Privacy Policy

Our Privacy Mission

We are sensitive to the private nature of the information you provide to us over the internet. Our Privacy Policy is designed to maximize your ability to protect your personal, private data while at the same time allowing us to provide you with the best interactive security, energy management, access control services possible for your home, business, or vacation property. This Privacy Policy states our privacy practices for your use of (i) this website and any mobile sites or applications operated by PointCentral (the “User Interfaces”) and (ii) any combination of products and services we provide or that can be purchased or accessed via any User Interface (the “Services”).

If you reside in California, please also see the section below called California Consumer Privacy Act (CCPA) Rights.

PointCentral’s Services are provided by licensed and authorized service providers (referred to as “Authorized Service Providers” or “PointCentral Dealers”) or directly to residential and commercial property managers (“Property Managers”). If you are a customer of an Authorized Service Provider or a tenant or guest at a property with enabled PointCentral solutions, your information will be processed by PointCentral acting as a data processor and your Authorized Service Provider or Property Manager will remain responsible for the handling of any personal information it collects from you and for compliance with any applicable data protection and/or privacy laws. Please read the Privacy Policy carefully.

Information Collection and Use

PointCentral collects and stores certain information from or about you that can be used to uniquely contact, identify, or locate you (“Personal Information”).

When using the User Interfaces, you may provide us with Personal Information including, but not limited to, your name, home or business address, phone number and email address.

When using our Services, you or your Authorized Service Provider or Property Manager may also provide us with certain additional information (e.g., unit descriptions, property size, schedule, mode, automation settings, account information, device settings, and configuration options) in order for us to personalize your services. PointCentral may also receive Personal Information that you have provided to our partners to enable PointCentral to provide our Services.

PointCentral may process information regarding your use of the PointCentral Services, including but not limited to: performance of any security or other device monitored by PointCentral, electrical usage or consumption, heating and cooling information, light or other fixture settings, and usage and alert logs. We receive this type of information from devices that are monitored by PointCentral and your computer or other electronic device through which you may access, browse, download, receive, or otherwise use the PointCentral User Interfaces or Services (each a “Personal Device”), and we may also receive and collect such information from third parties.

Location-Based Information

Some features of our Services, such as thermostat adjustments, and other location-based Services (collectively, “GeoServices”), use location information. Before certain GeoServices information can be used or collected, you must first opt-in to activate these Services. If you enable these features, we will automatically collect and store location information from your Personal Device which is capable of producing location data (e.g., mobile device or GPS device). This location information may include your current location or places you have recently visited. We may also aggregate this information for PointCentral’s internal purposes and to provide information requested by you. If you do not wish for us to collect and store this information, do not enable these features.

Video and Audio Data

When you use a connected doorbell, camera, or other video- or audio-connected device using our Services, you may enable us to record, store and process video and/or audio recordings from your monitoring equipment, subject to your configuration and settings. This may include capturing and emailing to you portions of this data as part of a notification or analyzing the data to identify motion or other events. We may process information from your monitoring equipment so that we can send you alerts. In addition, if you have the recording features enabled, we will capture, process and store video and audio data recordings from your device and you may be able to access those recordings.

Data protection and privacy laws in your country may impose certain responsibilities on you and your use of security cameras, connected doorbells and other devices with recording capabilities. You (not PointCentral) are responsible for ensuring that you comply with any applicable laws. For example, you may need to display a notice that alerts visitors to your home or office that they may be recorded using security cameras and other devices with recording capabilities. PointCentral takes no responsibility for your compliance with applicable law.

Information Sharing

PointCentral will not disclose your Personal Information to any other entity except:

• as is necessary to provide the PointCentral User Interfaces and Services to you;
• to your service provider (also referred to as your PointCentral Dealer), the company through which you subscribed to our Services;
• when you have opted in to share the information with the entity;
• when we need to share the information with an entity who works on our behalf to provide the Services. (These entities do not have any right to use the Personal Information we provide to them beyond what is necessary to assist us;)
• if you are an existing end-user customer, to promote additional PointCentral-supported products and Services to you, either directly or through a third party;
• as necessary in connection with other business purposes; and
• as it is otherwise necessary to disclose as required or permitted by law.

In addition, we may disclose your information when the information has been converted to a form that cannot be used to identify you. It may also be necessary for us to disclose your Personal Information in case of a merger or combination with, or acquisition of a portion of our business by, another company or entity, in which case Personal Information collected by PointCentral would be expected to be one of the transferred business assets.

If you are a guest or tenant in a property with enabled PointCentral solutions, PointCentral may share certain information about your use of the User Interfaces and Services with the Property Manager, including but not limited to: video footage from outdoor cameras or video doorbells, your electrical usage or consumption, thermostat settings, heating and cooling information, and information about the opening and closing of garage doors and property doors and the locking and unlocking of property doors that are enabled with keyless access.

Information Protection

PointCentral has security measures in place to protect against the loss, misuse, and alteration of your information. For example, we protect your information through a unique username and password, and we protect certain sensitive communications with our website through server authentication and secure connections. However, no method of data transmission is completely secure.

Rights and Choices Regarding Your Personal Information

If you are an existing or potential end-user of PointCentral Services and have entered Personal Information directly through our website, you may request to correct or delete your Personal Information by contacting us at privacy@pointcentral.com.

If you are an existing end-user of Services you may view, update, or delete certain Personal Information at any time by following the links at www.PointCentral.com to your profile and contact information pages. These changes will be immediately made to our records. If you wish to stop Services notifications, you may do so through the User Interfaces. For customers of PointCentral Dealers, changes you make to your user profile on the PointCentral User Interfaces may not automatically change the records of your PointCentral Dealer. You should contact your PointCentral Dealer directly to make changes to its records. If you are a California resident, please see the “California Consumer Privacy Act (CCPA)” section below for more information about your rights and choices.

California Consumer Privacy Act (CCPA) Rights

If you are a California resident, then the CCPA may provide you with specific rights regarding your Personal Information.

You have the right to request that businesses subject to the CCPA (which may include your Authorized Service Provider), disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete or correct personal information collected for you, subject to certain exceptions. You also have the right to opt out of a business selling or sharing your Personal Information. You may ask a business to limit its use of your sensitive Personal Information (e.g., biometric information or ethnicity), but know that PointCentral doesn’t use your sensitive Personal Information in a manner subject to that right.  If you choose to exercise your rights, you also have the right not to be discriminated against and will not be charged different prices or provided different quality of services.

End Users of the Services

For end-users of PointCentral Services, PointCentral acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is done on behalf of our business partners (such as PointCentral Authorized Service Providers) in order for us to provide the Services. We do not sell Personal Information to third parties. We do allow third parties to collect Personal Information through our Services and share Personal Information with third parties for the business purposes described in this Privacy Policy.

If you are an end user of the Service, You can exercise your applicable CCPA rights by following the procedures listed for “All Existing or Potential End-Users” above, contacting your PointCentral Authorized Service Provider or contacting us at privacy@pointcentral.com. If you contact PointCentral directly, we may forward your request to your PointCentral Authorized Service Provider. Please note that the CCPA requires us to verify the requests we receive from you when you exercise certain of the rights listed above. We may need more information when we receive your request before taking further action.

Business Contacts and Website Visitors

Sometimes we collect Personal Information when you’re acting on behalf of a company (e.g., as an employee, agent, or contractor) or otherwise interact with PointCentral directly (e.g., visiting the PointCentral website outside of receiving Services from us).

Information we collected from consumers (Categories, Purposes, Sources)

We collect these categories of Personal Information:

• Identifiers — such as name, postal address, email address, or account name.
• Unique and online identifiers – such as internet protocol address or device IDs.
• Commercial information — such as records of products or services purchased.
• Demographic information — such as gender, age, income levels, and language preferences.
• Internet or other electronic network activity information — such as browsing history, search history and information regarding an individual’s interaction with an internet website, application, or advertisement.
• Professional or educational information.
• Location information.
• Online viewing activities (e.g., videos viewed, pages viewed).
• Inferences, such as preferences and behaviors.

We collected the above categories of Personal Information the following purposes:

• Performing our Services.
• Auditing customer transactions.
• Fraud prevention and authentication/ID verification.
• Debugging errors in systems.
• Marketing and advertising.
• Internal research, analytics and development — e.g., user-preference analytics.
• Developing, maintaining, provisioning or upgrading networks, services or devices.

We collected the above categories of Personal Information from the following sources:

• Directly from you.
• Automatically generated information — such as technical, equipment and usage information.
• Your employer.
• From other companies, such as marketing services.

We retain the Personal Information that we collect to achieve the purposes for which the Personal Information was collected. In certain cases, we may need to retain Personal Information for purposes required under applicable law, for tax, accounting, or audit purposes, or for other purposes permitted or required under law.

Disclosures of Personal Information

We may have disclosed each of the above categories of Personal Information with the following categories of third parties who perform services on our behalf:

• Product and services delivery companies.
• Marketing services companies.
• Cloud storage companies.
• Credit reporting agencies.
• Billing and payment processing companies.
• Fraud prevention and authentication/identity verification entities.
• Analytics companies.

We may allow certain third parties (such as online advertising services) to collect your Personal Information via automated technologies. We share the categories of Personal Information listed below for the business and commercial purposes of online advertising and to provide third-party social network features and functionality.

You have the right to opt out of this disclosure of your information, which may be considered a “sale” or “sharing” under California law. Beginning in January 2023, you may opt out of “sharing” or “selling” by setting a browser-level opt-out, the Global Privacy Control, sent by California consumers. You may learn how to set that signal by going to this website: https://globalprivacycontrol.org/.

As described above, we do not directly disclose your Personal Information with third parties for monetary consideration. Our “selling” or “sharing” is instead confined to the context of online tracking, and so we may have “sold” or “shared” the following categories of Personal Information:

We do not knowingly sell or share the Personal Information of minors under 16 years of age.

How to exercise your CCPA rights

You can exercise any of your CCPA rights described in this section by contacting us at privacy@pointcentral.com. We may need to collect additional information about your previous interactions with PointCentral to verify your identity. You may designate an authorized agent to submit requests on your behalf. To submit a request as an authorized agent on behalf of a consumer, please contact us at privacy@pointcentral.com.

Virginia Residents Only

Under Virginia’s privacy law, the Virginia Consumer Data Protection Act, PointCentral acts as a data processor and your Authorized Service Provider will remain responsible for the handling of any Personal Information it collects from you. You should refer to the Authorized Service Providers’ privacy notice for more information on the Authorized Service Providers’ privacy practices or to exercise a right under the Virginia Consumer Data Protection Act.

Cookies and Web Beacons

When you use the User Interfaces or access PointCentral Services using your Personal Device, certain information may be collected by automated means, such as cookies. Information about PointCentral’s use of cookies can be found in our Cookie Policy.

Third Party Websites

For your convenience, some hyperlinks may be posted on the PointCentral website that link to other websites not under PointCentral’s control. PointCentral is not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that PointCentral does not own or control. PointCentral does not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. PointCentral encourages you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website linked to the PointCentral website, even if you reached that site through the PointCentral User Interfaces, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how Personal Information that is collected about you is used and protected.

Visiting Our Site From Outside The United States

If you are visiting our Website from outside the United States, please be aware that your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy. By using our Services, you

understand and consent to the transfer of your information to our facilities in the United States and sharing of your information with the third parties described in this Privacy Policy.

Privacy Policy Changes

We may change this Privacy Policy at any time and from time to time. Any changes to this Privacy Policy will be posted on our User Interfaces. The most recent version of this Privacy Policy is reflected by the version date located below. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party.

California and Delaware Do Not Track Disclosures

PointCentral responds to the Global Privacy Control, as described above. With respect to a different preference signal called Do not Track browser requests, PointCentral adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

Contact Information

If you have any questions, concerns, or suggestions regarding this Privacy Policy contact us at:
privacy@pointcentral.com
Or by mail at:
PointCentral, LLC (“PointCentral”) – Privacy
8281 Greensboro Drive, Suite 100
McLean, Virginia 22102
USA

Last updated: December 30, 2022