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EU-U.S. Privacy Shield: Consumer Privacy Policy

Last Updated: 9 April 2018

Ring LLC and its subsidiaries Ring Protect Inc. and Wireless Environment, LLC (collectively, “Ring”) respect your concerns about privacy. Ring participates in the EU-U.S. and Swiss-U.S. Privacy Shield frameworks (collectively, the “Privacy Shield”) issued by the U.S. Department of Commerce. Ring commits to comply with the Privacy Shield Principles with respect to Consumer Personal Data the company receives from the EU and Switzerland in reliance on the Privacy Shield. This policy describes how Ring implements the Privacy Shield Principles for Consumer Personal Data.

 

For purposes of this policy: 

“Consumer” means any natural person who is located in the EU or Switzerland, but excludes any individual acting in his or her capacity as an Employee.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Customer” means any third-party entity located in the EU or Switzerland that obtains services or products from Ring. 

“Employee” means any current, former or prospective employee, intern or temporary worker of Ring or any of its EU or Swiss subsidiaries or affiliates, or any related individual whose Personal Data Ring processes in connection with an employment relationship, who is located in the EU or Switzerland. 

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“Personal Data” means any information, including Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Ring in the U.S. from the EU or Switzerland, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes Personal Data on behalf of a Controller.

“Sensitive Data” means Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership (including trade union-related views or activities), sex life (including personal sexuality), information on social security measures, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposition of such proceedings, or the sentence of any court in such proceedings (including administrative proceedings and criminal sanctions).

“Vendor” means any contractor, supplier, vendor or other third party located in the EU or Switzerland that provides services or products to Ring.

Ring’s Privacy Shield certification, along with additional information about the Privacy Shield, can be found at https://www.privacyshield.gov/. For more information about Ring’s processing of Consumer Personal Data, please visit Ring’s Privacy Notice.

 

Types of Personal Data Ring Collects

As a Controller, Ring obtains Personal Data about Consumers in various ways. This collection occurs, for example, when a Consumer uses a Ring product or service, creates or adds information to a Ring account, visits Ring’s websites or mobile apps, contacts Ring, or purchases products or services from Ring. Ring may use this information for the purposes indicated in the Ring Privacy Notice.

The types of Consumer Personal Data Ring collects include:

  • Contact information, such as name, telephone number, and email and postal address;
  • Account information, such as online password and other log-in details used to access Ring products and services;
  • Payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by Ring’s third-party payment processor on Ring’s behalf; Ring stores only the last four digits of a Consumer’s payment card and the expiration date;
  • Geolocation data if the Consumer consents to the collection of this data;
  • Product setup information, such as the name and description of the Consumer’s Ring product, the location where the Consumer installs a Ring product, and adjustments the Consumer makes to the product setup;
  • Technical information about the Consumer’s Ring product, such as Wi-Fi network information and the Ring product’s model, serial number and software version;
  • Social media handles, content and other data posted on Ring’s official social media pages;
  • Information Ring obtains from third-party social media services (g., Facebook) or payment services (e.g., PayPal) if Consumers choose to link to, create or log into their Ring account through these services (including when Consumers share Ring videos or content via their social media account);
  • Information Ring obtains from third-party business partners if Consumers choose to use our Ring+ Service, such as account ID, account name and email address;
  • Information submitted in connection with a career opportunity at Ring, such as contact details, resume information and details about current employment;
  • Other data collected automatically through Ring’s websites and mobile apps (such as IP address, identifiers associated with devices, types of devices connected to Ring’s services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of website or app visits); and
  • Other personal information contained in content Consumers submit to Ring, such as through our “Contact Us” feature or customer support tools on our websites or mobile apps.

In addition, Ring obtains Personal Data, such as contact information and financial account information, of its Vendors’ representatives, located in the EU or Switzerland. Ring uses this information to manage its relationships with its Vendors, process payments, expenses and reimbursements, and carry out Ring’s obligations under its contracts with the Vendors.  

Ring also obtains Personal Data, such as contact information, of its Customers’ representatives, located in the EU or Switzerland. Ring uses this information to manage its relationships with its Customers and carry out Ring’s obligations under its contracts with the Customers.

Ring also may obtain and use Consumer Personal Data in other ways for which Ring provides specific notice at the time of collection.

As a Processor, Ring receives Personal Data about Consumers when Controllers provide this data to Ring. For example, in connection with providing our products and services to our Consumers, Ring processes and stores content and related information that is captured and recorded when our products and services are used.   This includes video and audio recordings, live video and audio streams, images, comments, and data our products collect from their surrounding environment (such as motion, events, temperature and ambient light). When Consumers use our products or services, Ring may process Personal Data about Consumers with whom it does not have a direct relationship because Ring obtains or maintains the data as a Processor.

Ring’s privacy practices regarding the processing of Consumer Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

 

Notice

Ring provides information in this policy and the company’s Privacy Notice about its Consumer Personal Data practices, including the types of Personal Data Ring collects, the types of third parties to which Ring discloses the Personal Data and the purposes for doing so, the rights and choices Consumers have for limiting the use and disclosure of their Personal Data, and how to contact Ring about its practices concerning Personal Data.

When Ring acts as a Processor and Consumer Personal Data is transferred to Ring in the U.S. on behalf of a Controller, the Controller is responsible for providing appropriate notice to individuals and obtaining the requisite consent.

Relevant information also may be found in notices pertaining to specific data processing activities.

 

Choice

In circumstances in which Ring acts as a Controller, Ring generally offers Consumers the opportunity to choose whether their Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Consumer. To the extent required by the Privacy Shield Principles, Ring obtains opt-in consent for certain uses and disclosures of Sensitive Data. Consumers may contact Ring as indicated below regarding the company’s use or disclosure of their Personal Data. Unless Ring offers Consumers an appropriate choice, the company uses Personal Data only for purposes that are materially the same as those indicated in this Policy. 

When Ring processes Personal Data about Consumers with whom Ring does not have a direct relationship because Ring obtained or maintains the Consumers’ data as a Processor, the Controller is responsible for providing the relevant individuals with certain choices with respect to the use or disclosure of their Personal Data.

Ring shares Consumer Personal Data with its affiliates and subsidiaries. Ring may disclose Consumer Personal Data without offering an opportunity to opt out, and may be required to disclose the Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Ring also reserves the right to transfer Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

 

Accountability for Onward Transfer of Personal Data

This policy and Ring’s Privacy Notice describe Ring’s sharing of Consumer Personal Data.

To the extent Ring acts as a Controller, except as permitted or required by applicable law, Ring provides Consumers with an opportunity to opt out of sharing their Personal Data with third-party Controllers. Ring requires third-party Controllers to whom it discloses Consumer Personal Data to contractually agree to (i) only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Consumer, (ii) provide the same level of protection for Personal Data as is required by the Privacy Shield Principles, and (iii) notify Ring and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Consumer Personal Data to third-party Processors, Ring (i) enters into a contract with each relevant Processor, (ii) transfers Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the Personal Data in a manner consistent with Ring’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify Ring if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Ring remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Ring proves that it is not responsible for the event giving rise to the damage.

 

Security

Ring takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

takes reasonable and appropriate measures to protect Consumer Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

 

Data Integrity and Purpose Limitation

Ring limits the Consumer Personal Data it processes to that which is relevant for the purposes of the particular processing. Ring does not process Consumer Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Consumer. In addition, to the extent necessary for these purposes and consistent with its role as a Controller or Processor, Ring takes reasonable steps to ensure that the Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Ring relies on Consumers to update and correct the relevant Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Consumers may contact Ring as indicated below to request that Ring update or correct relevant Personal Data. 

Subject to applicable law, Ring retains Consumer Personal Data in a form that identifies or renders identifiable the relevant Consumer only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Consumer.

 

Access
Consumers generally have the right to access their Personal Data. Accordingly, to the extent Ring acts as a Controller, where appropriate, Ring provides Consumers with reasonable access to the Personal Data Ring maintains about them. Ring also provides a reasonable opportunity for those Consumers to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Ring may limit or deny access to Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Consumer’s privacy in the case in question, or where the rights of persons other than the Consumer’s would be violated. Consumers may request access to their Personal Data by contacting Ring as indicated below.  

When Ring maintains Personal Data about Consumers with whom Ring does not have a direct relationship because Ring maintains the Consumers’ data as a Processor, the relevant Controller is responsible for providing those individuals with access to the Personal Data and the right to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. In such circumstances, Consumers should direct their questions to the appropriate Controller. When a Consumer is unable to contact the appropriate Controller, or does not obtain a response from the Controller, Ring will provide reasonable assistance in forwarding the Consumer’s request to the Controller.

 

Recourse, Enforcement and Liability

Ring has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Ring conducts an annual self-assessment of its Consumer Personal Data practices to verify that the attestations and assertions Ring makes about its Privacy Shield privacy practices are true and that Ring’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Consumers may file a complaint concerning Ring’s processing of their Personal Data. Ring will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Consumers may contact Ring as specified below about complaints regarding Ring’s Consumer Personal Data practices.  

If a Consumer’s complaint cannot be resolved through Ring’s internal processes, Ring will cooperate with JAMS pursuant to the JAMS Privacy Shield Program, which is described on the JAMS website at https://www.jamsadr.com/eu-us-privacy-shield. JAMS mediation may be commenced as provided for in the JAMS rules. Following the dispute resolution process, the mediator or the Consumer may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Ring. Under certain circumstances, Consumers also may be able to invoke binding arbitration to address complaints about Ring’s compliance with the Privacy Shield Principles.

When Ring maintains Personal Data about Consumers with whom Ring does not have a direct relationship because Ring maintains the Consumers’ data as a Processor, Consumers may submit complaints concerning the processing of their Personal Data to the relevant Controller and Ring will participate in this process at the request of the Controller or the Consumer.  

 

How to Contact Ring

To contact Ring with questions or concerns about this policy or Ring’s Consumer Personal Data practices, write to:

Legal – Privacy

Ring LLC
1523 26th Street
Santa Monica, CA 90404

or

E-mail: privacy@ring.com

 

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