LUCIS Technologies User Information Privacy Policy

 

Effective date: December 15, 2015

 

We, at LUCIS Technologies, respect the privacy of the customers who use our products and services (“Users”). We acknowledge the need for privacy protections over personal information you provide to us. Accordingly, we have written this document to explain what kind of information LUCIS Technologies and its subsidiaries and affiliates (collectively, “LUCIS”) collects and stores, including Personal Information (as defined below), in connection with the operation of Products and Services from LUCIS (collectively, “NuBryte”).

 

This policy covers our Users that have obtained our Products and Services. We have a separate Website Privacy Policy, which covers our website visitors. By using LUCIS Products and Services in any manner, you agree to allow us to collect, use, and share information as described below.

 

By “Products and Services,” we mean the NuBryte Touchpoint, NuBryte Flex, NuBryte mobile app, LUCIS websites, and other products and services offered by LUCIS Technologies. “Services” means NuBryte services that support the NuBryte Touchpoint, NuBryte Flex, NuBryte mobile app, LUCIS websites, and other LUCIS products. “Personal Information” means any information that can be used to distinguish or trace an individual’s identity or any other information that is linked or liable to an individual. “User Information” means the information and data we receive, process, create, maintain, or transmit on behalf of a User when the User uses our Products or Services. Some User Information is Personal Information, but some is not, such as machine data generated by a NuBryte device.

 

I. What information does LUCIS collect, and how does LUCIS use it?

We gather various types of User Information in connection with NuBryte, to provide you Products and Services, including functionality of our products, to personalize and improve our Products and Services, to obtain payment, to provide User and technical support, to allow you to set up a user account and profile, to communicate with you and allow other users to contact you, to fulfill your requests for certain Products and Services, and to analyze how you use NuBryte.

 

The type of User Information that is collected from each device will vary depending on the device type and may include:

• Account information

• Information input during setup

• Environmental information from NuBryte sensors

• Direct security mode interactions with a device

• Video and audio information

• Information from direct and indirect lighting control interactions with a device

• Technical and status information from the device

 

Account Information

We ask for certain information such as your username, real name, address, phone number and e-mail address when you register for a NuBryte account, place or consult a pre-order or order, or if you correspond with us. We may also retain any messages you send through the Service, and may collect information you provide in User Information you post to the Service. We use this information to operate, maintain, and provide to you the features and functionality of the Service. Please refer to our Website Privacy Policy for full details.

 

Information input during setup

We use account-related information in order to provide and market our Products and Services, establish relationships, set up the NuBryte device (as described below), obtain payment for Products and Services, provide User and technical support, and otherwise communicate with users.

 

After connecting your NuBryte Touchpoint panel it will display our Terms of Service and ask a series of questions we call the “Setup Wizard.” We use the information you enter here, and during your NuBryte Account setup, to help you take full advantage of all of the NuBryte features right away. For instance, we’ll ask you what room the NuBryte is installed in so we can help you identify it from others when you have multiple devices installed. We ask you to connect to the Internet so our weather service can look up your IP address and provide real time weather information. We also ask you if your bulbs are dimmable or not to provide you with dimming control and better understand how you prefer to light your rooms during a particular time of day.

 

Environmental information from NuBryte sensors

There are a number of sensors built into NuBryte devices that collect User Information including: temperature, humidity, ambient light and motion. The information collected is used to inform you of the events occurring within your home and help operate connected NuBryte products. For example, when the NuBryte Security Mode is activated, the motion sensor is used to detect any movement in range, and information is relayed to your mobile device via the NuBryte mobile app in the form of videos or alerts. We track the ambient light over time to help us create new smart lighting modes and temperature, and humidity to give you on-screen readings on the NuBryte Touchpoint and app.

 

Direct Security Mode interactions with the device

NuBryte features a Security mode that uses a motion sensor, video camera technology and an alert system to help protect your home and notify you of potential intrusions. To be able to provide this service, we need to record information if and when the motion sensor detects movement, process the information, and then relay information to you via a mobile app notification. We then need to perform a similar process if you decide to deactivate the Security mode to let other users sharing your Account know that the alarm has been deactivated. Keeping a record of security events also allows us to provide the “Alerts Record” in the NuBryte mobile app and Home Report email service.

 

Video and Audio Information

Activating the NuBryte Security mode sets the built-in motion sensor to notify you when motion is detected. When detected, the NuBryte Touchpoint video camera will begin to record audio and video for a maximum duration of 90 seconds. If the correct pin is not entered within 40 seconds, the second alarm will sound and the recording will be securely uploaded to your NuBryte Account on our servers and pushed to the NuBryte mobile app for all members of your NuBryte Account, ready for download and viewing. You can download copies of these recordings by connecting your mobile device to a computer and using licensed software as recommended by your mobile device’s manufacturer to copy these files to an external location. You can delete video files from your Account completely, including the original on our servers, by navigating to Alert History on the NuBryte mobile app and selecting the “Delete” option. We will retain video files on our servers for you to access for a maximum duration of 3 months. After that point they may be deleted, with the free space allocated to newer recordings stored under your NuBryte Account.

 

Direct and indirect lighting control interactions with the device

Every time you turn the light on or off, whether at the NuBryte device itself, via motion detection or through the NuBryte mobile app, we record that information in order keep every NuBryte product and connected App in sync. This allows you to know which lights are in use at any given time. We also use this User Information to provide you with smarter lighting modes and insightful statistics in the Home Report.

 

Technical information and status from the device

NuBryte is an Internet-connected product. This Internet connectivity allows us to react to any issues experienced by our users by identifying the cause and resolving them by updating NuBryte devices over the Internet. To be able to provide this service we need to be able to record User Information such as the number and types of NuBryte devices listed under your Account, their serial numbers, NuBryte current software version, connectivity status and any record of errors encountered.

 

What Information is shared between multiple connected NuBryte Products?

When multiple NuBryte products are installed in the home they are designed to operate as a network, sharing User Information with one another to provide a consistent user experience and in some cases, additional functionality. For example you can check the room temperature in every room where a NuBryte switch is present, from any NuBryte Touchpoint in the home. If the Security mode has been activated and motion is detected in one room, the alarm built into every NuBryte Touchpoint sounds, increasing their volume and the chance of notifying a neighbor or passer-by. In these cases, we record this information as this information is also accessible through the NuBryte mobile app. Other information is only transferred between NuBryte devices and not recorded, such as intercom voice messages. Voice messages are simply broadcast from one NuBryte device to another over the local home network and not stored for further analysis or use.

 

What information does LUCIS collect and store when I connect my LUCIS Product to the Internet or create a LUCIS NuBryte Account?

Connecting your NuBryte product to the Internet will require your permission to join your WiFi network. You will be asked to enter your WiFi network name (SSID) and password at the NuBryte Touchpoint display to grant it access to the Internet. You can choose to do this either during the initial Setup Wizard or any time through the Settings menu. Once entered, this information is saved locally on the product to maintain its Internet connection, but is never stored on our servers. We do however store the IP address and corresponding coordinates assigned to your home network so we can provide you with weather forecasts and software updates as well as allow you to connect to your NuBryte devices from your NuBryte mobile app.

 

When your account is accessed online, we may use technologies such as cookies, web beacons, or scripts to gather information about how you users in your household interact with NuBryte. For example, we will know how many household members access your NuBryte device(s) at your location or access features within the app. We use this aggregated User Information to understand and optimize how NuBryte and the app are used and to provide content and features that are of interest to you.

 

You can register for a NuBryte Account by downloading the NuBryte mobile app. We receive and store any information you provide to us during the account setup and operation. To create a new Account we will ask you accept our Terms of Service and Privacy Policy before entering your email address and creating a password. We will also ask you during the Sign Up process if you’d like to invite any one else by email to join your NuBryte Account, allowing them control the NuBryte devices you have installed. We will send invitation emails out automatically and guide them through a brief registration process. We will store all email addresses registered under your Account and occasionally use them to update you with news related to our Services, the products you own, and any changes to our terms of use or policies, and to monitor the effectiveness of our programs. Email preferences can be managed in the NuBryte Account settings.

 

As noted in the Terms of Service, we do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will respond as described in our Terms of Service, including to delete your personal information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at support@NuBryte.com.

 

When you have both an Internet-connected NuBryte product and have signed up for a NuBryte Account, your products will then begin to send the User Information detailed in this policy to LUCIS. We automatically receive and record User Information on our servers, logs and information bases from your browser, application, services or device(s). While connected, these devices automatically report information to our servers (including information that you may have provided when setting up or configuring that device), which may include Personal Information.

 

Please refer to our separate Website Privacy Policy  to find more information on types of information we collect when you or your invited Account members visit our website, register and use our web hosted Services.

 

II. How does LUCIS ensure the security of my Personal Information?

NuBryte products utilize generally-accepted industry standards for security measures to protect the storage and transmission of your information among NuBryte products, services and networks using security protocols such as SSL and TLS, which protect the confidentiality of information by encryption. We endeavor to protect the privacy of your Account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, are always risks for compromise of the security of user information at any time.

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Your NuBryte Account is protected by a password for your privacy and security. You must prevent unauthorized access to your Account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device. Please notify support if you have reason to believe that your password or Account has been compromised.

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III. Sharing of Personal Information

How does my LUCIS Account or Product(s) interact with third party compatible products or services?

Every time a new, compatible third party product is connected to your NuBryte network, an agreement detailing the information to be exchanged among the devices, service providers and manufacturers and explaining the purposes for usage of the information will be displayed on the NuBryte Touchpoint screen and/ or the NuBryte mobile app during the setup process. The purpose of this step during setup is to seek your permission to allow this exchange of information before adding it to your NuBryte network of devices. You are able to revoke this permission at any time by deleting the product from your Device List within the NuBryte mobile app. If you agree to the terms any NuBryte information that is shared and stored by third parties is then held by terms specified within that third party’s own privacy policy. Any information received by LUCIS under the terms in the agreement will be stored and processed using the same practices as detailed in this User Information Privacy Policy.

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Use of Third Party Service Providers

We use certain third party service providers to host and maintain User Information that we may receive from you. In specific, we use one or more cloud service providers to host User Information stored by our Services and collect and maintain User Information uploaded by NuBryte devices to the Services. In addition, we upload Account information to one or more cloud services providers to maintain and analyze information about our relationships with our Users, undertake marketing campaigns, and provide support.

We enter into agreements with third parties hosting User Information. These agreements bind such third parties to confidentiality restrictions requiring them to use User Information only for purposes of delivering their services to us, not to disclose User Information without authorization, and to adhere to practices at least as restrictive as this Policy.

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How does LUCIS share the Personal Information it collects?

Our guiding principle is to only use the information we collect to further our efforts in creating experiences that enable our users to live a simpler, smarter lifestyle. This means developing and improving our product’s features, understanding what is most important to you as a member of the NuBryte community and finding new ways to deliver exciting and meaningful content to you. To do this, we need to collect the information types detailed in the privacy policy, analyze the information as part of our research and understand where best to focus our development efforts. The findings from this research may be shared in an anonymized, aggregated form with partners of LUCIS, or the public for marketing or business development purposes, to increase the awareness of the benefits NuBryte products can offer. For example, LUCIS may contribute to a report on how smart home products may help reduce energy consumption, providing figures stating the total amount of energy saved by Users using NuBryte products in a specific region, or per User Information such as averages.

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IV. Under what other circumstances might LUCIS disclose the Personal Information it collects?

Here are the other situations in which LUCIS may share your information and the reasons why:

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Information Management and Analysis

User Information is shared over secured, monitored channels internally between relevant LUCIS employees that have been granted certain permissions under strict guidelines to work with and analyze information to find patterns that further our research and product development. Highly personal aspects of the information, such as images from video information, are not a part of this research effort and their access is restricted to relevant LUCIS employees.

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Any service providers LUCIS may use to help store, structure, analyze or aggregate this information are held to strict and legally binding agreements preventing them from using it for any other purpose. In some cases, depending on your location, some or all of this information may be located within a country outside of the U.S. However, it too is managed under this policy.

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Sharing with Third Party Compatible Product Manufacturers or Partners

With your express permission, we may share Personal Information with a third party product manufacturer or partner that offers a compatible service that you wish to add to your NuBryte network, or enroll in to enhance your NuBryte experience. Any information to be exchanged with this third party and LUCIS will be detailed within a separate agreement on the NuBryte Touchpoint, NuBryte mobile app and/ or LUCIS and Partner website. Your agreement to the terms provided is required before any information exchange is processed.

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In the Event of Business Acquisition or Transfer

The User Information collected by NuBryte devices may be defined as an asset and included as part of an acquisition or transfer of ownership of the company, including in connection with a merger, acquisition, reorganization, or sale of assets of our business, or in the event of bankruptcy. In case of such an acquisition or other transfer, any purchaser will be requested to maintain and enforce the privacy policy in place at the time of transfer in order to ensure the continued safeguarding of your information.

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For Legal Reasons

We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons, for example, to respond to legal process, or comply with state and federal laws (or the applicable laws of foreign countries other than the United States). Your personal information may be collected, processed and stored by LUCIS or its service providers in the United States and other countries where our servers reside. As a result, your personal information may be subject to legal requirements, including lawful requirements to disclose personal information to government authorities, in those jurisdictions.

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We reserve the right to access, read, preserve, and disclose any information that we reasonably believe is necessary to comply with law, subpoena, other administrative or judicial process, or court order; enforce or apply our conditions of use and other agreements; resolve legal disputes; or protect the rights, property, security, or safety of Lucis, our employees, our users, or others.

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V. How long will LUCIS store my product and Account information, and can I delete it?

LUCIS stores the User Information outlined in this privacy policy as long as you keep an Account with us. The majority of the information is generated by the NuBryte device itself and automatically encrypted on the device before being uploaded to our secure servers via the Internet and stored under your registered NuBryte Account. To fully delete all information from LUCIS’s systems you first need to perform a device reset to clear the information held on the device’s internal storage. To do this, go to the NuBryte Touchpoint menu, enter Settings > Information and select “Reset Device”.

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VI. Accessing User Information and Making Changes

You will have access to Account information by logging into to your NuBryte account at www.nubryte.com and visiting the Change Profile section of your account. There, you can view, update, and correct Account information. Device-level information, such as room names, can be managed directly in the device’s Settings menu. If you need any assistance in accessing your Account or Settings menu, please contact support, as described below.

 

To delete the information from LUCIS’s servers you will need to delete your NuBryte Account. You can do this by visiting the Support section of the LUCIS Website, logging in to the community using your Account credentials and issuing a new support ticket with “Delete My NuBryte Account” as the chosen subject title. Upon receiving your request, we will clear any information held under your Account and close it, before notifying you that the action has been completed. Copies of some or all of this information may be present in the system for a short amount of time for backup purposes.

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Please note that deleting your NuBryte Account will result in reduced functionality with NuBryte products, including but not limited to:

• Access to the NuBryte mobile app

• Remote access to your devices

• Access to third party devices through NuBryte Services

• Smart lighting modes

• Security notifications and video clips

• Event scheduling

• NuBryte Home Report information

• NuBryte Community access

 

VII. Amendments to this Policy

Please note that this Privacy Policy may change from time to time. We will provide notice of any changes on the website via a new version or amendments, or by contacting you. Your continued use of NuBryte devices, your Account, or the mobile app after such notification indicates your continued agreement to the terms of this Policy as amended. Please review this Policy on our website to review the latest information about our privacy practices for handling user information.

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VIII. Contact Information and Resolving Disputes

If you have any questions about this Policy or our privacy practices, please contact us at support@nubryte.com or by mail to:

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Information Integrity Department 
LUCIS Technologies 
1159 Sonora Court, Suite 302 
Sunnyvale, CA 94086

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If you have a complaint about our User Information Privacy Policy, you may submit a complaint to us at the above contact information. Our privacy team will look into your complaint and provide a response. You will need to provide sufficient information for us to evaluate your complaint and we may ask you to provide additional information as a condition of evaluating your complaint.