logged in to your account, the request form or e-mail may contain pre-populated account information, so you don’t have to type it manually. You may also contact Plume on public forums such as Twitter or Facebook; note that your communications will be public if you contact us through these channels.
Contests and giveaways
Plume may offer opportunities to participate in contests, giveaways and other promotions. Any data you submit in connection with these activities will be treated in accordance with this Policy, unless the rules for those offers provide otherwise.
Surveys and beta tests
Plume may also ask you to participate in surveys (processed by Plume or third parties) that help us understand your use of our Services and beta tests we conduct to test a new product or service. Any Personal Information we collect in that context will only be used in relation to that survey or beta test and as stated in any privacy notice provided to you in that context.
B. Information Collected via Automated Means
When you use Plume Wi-Fi Services
To deliver the best Wi-Fi experience, we automatically collect some information when you use your Plume network such as:
- Information about your connected devices: This information includes the type of device you use, operating system version, user agent information, a sampling of DNS requests, device hostname, the nickname given to the device and the unique addresses of the device. This information is used to better identify the device to more accurately represent it in the Plume App and to provide more accurate security threat identification.
- Network and connectivity status: This information indicates the networking addresses of the device and system used to communicate with Plume and the Internet along with the operating statistics of the Wi-Fi and Internet connections.
- Your device and Plume data consumption from your devices, the Internet and Plume system interfaces. We collect this information including current and historical data transfer speeds and data amount consumed to understand your network bandwidth and the devices that are consuming network resources.
- Plume Services statistics: We collect certain information to help us create statistics and optimize our Services. Such information includes your ISP name and IP address, ISP speeds and outages, Wi-Fi operating environment, mobility of devices within Plume, and Plume App usage stats (e.g., number of features used or screen views). We also collect log information such as messages from the Plume pods regarding Plume connected devices, device inventory data, and software and hardware versions.
- Safety controls and security features: Safety controls and security features require the monitoring of device network traffic like source and destination traffic headers, IP addresses, ports and DNS requests. We use this information to protect home devices from contacting malicious Internet locations or websites and content that has been identified as inappropriate by Plume in accordance with the content filters set by the Plume App user, prevent them from being hacked, app reporting and analytics, and to identify device behavior that may indicate an anomaly or attack, when the security feature is On. The safety controls and security features can be turned Off for some or all home devices, which will turn off the data collection. If you are using the WiFi of someone while the safety controls and security features are On, note that the user of the Plume App may link the activity on your device to you, and see in the Plume App information about your use of the WiFi, such as whether your device is currently connected to the WiFi, since when it is connected, a blocked domain name that you tried to access, and the time when you tried to access it.
- Crash reports: We collect crash reports for both the Plume Software and the Plume App. These reports can include information such as the type of crash, the software version you are running and the OS version of the device running the Plume App.
When you visit our websites and apps or open our emails
Plume collects industry standard data from everyone who visits our websites and apps – even if you don’t have a Plume account. We and our third-party partners analyze log file information and other data collected through cookies, web beacons, and similar technologies. Cookies are small data files stored on your hard drive by a website. We use session cookies to keep you logged in while you use features of our website; these disappear after you close your browser. We also use persistent cookies, which stay in your browser and allow us to recognize you when you return to the website. In some of our email messages, we use a "click-through URL" linked to content on our website to help us measure the effectiveness of our customer communications. To learn more about cookies, clear gifs/web beacons and related technologies, visit www.allaboutcookies.org. In this Policy, we refer to "cookies" to say cookies and other similar technologies.
We collect certain information via cookies, including your browser type, operating system, domains, IP address, the URL of the page that referred you, referring/exit pages, the different actions you performed, such as page views, how you interact with our Services and with third-party links, traffic and usage trends. Below is an overview of the purposes for which we and third parties process this information.
- Functionality. Some cookies are strictly necessary to make our websites or apps available to you and you cannot use them without this type of cookie. For example, we use authentication cookies to remember that you have logged in for the duration of the session. We use this information to provide you with our Services, prevent misuse, and ensure our websites and apps are working properly.
- Website customization. We use information collected via cookies to make the Services more useful to you by providing you with a customized experience on our websites and apps (e.g., experience relevant to your location based on your IP address).
- Third-party content. Our website may contain links to other websites operated by third parties and may include social media features such as Facebook and Twitter buttons (such as "Like," "Tweet" or "Pin"). These third-party websites may collect information about you if you click on a link and the social media websites may automatically record information about your browsing behavior every time you visit a website that has a social media button. Your interactions with these features are governed by those third parties’ privacy policies, not by this Policy. We do not control what Personal Information these third parties collect. Please review your privacy settings on your social media websites and think carefully before clicking on links which may direct you to a third-party website.
To learn how to opt-out from cookies, please refer to the "your rights and choices" section below.
We process your Personal Information for the following purposes:
- 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 Services and arranging the delivery or other provision of products and services.
- To enable our business in accordance with our legitimate interests, in particular:
- we monitor use of our Services and may use your Personal Information to help us analyze, troubleshoot, protect, improve and further develop our Services and other products and services;
- we may send you marketing messages about our or third party products and services;
- we may use your Personal Information to tailor our Services to you;
- we may use your Personal Information to invite you to take part in market research and testing of new features or products and to conduct these activities;
- we may de-identify data about your use of our Services to create statistical analysis and aggregated reports to identify trends;
- 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); and
- With your consent, where appropriate or required by applicable law, such as for certain marketing activities and advertising practices.
We do not sell or otherwise disclose your Personal Information for purpose unrelated to the delivery of Plume products and services, unless otherwise described in this Policy. We may share your Personal Information under the following circumstances:
- With our affiliates and subsidiaries, such as Plume’s entities in the U.S., Poland, Slovenia, Switzerland and India.
- With vendors that provide us with services and process some Personal Information on our behalf (e.g., for order fulfillment, email management, payment processing, 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 consent. For example, you may let us 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 de-identify and aggregate your Personal Information to share it with partners and the public in a variety of ways, such as by providing research reports about Wi-Fi usage. When we provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from trying to re-identify you.
- 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 will notify you if a different company will receive your Personal Information and the promises in this Policy will apply to your data as transferred to the new entity.
We may also share Personal Information with our business customers when we process it on their behalf.
We take measures to retain your Personal Information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. Please note that we have a variety of obligations to retain your Personal Information, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help our service providers handle their obligations, and to comply with laws and regulations. Accordingly, we may retain your Personal Information even after you’ve closed your Plume Account to meet our obligations. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrolment with our Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations. For example, we keep information associated to customers who returned our products or canceled their subscription up to 13 months.
The U.S. Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. Plume’s services are not directed to children, and Plume does not knowingly collect information from children under the age of 13. If you learn that a child has provided us with Personal Information in violation of this Policy, then you may alert us at firstname.lastname@example.org.
Plume uses a combination of technical and administrative security controls to maintain the security of your Personal Information and protect it against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession. We use commercially reasonable physical, administrative, and technological methods to transmit your Personal Information securely including HTTPS, TLS protocol, AES and RSA data encryption. Your Personal Information is stored securely using Amazon’s S3 cloud Services. However, Plume cannot guarantee that unauthorized third parties will never be able to defeat our security measures and use your Personal Information for improper purposes. In the event that any information under our control is compromised as a result of data breach, we will take reasonable steps to investigate the situation and, where appropriate or required by law, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Depending on your country, you may have certain rights regarding the Personal Information we maintain about you and certain choices about what Personal Information we collect from you, how we use it, and how we communicate with you:
- Marketing opt out. You can opt-out of receiving regular summaries, contests, giveaways, surveys and promotional emails by following the instructions contained in our marketing communications. Opting-out of these emails will not end transmission of important services-related emails that are required to use our Services.
- Account deactivation. You can deactivate your Plume account at any time by contacting Customer Support.
- Opt out from cookies. Most Internet browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you set your browser to reject cookies, parts of our website may not work for you. Additionally, some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. If you prefer to not receive targeted advertising, you may be able to opt out of some network advertising programs by visiting the Digital Advertising Alliance Opt-Out Page and the Network Advertising Initiative Opt-Out Page. Please note, depending on your type of device or browser, it may not be possible to delete or disable all cookies and similar technologies on your device. Your selection of the "Do Not Track" option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes, as we do not respond to Do Not Track signals.
- European Privacy Rights. If you are located in the European Economic Area ("EEA") or Switzerland, you are entitled to reach out to us via the contact details in this Policy and ask us for an overview of your Personal Information or ask for a copy. In addition, you may request us to update and correct inaccuracies, delete your Personal Information, restrict processing of your Personal Information, or exercise your right to data portability and to easily transfer your Personal Information to another company. In some cases, you may object to the processing of your Personal Information and where we have asked you for your consent to process your Personal Information, you can withdraw it at any time. We always enjoy hearing from you and appreciate your business. Should you nonetheless have unresolved concerns, you have the right to lodge a complaint with the supervisory authority of your residence, place of work or where the incident took place.
Please note that the rights described above are not absolute, and that your requests cannot always be met entirely. For example, under specific circumstances we may not be able to delete or restrict the processing of your Personal Information as we may have legal obligations or contractual obligations to keep certain information.
We will use commercially reasonable efforts to timely respond to any changes you request. Many such changes are accomplished using batch processing (i.e. collecting a number of similar change requests and making all such changes at once), so the changes may not be immediately effective but may take 30 days or longer. If you require a more immediate change to your Personal Information and are unable to make such a change using the available website resources, please contact us.
Our Services are hosted and operated in multiple geographic regions. Any Personal Information that you provide to us may be transferred, accessed and processed outside of your country. If you are located in the EEA, Switzerland or other regions with laws governing the processing of Personal Information that may differ from U.S. law, please note that your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information.
We comply with applicable legal requirements providing adequate safeguards for the transfer of Personal Information to countries other than the country where you are located. To protect Personal Information transferred from the EEA or Switzerland to the U.S., we have certified to the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. To learn more, read our Privacy Shield Notice.
We may also transfer Personal Information to countries for which adequacy decisions have been issued by the European Commission, use contractual protections for the transfer of Personal Information to third parties, such as the European Commission's Standard Contractual Clauses, or rely on third parties’ certification to the EU-U.S. or Swiss-U.S. Privacy Shield Frameworks where applicable. You may contact us to obtain a copy of the safeguards we use to transfer Personal Information outside the EEA.
Because we’re always innovating and finding new ways to deliver the best Wi-Fi and in-home digital experience to our users, this Policy may change over time. We will post the new Policy online and we will change the "Last Updated" date. You should consult this Policy regularly for any changes. If any modifications materially change your rights, we will provide notice on the Plume website.
The entity responsible for the processing of your Personal Information is Plume Design, Inc., unless we are acting on behalf of one of our business customers. If you have questions or comments about this Policy or our privacy practices, please contact us at email@example.com or at:
Plume Design, Inc.
290 South California Avenue
Palo Alto, CA 94306