PRODUCTS PRIVACY POLICY

Last Modified on: March 7, 2018



This Products Privacy Policy ("Privacy Policy") describes how Light Labs Inc. ("Light," "we," "us" or "our") collects, uses, discloses and secures information collected from or about users ("users" or "you" or "your") resulting from or relating to your use of Light's camera products, hardware, software, and applications, including desktop and mobile applications (the "Light Products"), but excluding Light's website and any services provided or accessed via Light's website.  Any use of Light's website, or the services Light provides via its website, is instead subject to Light's Website Privacy Policy, located at https://light.co/legal#privacy ("Website Privacy Policy").



Certain provisions differ for users based in the European Union (including the United Kingdom).  Where this is the case, it is indicated below.



Summary of Certain Key Points to Note:



Advanced, innovative Internet-connected devices, such as Light L16, collect, use, store and share data. Please read this Privacy Policy carefully as by accessing and using a Light Product you are consenting to the terms of this Privacy Policy.



The Light Products automatically collect, use, and store certain data (including Personal Information) such as system tracking, device IDs, error issues, geolocation and product usage reporting data. Your Light Products will then automatically share certain of that data with Light, unless you opt out of the automatic sharing of such data during the start-up process or at any time via the settings menu. Light uses the data for various reasons, including to analyze usage patterns and trends (and Light shares some of its analysis with its distribution partners and third party providers). If you do not opt out of automatic sharing, Light will use, store and share data collected by your Light Products as described above, in accordance with this Privacy Policy. If you opt out of automatic sharing, your Light Products will not automatically transmit any information to Light unless you proactively chose to provide us with this information via the Light Products or otherwise. Users based in the EU should note that Personal Information will be stored and processed by Light and other parties in the USA.



1.	What Information Do We Collect About Our Users?



We, and third parties on our behalf, collect Personal Information and Non-Personal Information via the Light Products. Certain information stored on the Light Products will not be automatically transmitted to Light, but you may proactively provide us with such information, as set forth herein. Other information stored on the Light Products will (where Light Products are online) be automatically transmitted to Light, again as set forth herein. Personal Information collected by Light from the Light Products will also be combined or linked with information collected via another application or service, including through our website, in a manner that identifies/further identifies you or another specific natural person.



For purposes of this Privacy Policy:



-	"Personal Information" is data relating to an identified or identifiable natural person, including where the person is referred to by an identifier such as name, email address, or phone number.



-	"Non-Personal Information" is data that is not Personal Information.



2.	How Do We collect the Information About Our Users?



We collect information about our users in several different ways:



Information Provided by the User:



You may proactively provide Light with certain information as described below.



-	Light, and third parties on Light's behalf, collect Personal and Non-Personal Information you proactively choose to provide to Light via the Light Products or otherwise, including information contained in videos, photos, and other submissions you upload or capture via the Light Products (the "Content"). This information may include "sensitive" Personal Information, such as details of racial or ethnic origin, biometric data and other sensitive categories of information, depending on the Content (e.g. photos, video) uploaded. While Personal Information may be included in the visual images of the Content, Light will not use such information. Instead, Light will use the Content to analyze and improve the functionality of our products and services. Light also collects and analyzes Content metadata (e.g. how images were captured, whether modules were in focus, how Light's algorithm overlays the images and fuses together) to improve the Light Products, as well as to diagnose and troubleshoot issues.  The specific types of information collected will depend upon the Light Products you use, how you use it, and what you choose to provide.



-	Light, and third parties on Light's behalf, collect Personal and Non-Personal Information when you choose to provide an error report to Light through the Light Products.  Personal Information collected for this purpose would include information such as your name and email address that you provide in connection with uploading the error report. It may also include the further types of Personal Information set out in the bullet above, in the event you share Content as part of your error report.



-	The Light Products may prompt you to provide your Wi-Fi network name and to provide us with access to your Content to enable you to download Content to your computer/mobile device and to upload Content to third party websites and applications (including social media networks).



-	Light and third parties on Light's behalf will have access to Personal and Non-Personal Information contained on the Light Products when you return them to Light for repair, replacement or refund (including in accordance with the Product Warranty). Our standard policy however is to delete Content upon receipt of Light Products for repair, replacement or refund.



-	Other contexts where you may provide Light with Personal and Non-Personal Information include: (i) in connection with us providing updates regarding and to your Light Products; (ii) registration of your Light Product; and (iii) other uses of the Light Products where information is requested for use and/or participation.



Light collects additional information via its website. Such collection is governed by the Website Privacy Policy, as noted above.



Automatically Collected Information:



When you use your Light Products, Light automatically collects certain information as described below. This information is transmitted to Light either directly from your Wi-Fi-enabled Light camera or via Light's desktop or mobile application. We also collect such information through the use of third-party applications. You will be asked to consent to this collection of information as part of your initial set-up of the Light Products. If you have not given consent or have subsequently opted out of such collection by Light, your Light Products [may] still collect this information, but they will not transmit this information to Light (unless you proactively provide us with this information after refusing consent or opting out).



-	Once you have activated any Light Product, it will collect behavioral, contextual, and operational data (including Personal Information).  Where your Light Products are online we automatically receive certain information about your Light Products and your use thereof, including serial number, firmware version, log files, user metrics and diagnostics.



-	Light also collects information about precise geolocation.  We collect information on your location in order to provide location-based features, such as geo-tagging images, and to improve the functionality of the Light Products, such as for server optimization. If you do not wish to share your geolocation with us, in addition to opting out (as above) you can also switch off the GPS functionality on your device.



-	Light partners with third party applications to collect user statistics and diagnostic information on Light Products and your usage thereof. These applications will collect information on how you are using the camera, including which features and functionality you are using. The information collected will not be combined or associated with other Personal Information or Non-Personal Information.



Anonymization and Aggregation:



When we collect information that could identify you personally, we "anonymize" it for certain purposes. We remove data fields that can reasonably be used by third parties to identify you. We also use a variety of statistical techniques and operational controls to anonymize data. Anonymizing information is one of the tools we use to protect your privacy. We also combine data into anonymous groups, and analyze it. We call this "aggregation".



In particular, the usage data we extract and the crash reports are anonymized by the creation of a Universally Unique Identifier ("UUID") that will not be combined or associated with other Personal Information and will not be tied back to you unless done so at your request, i.e., you provide the device or the UUID to us or to an authorized representative of ours.



Information from Third Party Partners:



If you connect to a third party (such as a social network) through the Light Products, you are authorizing Light to collect, store, and use any and all information that you agreed that the network or other third party platform could provide to us based on your settings on the third party network or platform. Our use of any information provided by a third-party network or platform will be in accordance with this Privacy Policy.



The privacy practices set forth in this Privacy Policy are applicable only to the Light Products.  If you link to or obtain information from third party applications, websites or other online services, please be aware that Light does not control the privacy practices of such applications, websites or services and your use of any information received from such websites or services shall be governed by the policies of those applications, websites or services.



3.	How Do We Use the Information?



The information we collect from and about you and your Light Products will be used:



-	to provide and update the Light Products and to enable you to utilize the same (including uploading/downloading Content and any geolocation features you choose to use);

-	to evaluate, personalize and improve the features and functionality of current and future Light Products and to develop other Light Products and products and services to be used in or with Light Products;

-	to diagnose and troubleshoot issues with the Light Products;

-	to provide customer support and service and to maintain our relationship with you;

-	to process requests for repair, replacement or refund (including in accordance with the Product Warranty);

-	to fulfil your requests, facilitate registration, respond to error reports submitted and complete transactions;

-	to create anonymous and aggregate data or reports, which are analyzed for the purposes of creating summary reports and identifying and summarizing data patterns or trends regarding use of Light Products (including for distribution to our partners and third-party service providers); and

-	to comply with legal requirements.



4.	Who do we Disclose the Information to?



Disclosure to Third Parties:  If you choose to share your Content with any media services or sites (like Instagram or Facebook), then your Content will be shared with users of those social media services with which you have chosen to share.  In that case, any information you share will be governed under the third party?s privacy policy and your privacy settings on those services.  Please note that such Content may contain geolocation or other metadata information that may be disclosed to third parties in the event you share such Content. We will disclose your information to such third parties as required to allow you to upload Content to third party websites and applications.



Disclosure to Our Third-Party Partners:  We disclose anonymized user data to third parties who are working with Light to develop Light Products and products or services to be used on, in or with Light Products, such as third-party accessories and applications. When we supply information to these third parties, we require them to use it only for the purpose for which they are working with Light, and prohibit disclosure except at our direction. Light does not share, sell, rent, or trade information it collects from users with any third party partners for their promotional purposes.



Disclosure to Our Third-Party Service Providers:  We disclose your information to our third party service providers (e.g., fulfillment and repair partners, analytics companies, etc.). When we supply information to these third parties, we require them to use it only for the purpose for which they are working with Light, and prohibit disclosure except at our direction and consistent with the services they are contracted to provide.



Legal Disclosures:  Light will (where applicable) disclose information about you and other users of the Light Products with or without your consent, and with or without notice, to comply with a valid legal obligation, for example a subpoena (in the USA) or a court order. We may also disclose this information about you and other users of the Light Products when we reasonably believe that the disclosure of information is necessary to establish, exercise or defend legal claims, protect or defend the property, safety and security of Light, our users, the public and third parties, or to prevent imminent physical harm.



Business Transfers:  We may provide your information to a third party in connection with the sale, transfer or reorganization of some or all of Light or its assets, and any such acquirer or transferee will have the right to use, store and disclose such information subject to the terms of this Privacy Policy.



5.	Your Choices



Our aim is to provide you with clear choices over your information. You may opt out of the automatic collection of  data by Light during the start-up process or at any time in the settings menu.



6.	Data Storage and Security



Data security is very important to us. Your information collected by Light via the Light Products will be collected, processed and secured using reasonable operational, technical and administrative measures.



Light will retain your information for the period necessary to enable you to use the Light Products and to enable Light to establish or respond to any legal claims in respect of the Light Products or this Privacy Policy (and for any longer retention period required by law).



To make a complaint about how we process your Personal Information, please contact us in the first instance using the details set out below and we will endeavor to deal with your request as soon as possible.  This is without prejudice to your right to launch a claim with the Information Commissioner's Office.



7.	How do We Make Changes to this Policy?



We may periodically modify this Privacy Policy. If we make significant changes to the Privacy Policy, we will notify you via electronic mail and/or the Light Products indicating that the Privacy Policy has been changed. By continuing to access and use the Light Products you are consenting to the revised Privacy Policy.



8.	Contact Information



If you have any questions, comments or concerns about this Privacy Policy, please contact us at:



Email address: hello@light.co



Light Labs Inc.

PO Box 800

Palo Alto, CA 94302



If you are a user based inside the European union (including the United Kingdom), the following additional provisions apply:



1.	Transfer of Personal Information Outside the EU



Light is a corporation organized under the laws of the United States.  Certain third parties with whom Light shares your Personal Information (as detailed above) are also based in the USA. Please note that the information you submit to Light or that is collected by Light via the Light Products will be transferred to, and collected, processed, stored and used in the United States.



2.	User Rights



As a user based inside the EU, you have certain rights relating to the Personal Information we process. These include the following.

-	Access to Information.  You have the right to access Personal Information held about you.  Your right of access can be exercised by contacting us using the details set out above. Any access request after the first such request by you will be subject to a fee of 10 (if you are based in the UK) to meet our costs in providing you with details of the information we hold about you.

-	Consent.  You may withdraw your consent to any processing of any Personal Information which is based on your consent (such as the "Automatically Collected Information" set out above), at any time by contacting us using the details set out above (or adjusting the settings on your Light Product, as detailed above).

-	Rectification.  You have the right to rectify any Personal Information held about you that is inaccurate.  Your right of rectification can be exercised by contacting us using the details set out above.

-	Erasure.  You may have the right to erasure of Personal Information held about you, which you can exercise by contacting us at using the details set out above.

-	Complaints.  In the event that you wish to make a complaint about how we process your Personal Information, please contact us in the first instance using the details set out above and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the Information Commissioner's Office.

