Effective Date: October 1, 2018
1. What Information We Collect About You
We collect information about you when you provide it to us, when you use our Services, and when other sources provide it to us, as further described below.a) Information You Provide To Us
We collect information about you when you input it into the Services or otherwise provide it directly to us.
We collect information that you give us by filling in paper forms or data fields on our websites, or by corresponding with us by phone, email or otherwise. This includes information you provide to us when you complete a contact form, register on our website, or subscribe to Life360 Innovations communications, or purchase our products. The information you give us may include your name, year of birth, race and ethnicity, contact information (i.e. shipping address, email address, phone number, email), and contact preferences. To the extent necessary to process a payment, you may also give us certain of your financial information, including credit card information, or information regarding credit history.
b) Information We Collect Automatically When You Use The Services
When you use the Services, we (or a third-party designated by us) may automatically record certain information from your device by using various types of technology, including cookies, "clear gifs" or "web beacons." This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites visited just before or just after using the Service, the pages or other content you view or interact with on the Service, and the dates and times of the visit, access, or use of the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you open, click on, or forward a message. You may limit the automatic collection of certain information by our Service, for instance by disabling the cookies using your browser options. Please be aware that by doing so it may prevent you from using specific features on our Service, such as receiving newsletters. We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Services, such as remembering your information so that you will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Services and third party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Services.
c) Information We Receive From Other Sources
We receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.
• Other users of the Services: Other users of our Services may provide information about you. For example, we may receive your email address from other Service users when they provide it in order to refer you to the Services. Similarly, an administrator may provide your contact information when they designate you as the billing or technical contact on your company's account;
• Life360 Partners: We work with a global network of partners who provide consulting, implementation, training and other services around our products. Some of these partners also help us to market and promote our products, generate leads for us, and resell our products. We receive information from these partners, such as billing information, billing and technical contact information, company name, name, what products you may be interested in, evaluation information you have provided, what events you have attended, and what country you are in; and
• Other Partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with, our Services and online advertisements.
2. How We Use Information We Collect
We take steps designed to ensure that only those employees who need access to your personal information to fulfil their employment duties will have access to it. How we use the information we collect depends in part on which Services you use, how you use them, and any preferences you have communicated to us. We use information we hold about you only for permitted purposes, in accordance with applicable national or local data protection laws and applicable provisions of the European General Data Protection Regulation (GOPR). Below are the specific purposes for which we use the information we collect about you:
• To operate, maintain, enhance and provide all features of the Services, to provide the Services and information that you request, to respond to comments and questions and to provide support to users of the Services;
• To understand and analyze the usage trends and preferences of our users, to improve the Services, and to develop new products, services, feature, and functionality;
• To provide information to competent regulatory authorities in geographies Life360 or its' partners operate, which support various regulatory submissions and reporting requirements;
• To verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of Service policies;
• To review and assess your job application;
• To send you communications; or
• To comply with legal and regulatory requirements, where applicable.
Legal bases for processing (for EEA users)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under the GDPR. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
• We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
• You give us consent to do so for a specific purpose;
• We need to process your data to comply with a legal obligation; or
• If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer, your healthcare professional) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
3. How We Share Information We Collect
a) Sharing With Other Service Users
When you use the Services, we share certain information about you with other Service users. Managed accounts and administrators: If you register or access the Services using an email address with a domain that is owned by your employer or organization, certain information about you including your name, profile picture, contact info, content and past use of your account may become accessible to that organization's administrator and other Service users sharing the same domain.
b) Sharing With Third Parties
• Service Providers: We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis and other services for us, which may require them to access or use information about you;
• Life360 Partners: We work with third parties who provide consulting, sales, and technical services to deliver and implement solutions around the Services. We may share your information with these third parties in connection with their services, such as to assist with billing and collections and to provide localized support. We may also share information with these third parties where you have agreed to that sharing;
• Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to:
a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements,
b) enforce our agreements, policies and Terms of Service,
c) protect the security or integrity of our products and services,
d) protect Life360, our customers or the public from harm or illegal activities, or
e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
4. How We Store And Secure Information We Collect
5. How Long We Keep Information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible:
• Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to reactivate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you;
• Managed accounts: If the Services are made available to you through an organization (e.g., your employer, your healthcare professional), we retain your information as long as required by the administrator of your account; and
• Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
6. How To Access And Control Your Information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations:
• You have the right to request a copy of your information, to object to our use of your information (including for marketing purposes), to request the deletion or restriction of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. Where the Services are administered for you by an administrator (see "Notice to End Users" below), you may need to contact your administrator to assist with your requests first. For all other requests, you may contact us as provided in the Contact Us section below to request assistance;
• Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. Where you have asked us to share data with third parties, for example, by integrating third-party health care providers, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed;
• Access and update your information: If your information is inaccurate or incomplete, you have the right to request rectification of your information;
• Deactivate of your account and or subscription: If you no longer wish to use our Services, you may deactivate your Services account. Please contact firstname.lastname@example.org. Please be aware that deactivating your account or cancelling your subscription does not delete your information;
• Delete your information: You have the right, under certain circumstances, to request deletion or removal of your information from our systems;
• Opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services. You can opt out of some notification messages by contacting us; and
• Data portability: Data portability is the ability to obtain some of your information in a format you can move from one service provider to another (for instance, when you transfer your mobile phone number to another carrier). Depending on the context, under the GDPR, this applies to some of your information, but not to all of your information. Should you request it, subject to applicable laws, we will provide you with an electronic file of your basic account information.
7. Notice To End Users
Administrators are able to: (i) require you to reset your account password; (ii) restrict, suspend or terminate your access to Services; (iii) access information in and about your account; (iv) access or retain information stored as part of your account; (v) install or uninstall third-party apps or other integrations. In some cases, administrators can also: (i) restrict, suspend or terminate your account access; (ii) change the email address associated with your account; (iii) change your information, including profile information; (iv) restrict your ability to edit, restrict, modify or delete information.
Even if the Services are not currently administered to you by an organization, if you use an email address provided by an organization (such as your work email address) to access the Services, then the owner of the domain associated with your email address (e.g. your employer) may assert administrative control over your account and use of the Services at a later date. Please contact your organization or refer to your administrator's organizational policies for more information.
8. Our Policy Towards Children
The Services are not directed to individuals under 18. We do not knowingly collect personal information from individuals under 18. If we become aware that an individual under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that an individual under 18 has provided us with personal information, please contact email@example.com.
10. Contact Us
Life360 Innovations Holdings Inc.,
#1200 - 555 West Hastings Street.
Vancouver, British Columbia, V6B 4N6, Canada
Attention: Audit Committee Chairman