SAVANT PRIVACY POLICY

Last Updated: June, 2024

California Notice at Collection: If you are a California resident, see the U.S. States Privacy Rights section below for important information about your rights under California law. If you are located in the European Economic Area, UK, or Switzerland, please also see the Supplemental European Privacy Statement below.

Savant Systems, Inc. and our affiliates (“Savant”, “we”, “us”, or “our”) respect the privacy of our users. This Privacy Policy explains the type of personal information that we collect and how we collect, use, access, disclose, safeguard, store and otherwise process your personal information (i.e. any information that personally identifies you such as your name and contact information), when you use the Savant family of smart home products and services including, but not limited to, Lighting, Power, Climate, Energy Monitoring & Management, Audio, Video, Security, Entry Access, Pool & Spa, and other services from Savant, as well as any products which may include embedded software (“Product Software”, and together with the purchased hardware product will be referred to as “Products” herein), related software applications, including any mobile software application, such as the Savant Application and the Savant Power Storage Application (“Savant App”, “Savant Mobile App” or “App”), the related Savant Website Application (“WebApp”), use of our website (www.savant.com) (“Site”), including subscription services available through our Site, the App and WebApp (“Subscription Services”). The Site, App, WebApp and Subscription Services are the “Services” and together with the Products, the “Savant System”.

Please read this Privacy Policy carefully. You can download a printable copy of this Privacy Policy here. If you do not agree with the terms of this Privacy Policy, please do not access or use the Savant System. Your clicking to accept these terms in our App or WebApp or use of the Savant System is your acknowledgement and agreement (i) to the terms of our Privacy Policy and any other applicable agreement that may be provided together with the Products and Services, and (ii) that we have your permission to collect and process your information as described in this Privacy Policy. If you’re agreeing to this Privacy Policy on behalf of an organization or entity, you represent and warrant that you are authorized to agree to this Privacy Policy on behalf of that organization or entity and to bind them to these provisions (in which case, the references to “you” and “your” in this Privacy Policy, except for in this sentence, refer collectively to you personally and to that organization or entity). We may need to make changes to this Privacy Policy as privacy laws change, our Services evolve, or we add or change service providers among other things. As a result, we reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. We will also attempt to notify you via email or through the App or WebApp should a material change occur. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on our websites at www.savant.com. Your continued use of the Savant System following the posting of changes to these terms means you accept the updated Privacy Policy.

INFORMATION WE COLLECT

1. Information we may collect directly from you:

• Personal Information that identifies you, such as your name, contact details including phone number, email address, postal address, telephone or fax number; area code only, zip code only, ID information such as driver’s license number or SSN, dependents, spousal and other family information, and household information;
• Account Registration Information, such as information provided by you when you register for an account to use your Savant System, including User ID, log-in details, security questions and answers, and passwords;
• Product Set-Up Information, such as the name, description and location of Products you have registered;
• Financial, Payment and Commercial Data, such as name, billing address and payment card details, including credit card numbers, expiration dates, and security codes (which are collected by our third-party payment processor on our behalf) in the event you purchase any Products or Services directly from us as well as any history and records of Products and Services inquired about, obtained or other information that may facilitate purchase, refunds, rebates, returns or exchanges of Products and Services;
• Sensitive Data and Biometric Information, such as health and medical information, including but not limited to, disability status or biometric Information such as facial recognition, fingerprint recognition, or voice ID you upload as part of the Services;
• Audiovisual Materials, such as photographs, images and recordings that you upload to identify users. Products, your home or facility, or otherwise as part of your use of the Savant System;
• Professional or Employment Related Information you provide, such as your current position, job title, employer, or location, that you may provide in relation to the Services;
• Export Control Information, such as your nationality or country of residence, that allows us to determine if you are permitted to receive certain information or technologies pursuant to export control regulations;
• Marketing and Communications Data, including your preferences for receiving our marketing communications and details about your engagement with them, or your interest in our Products and Services, and your subscriptions to our Services; and,
• Other personal information you submit to us through communications, customer support exchanges, our “Contact Us” link, surveys, a competition, reporting a problem, email, or otherwise.

2. Information we may obtain about you from your usage, from others or by automated means:

• Information We Obtain from Third-Party Business Partners, such as personal contact details, account registration, or Products information provided by an Authorized Savant Dealer, Distributor or Installer;
• Biometric Information including Facial Recognition, footage recorded from your use of the Savant System, such as facial recognition or voice identification of you, your family, or any person in or outside your home that is captured by the Savant System;
• Video, Audio and Other Data, such as video or audio streams, images, preferences, usage data, comments, performance metrics, and data collected by the Savant System during the performance of any Products or Services, and their respective functions including motion detection, audio detection, video recordings, energy use and consumption, event logging or recording, temperature, and lighting;
• Derivative Data, such as technical information about the Products or Services, including device name and type, IP address, Wi-Fi network information and signal strength, other set up data, sensor status, adjustments to Products, usage, performance, battery charge level, operating system, browser type, access times, pages viewed directly before and after accessing the App or Web App, other interactions with the App or Web App which are automatically collected and stored in log files;
• Data from Social Media Sites or Services, such as items, comments, feedback or content posted on our social media pages; including Facebook if you choose to link to, create or log into your Savant account through these third party sites or services (including when you share Savant videos, Ring videos, or content via your social media account) or payment services;
• Geolocation and GPS Data, including physical location of your Products, such as device(s) data or collection of audio by using satellite, cell phone tower, or Wi-Fi signals;
• Audiovisual Materials, such as other audio, video captured during marketing/public filming events that you consented to including recording of virtual or live workshops or similar events;
• Information We Collect from Publicly Available Sources, including registers, the internet, public authorities, previous employers, educational institutions, suppliers and vendors without obligations of confidentiality;
• Market and Research Information, such as IP address, social media handle, or other online identifiers of a person, email address/mobile number if used for direct marketing and name and address, demographic data, (e.g., income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers); and
• Cookies, web server logs, web beacons and other technologies (See also Cookies Section below).

With respect to your use of any camera that is part of the Savant System, we may also collect sensitive information (personal data that has special protection under data protection laws) about you. For example, we may collect biometric data in order to provide a facial recognition functionality for an Authorized User, family member, third-party you upload, or other visitors at your residence, property or business.

You can disable the processing of biometric data at any time by managing your settings directly from the Savant System. Our cameras are strictly for personal or domestic use. The Savant System and associated cameras allow you to determine the purposes and means of the processing activities you want to achieve in your home or facility. In certain jurisdictions, the rights of individuals under camera surveillance are protective of such individuals being recorded. Your sharing of such videos in the public domain or surveilling public space with your camera may make additional laws applicable to your surveillance. In any case, you are responsible for compliance with any applicable law when using our Products and Services. It is your responsibility to understand the law that applies to your collection and use of facial recognition, video, audio and other data where you live. For any other components of the Savant System, such as door entry products that use fingerprint recognition to allow for doors to open or lock based upon reading authorized person’s fingerprints, such components may not work if you disable the biometric data functionality.

Additionally, certain laws or regulations require that you inform anyone entering your property or home about the functioning and operation of the cameras. If necessary, depending on applicable law and your processing activities, you may either need to display a notice alerting visitors to your property or home that you are using a camera to record images and people on your property, and, in some cases, you may need to obtain their prior explicit consent. We cannot be responsible and will not be responsible for your compliance with applicable laws from the use of the Savant System, and it is your responsibility to understand the law that applies to you and where required obtain explicit consent for the collection of biometric information including, but not limited to, fingerprint recognition, and facial recognition, of other users or visitors to your home or facility, invited or uninvited, inside or outside your home or facility. You are required to comply with all applicable legislation regarding the protection of personal information, image rights and privacy.

HOW WE USE THE INFORMATION WE COLLECT
We use your personal and other information to:

• Manage our contractual relationship with you, including providing you with information regarding Products and Services, billing and order information, purchased Products, handling claims, troubleshooting, system maintenance, hosting and providing customer support services;
• Set up and manage your Savant account and profile, including to maintain your subscription to any Services and contact you regarding your account;
• Provide, develop and improve our Products and Services, including delivering our Products and Services to you and for additional purposes that help us to develop and improve the quality of our Products and Services (including as part of the development of any new products and services);
• Facilitate communication, between us as well as the Savant Authorized Dealer or Installer that installs your Savant System;
• Comply with a legal, regulatory or relevant industry standard obligation, including this Privacy Policy, intellectual property infringement, or enforcing our Terms of Service, Support Agreement, or other contracts you have entered into with us;
• Protect against, identify and prevent fraud or other criminal activity, claims and other liabilities, that we may notice based upon any activity on your account or your use of the Services;
• Monitor your use of the Savant System, as part of any routine support and maintenance of the Products or included in any subscription Services, provided you understand Savant is not obligated to monitor your use of the Savant System;
• Improve the security and other related system and network functions including preventing misuse;
• Perform analytics, including trend and financial analysis, market and consumer research, anonymization and aggregation of personal information; and
• Conduct marketing activities in accordance with applicable laws. Depending on your jurisdiction, you will either be required to opt in to receive marketing communications or opt out by using the unsubscribe link in any marketing materials you receive via email from us or by contacting us at the link provided on our website.

HOW WE SHARE YOUR INFORMATION

1 ) We share your personal information in the following limited situations:

• With your consent;

• With our Affiliates, other Savant companies that comply with this Privacy Policy;

• With Authorized Users, that you invite;

• With our Third-Party Business Partners, including those that you contracted with such as an Authorized Dealer, Distributor or Installer;

• With our Third-Party Advertisers, for marketing purposes from which you can opt out at any time

  • Our third-party advertising partners may use cookies and similar technologies to collect Site, App and WebApp Information and other information, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate such advertising to those or similar users on other online platforms;

• With Third-Party Providers’ Products or Services that you select to integrate or interoperate with the Savant System, only where you have directed us to connect you with such third-party and you have consented to their access or control of the Products or Services that you have connected, such as Ring, Google, Spotify, Amazon Alexa, or other third-party providers whereby such third-party providers have own terms and conditions and privacy policies which will govern your use of their products and services and their use of your personal information;

• With our Service Providers, who facilitate us in providing some of our Products and Services to you including, for example, processing, storage, and technical assistance, whereby we have entered into contracts with such service providers which include limitations on their use of certain of your information and only as necessary to provide these Products and Services to us/you;

• With Third-Party Service Providers for Web and App Analytics, including automated technology to collect and analyze your information, including personal information to help us understand your use and optimize your customer experience (please see our section on Cookies and our separate Cookie Policy to learn more);

• With Professional Advisors and Governmental Authorities, if we believe in good faith that disclosure, access, use or preservation of such information is necessary to (i) meet any applicable law, regulation, legal process or governmental request; (ii) enforce or investigate your compliance with the terms of any of our contracts or policies we have with you for potential violations; (iii) protect against physical, financial or other harm against the rights, safety or property of you, us, or any third-party; and, (iv) investigate fraud, technical, security or other operational issues; and

• In connection with Corporate Transactions, meaning changes to our corporate structure due to sale, transfer, merger or other reorganization of our company during which your personal information may be among the items sold or transferred.

2 ) We may share your non-personal information with:

• Affiliates,
• Third-Party Business Partners and Service Providers, and
• Other Users, including aggregated or anonymized customer data related to, for example, energy use and consumption, to help us improve the Savant System or raise awareness about safety issues.

Note: Our Privacy Policy does not cover any information that you provide to a third-party, Savant Authorized Dealer or Distributor that you purchase a Savant Product from, or an installer for the installation of the Savant System. Their use of your personal information will be covered by their respective privacy policy. Our Privacy Policy does not cover any information collected through your use of a third-party product that you have integrated into the Savant System; it is your responsibility to review and understand any such privacy practices of third-party integrated products. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We may make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Savant System and promote our business. We will not attempt to re-identify any such data, except as permitted by law. Additionally, in some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law. Any data that Savant receives from third-parties will be processed and stored by Savant in accordance with the terms of this Privacy Policy.

YOUR CHOICES In this section, we describe the rights and choices available to all users regarding their personal information. Users who are located in certain U.S. States (e.g., California) and Europe can find additional information about their rights below.

• Access or update your information. If you have registered for an account with us, you may review and update certain account information by logging into the account or by contacting us.
• Opt-out of communications. If you no longer wish to receive marketing-related communications, you may opt-out of receiving these emails by clicking “Unsubscribe” found in emails we send you. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

THIRD PARTY WEBSITES Our Services may include links to third-party applications, products, services, or websites. If you access those links, you will leave our Services. Savant does not control these third-party sites or their privacy practices, which may differ from Savant’s practices. The Savant Privacy Policy does not cover the personal information you choose to provide to or that is collected by these third parties. You are encouraged to review the privacy documentation of any third-party site you interact with before you allow them to collect and use your personal information. Savant may also provide social media features through, e.g., the Site, such as Facebook, Instagram, YouTube or X (Twitter) buttons, that enable you to share information with your social networks or to interact with Savant on various social media websites. Your use of these features may result in the collection or sharing of information, including personal information, about you depending on each specific social media website. This may include your IP address, which page you are visiting on our Site, and a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.

HOW WE SECURE YOUR INFORMATION

The security of your information is important to us. Savant takes a number of precautions — including administrative, technical, and physical measures — designed to safeguard your personal information against loss, theft, and misuse, as well as against unauthorized access, disclosure, alteration, and destruction. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information. For more information on our security practices, please contact us at the Contact Information provided below.

WHERE YOUR PERSONAL INFORMATION IS USED OR ACCESSIBLE INCLUDING ANY INTERNATIONAL TRANSFERS

Savant is located in the United States, and as such, all personal information will be accessed and stored there, and will be transferred there should you live in another country. Savant may also contract with cloud service providers located in other countries, and certain personal information may be accessed and stored from additional countries. Where required, we have put in place appropriate safeguards with our affiliates, service providers, contractors, distributors and other business partners and agents to ensure that transfers of personal information outside the EEA and UK are adequately protected. Unless a jurisdiction is deemed to have adequate safeguards, the safeguards we typically put in place are the Standard Contractual Clauses in accordance with the General Data Protection Regulation and the UK General Data Protection Regulation.

RETENTION OF YOUR PERSONAL DATA

We retain your personal information as follows:

The period during which we store your personal information varies depending on the purpose for the processing:

• For the provision of our Products and Services, for so long as you are a client or subscriber to the Services.
• For marketing purposes, until you have opted out of receiving further direct marketing communications in accordance with applicable law.
• In all other cases, we store your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy or such retention period as required by law, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed. The applicable information, and location and infrastructure where your personal information is stored or can be accessed is as follows:
• Product information, in your home, including but not limited to photos, videos, audio, email address, Wi-Fi or network password, usage information, energy usage and consumption information, account profile information, with such information being stored until you delete it from or reset your Product, - Within Savant’s infrastructure, such as on our or our service provider’s servers or cloud environment, where we may store your personal information, including but not limited to photos, videos, audio, email address, Wi-Fi or network password, usage information, energy usage and consumption information, account profile information, until you delete it, edit it, or for as long as you remain a client or for such period for us to meet a legitimate interest, resolve dispute, legal defense, enforce agreements, conduct audits and comply with laws. Further, you can request that we provide you with access, amend or delete your information on our servers in certain cases.

USE OF COOKIES AND OTHER DATA COLLECTION TOOLS

Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.

• “Cookies” are small text files that are placed on your device by a Web server when you access a website. To enable our systems to recognize your browser or device and to provide and improve the Site and/or WebApp, we may use both session Cookies and persistent Cookies. We may also use Cookies to monitor aggregate usage and web traffic routing on our Site and WebApp and to customize our Services. Unlike persistent Cookies, session Cookies are deleted when you log off and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Site and/or WebApp. Some third-party service providers that we engage (including third-party advertisers) may also place their own Cookies on your device. Note that this Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third-parties.
• “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be used for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Site and WebApp, to monitor how many visitors view our Site and WebApp, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

For more information about cookies and how we use them, please read our Cookie Policy.

You can opt out of our use of cookies to recall information about you by setting your browser not to accept cookies or to disable cookies. Most browsers also offer additional built-in tools to help you manage, control, and delete cookies, including cookies used for advertising. We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities. We respond to the Global Privacy Control signal for California residents.

MINORS

You must be at least 18 years old (or equivalent minimum age in the jurisdiction where you reside) to use the Products and Services. If you are between the ages of 13 (or equivalent minimum age in the jurisdiction where you reside) and 17, you may use our Products and Services only with the consent and under the supervision of a parent or legal guardian who agrees to be bound by this Privacy Policy on your behalf. If you are a parent or legal guardian of a user between the ages of 13 and 17 (inclusive), you consent to the provisions of this Privacy Policy on behalf of such user and you are fully responsible for the acts of such user in relation to our Products and Services. Any use or access to the Products and Services by individuals under the age of 13 (or the equivalent minimum age in the jurisdiction where you reside) is strictly prohibited and is a violation of this Privacy Policy.

CONTACT INFORMATION

If you have any questions about this Privacy Policy or if you would like us to update information we have about you, change your preferences, or exercise applicable data protection rights, please contact us by e-mail at support@savant.com or write to us at:

Savant Systems, Inc.

Attn: Legal
45 Perseverance Way
Hyannis, MA 02601
Phone: 800-986-3041

U.S. States Privacy Rights
Last updated: May 2024

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or any other state that has enacted applicable data protection regulations (the “Supplemental States”), the following provisions may apply to our processing of personal information as described in our Privacy Policy. For such residents, the provisions of this U.S. States Privacy Rights section prevail over any conflicting provisions of our Privacy Policy. Savant values the privacy of our clients, users and Site visitors and we take measures to implement reasonable security controls for the protection of our clients’ information. This section does not apply to our collection, use, and sharing of personal information of our job applicants and employees. We provide a different privacy notice to such individuals, and that notice applies to such individuals.

Your Rights. If you are a resident of a Supplemental State, you may have certain rights related to your personal information. The rights listed below are not absolute, and we may be entitled to refuse requests, wholly or in part, where exceptions under applicable law apply. Your rights may include:

• The right to request access to personal information that we have collected or retained about you. If requested, we shall provide you with a copy of your personal information which we collected as permitted by the Supplemental States privacy laws. You also have the right to receive your personal information in a structured and commonly used format so that it can be transferred to another entity (“data portability”).

• The right to request to know:

  • specific types or categories of personal information we have collected about you;
  • categories of sources from which the personal information is collected;
  • our business or commercial purpose for collecting, sharing, or selling personal information; and
  • categories of third parties with whom we share personal information.

• The right to request that we delete personal information about you which we have collected from you.

  • In certain circumstances, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (instructions and description below), we will delete, and, as applicable, direct our service providers to delete, your personal information from our records, unless an exception applies.
  • We may deny your request to delete your personal information if retaining the information is necessary for us or our service providers, subject to certain exemptions based on your state of residence.

• The right to opt-out/do not sell or share your personal information.

  • You have the right to opt-out of selling or sharing your personal information with third parties for some purposes, including sharing that may be defined as a sale under applicable Supplemental States laws. Savant does not sell your personal information in a traditional sense, that is, for monetary value. Savant does disclose personal information for business purposes as outlined in our “How we Share Your Information” section of our Privacy Policy.
  • You can opt-out of this selling or sharing by clicking on the “Do Not Sell or Share My Information” link at the bottom of our homepage and submitting a request via the authorized methods.
  • You also may have a right to opt-out of the use of automated decision-making technology.

• The right to request that we do not share or disclose your sensitive personal information.

  • You have the right to limit how your sensitive personal information is disclosed or share with third parties. We will not share your sensitive personal information without your consent.

• The right to request correction or rectification.

  • In certain circumstances, you have the right to request correction of any inaccurate personal information.

Exercising your rights: To submit requests to exercise any of the foregoing rights with respect to your personal information, please contact us at the contact information provided below. To exercise your right to opt-out of the “sale” or “sharing” of your personal information, you can update your cookie preferences to disable any applicable advertising cookies or contact us using the Contact Information found below. We respond to the Global Privacy Control signal for California residents. Subject to applicable Supplemental States laws, we may not discriminate against you because of your exercise of any of the above rights under the Supplemental States laws, including by:

• Denying you Products or Services; - Charging different prices or rates for Products or Services, including through the use of discounts or other benefits or imposing penalties; - Providing you a different level or quality of Products or Services; or - Suggesting that you will receive a different price or rate for Products or Services or a different level or quality of Products or Services.

Verification of identity; authorized agents: In order to process any of the foregoing rights with respect to your personal information, we reserve the right to confirm your residency in the applicable Supplemental States, and we will need to verify your identity. To do so, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law. In some instances, your authorized agent may make a request on your behalf. We will need to verify your agent’s identity and be in receipt of a valid power of attorney as required under applicable Supplemental States law(s).

Personal Information that we collect, use, and disclose. We summarize the personal information we collect by reference below to both categories defined in the “Information We Collect” section of the Privacy Policy. In accordance with the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively the “CCPA”), we have collected the following categories of personal information from consumers, clients and Site visitors within the last twelve (12) months. Information you voluntarily provide to us may contain other categories of Personal Information not described below.

• It is necessary for the performance of Services we provide to you; such as the delivery of our Products or Services under our Terms of Service or the fulfillment of a contract with you (“Contractual Necessity”); - It is necessary for us to comply with our legal and/or contractual obligations; such as replying to a governmental request or a subpoena or other legal process (“Compliance with Law”); - Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.

Personal Information (“PI”) we collect	CCPA statutory category	Source of PI	Business/ commercial purpose for PI collection	Categories of third parties to whom we “disclose” PI for a business purpose	Categories of third parties to whom we “sell” or “share” PI
Contact and Request Information	Identifiers Commercial information California customer records Internet or network information	You Third-party sources Automatic collection	For the purposes disclosed in “How we use the Information we Collect”	Service providers Savant affiliates Business and marketing partners Business transferees Others as required by applicable law Professional advisors Courts and public authorities	Business and marketing partners
Account Information	Identifiers Commercial information Professional or employment information California customer records Internet or network information	You Automatic collection	For the purposes disclosed in “How we use the Information we Collect””	Service providers Savant affiliates Third-party advertising partners Business and marketing partners Business transferees Others as required by applicable law Professional advisors Courts and public authorities	Business and marketing partners
Website information and mobile information	Identifiers Internet or network information	Automatic collection	For the purposes disclosed in “How we use the Information we Collect”	Service providers Savant affiliates Business and marketing partners Business transferees Others as required by applicable law Professional advisors Courts and public authorities	Business and marketing partners
Audiovisual information	Sensory information	You Automatic collection	For the purposes disclosed in “How we use the Information we Collect”	Service providers Savant affiliates Others as required by applicable law Business transferees Professional advisors Courts and public authorities	N/A
Sensitive Data and Biometric data	Biometric information Sensitive Personal Information	You Automatic Collection	For the purposes disclosed in “How we use the Information we Collect”	N/A	N/A
Marketing information	Identifiers Commercial information California customer records Internet or network information	You Third-party sources Automatic collection	For the purposes disclosed in “How we use the Information we Collect”	Service providers Savant affiliates Business and marketing partners Business transferees Others as required by applicable law Professional advisors Courts and public authorities	Business and marketing partners
Data derived from the above	Inferences	N/A	To provide and optimize our products and services To market and advertise to you For compliance and protection purposes as described in this Privacy Policy	Service providers Savant affiliates Third-party advertising partners Business and marketing partners Business transferees Others as required by applicable law Professional advisors Courts and public authorities	Business and marketing partners

Use of Personal Information** We may use or disclose the personal information we collect for one or more of the purposes provided in the “_How we use the Information we Collect_” and the “_How we Share & Secure Your Information”_ sections of our Privacy Policy. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Changes to Our Privacy Policy. We reserve the right to amend this U.S. Privacy Rights section at our discretion and at any time. If we materially change this U.S. Privacy Rights section, we will post the updated notice on our Services and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information

If you have any questions or comments about this U.S. Privacy Rights section, the ways in which we collect and use your personal information, your choices and rights regarding such collection or use, or wish to exercise your rights, you may email us at [support@savant.com](mailto:support@savant.com) or contact us at:

Savant Systems, Inc.
45 Perseverance Way
Hyannis, MA 02601
Phone: 800-986-3041

SUPPLEMENTAL EUROPEAN PRIVACY STATEMENT

Last updated: May 2024 The information provided in this Supplemental European Privacy Statement (“Supplemental Statement”) only applied to individuals in the European Economic Area (“EEA”), United Kingdom, and Switzerland (collectively “Europe”). If you are based in Europe, this Supplemental Statement applies to you in addition to the Privacy Policy above.

References to “personal information” in Savant’s Privacy Policy should be understood to include references to “personal data” as defined by the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”) and the EU GDPR as it forms part of UK law (“UK GDPR”)). Under the GDPR, personal data is information about an individual, from which that individual is either directly identified or can be identified. It does not include ‘anonymous data’ (i.e., information where the identity of the relevant individual has been permanently removed and that individual is no longer identified or identifiable).

Controller. Savant Systems, Inc. is the controller with respect to the personal data covered by this Privacy Policy for the purposes of GDPR.

Cookies. With respect to web cookies and similar technologies that are not strictly necessary for our provision of the App, WebApp and Site, we seek consent from users in Europe based on a separate Cookie Policy.

THE LEGAL BASIS ON WHICH WE PROCESS YOUR PERSONAL DATA

If European data protection law applies to the processing of your personal data and in such instances, we process your personal data for the purposes described in this Privacy Policy, based on the following legal bases:

• It is necessary for the performance of Services we provide to you; such as the delivery of our Products or Services under our Terms of Service or the fulfillment of a contract with you (“Contractual Necessity”);
• It is necessary for us to comply with our legal and/or contractual obligations; such as replying to a governmental request or a subpoena or other legal process (“Compliance with Law”);
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
  • Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see ‘How we Use the Information we Collect’ above.

Purpose	Categories of personal information involved	Legal basis
To respond to your comments, questions and requests	Contact and Request Information	Legitimate Interests We have a legitimate interest in offering you customer service, including by communicating with you where you have contacted us
To manage your account	Account Information	Contractual Necessity
To monitor the performance of our Products and Services	Website Information and Mobile Information	Legitimate Interests We have a legitimate interest in ensuring the ongoing security and proper operation of our Services and associated IT services, systems, and networks
To serve interest-based advertising	Website Information and Mobile Information	Consent Legitimate Interests We have a legitimate interest in offering you customer service, including by allowing you to customize your experience with advertising relevant to your interests
To personalize our Services	Public Information	Legitimate Interests We have a legitimate interest in offering you personalized customer service and that remembers your selections and preferences
To host or manage any events that we may sponsor or be a participant	Audiovisual Information	Legitimate Interests We have a legitimate interest in promoting the Products and Services we offer
To send you personalized direct marketing communications based on your needs and interests	Marketing Information	Consent Legitimate Interests We have a legitimate interest in promoting the Products and Services we offer and sending marketing communications for that purpose
To comply with our legal and contractual obligations and protect our legal interests	Any and all data types relevant in the circumstances	Compliance with Law Legitimate Interests Where Compliance with Law is not available, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety
To create aggregated, de-identified and/or anonymized data		Legitimate Interests We have a legitimate interest in ensuring that our Services and how we use your personal data are as unintrusive as possible.

INTERNATIONAL TRANSFERS

Savant is located in the United States, and as such, all personal information will be accessed and stored there, and will be transferred there should you live in another country. Where required, we have put in place appropriate safeguards with our affiliates, service providers, contractors, distributors and other business partners and agents to ensure that transfers of personal information outside Europe are adequately protected. Unless a jurisdiction is deemed to have adequate safeguards, the safeguards we typically put in place are the European Commission’s Standard Contractual Clauses or the UK’s International Data Transfer Agreement in accordance with the GDPR.

DATA RETENTION

We keep personal data as long as required to provide our Services to you and comply with applicable laws. For example, if you register for an account, we retain your personal data for as long as you have an account with us and then for only as long as required for us to comply with applicable laws, discharge our contractual obligations to you, or defend our legal interests in connection with any claim or defence we could face before any formal dispute resolution body. We take reasonable measures to ensure that personal data is deleted, erased or anonymised as soon as possible once the purposes for which personal data was collected have been fulfilled.

DATA SUBJECT RIGHTS

European data protection laws give you certain rights regarding your personal data. If you are located in Europe, you may ask us to take the following actions in relation to your personal data that we hold:

• Access. Provide you with information about our processing of your personal data and give you access to your personal data.
• Correct. Update or correct inaccuracies in your personal data.
• Delete. Delete your personal data where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Transfer. Transfer a machine-readable copy of your personal data to you or a third party of your choice.
• Restrict. Restrict the processing of your personal data, for example if you want us to establish its accuracy or the reason for processing it.
• Object. Object to our processing of your personal data where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal data for direct marketing purposes.
• Withdraw Consent. When we use your personal data based on your consent, you have the right to withdraw that consent at any time.

If you object to our processing of your information, it may impact our ability to deliver all of our Services to you. You may request action with respect to such rights by emailing us at: support@savant.com, or calling, faxing or writing us at the address below, which will require you to provide valid identification prior to our sending any information.

Savant Systems, Inc.
45 Perseverance Way
Hyannis, MA 02601
Phone: 800-986-3041

Your Right to Complain. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal data, you can make a complaint to the data protection regulator in your habitual place of residence.

• For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
• For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow - Cheshire SK9 5AF
Tel. +44 303 123 1113
Website: https://ico.org.uk/make-a-complaint/

Your Choices. You are not required to provide any personal data to Savant, but if you do not provide any personal data to Savant, you may not be able to use our Products or Services or conduct business with us effectively. You can use our Web App, App and Site without consenting to cookies that are not strictly necessary; the only consequence is that our Web App, App and Site will be less tailored to you.

Profiling. Savant does not use in connection with our Products and Services automated decision-making in a way that produces legal effects concerning you or which significantly affects you.