Privacy Supplement for SimpliSafe® Active Guard

Last Updated: September 2024

This Privacy Supplement for SimpliSafe® Active Guard (“Privacy Supplement”) incorporates the SimpliSafe Privacy Policy, which is posted at https://simplisafe.com/legal/privacy-policy. Together these privacy statements describe our privacy practices for SimpliSafe Active Guard outdoor protection. Capitalized terms, if not defined in this Privacy Supplement, are defined in the SimpliSafe Privacy Policy. In the event of a conflict, the terms of this Privacy Supplement will control.

NOTE: Privacy laws in your state may impose certain obligations on you and your use of the security camera(s) or other camera-enabled products. You (not SimpliSafe) are solely responsible for ensuring that you comply with any applicable laws when you use such camera-enabled products. For example, you may be required to provide notice (even inside your home) to alert visitors to your home that you are using camera-enabled products that are capable of capturing audio, video, and biometric data for security purposes. Please also consider that recording and sharing a video that involves other people may affect their privacy rights and that it is your responsibility to provide notice and obtain consent as required by applicable laws and regulations.

Scope

SimpliSafe takes your privacy seriously. We believe in protecting your information as well as your person and belongings. This Privacy Supplement describes how your equipment may collect, use, and share audio, video, images, and biometric information to provide SimpliSafe® Active Guard.

As such, this Privacy Supplement applies to information we collect in conjunction with SimpliSafe Active Guard. Other information is subject to our SimpliSafe Privacy Policy.

Additional Terms

SimpliSafe services are subject to: the SimpliSafe Terms of Use, which is posted at https://simplisafe.com/legal/terms-of-use; the SimpliSafe Terms of Sale, which is posted at https://simplisafe.com/legal/terms-sale; and the SimpliSafe Terms of Service, which is posted at https://simplisafe.com/legal/terms-of-service. In the event of a conflict, the terms of this Privacy Supplement will control.

Additional Information

To provide security monitoring for SimpliSafe Active Guard, we may collect and process identifiers (e.g., names, addresses, and device identifiers associated with cameras and accounts); system events, video and audio data, such as images, likenesses, facial features, facial embeddings, predictions from AI models (e.g. motion detection, face detection, face recognition, object detection and reidentification) and other information related to individuals who enter camera fields of view, including but not limited to voice recordings, and images of personal property (e.g., name tags, vehicles, license plates); biometrics for purposes of recognizing individuals by image; and inferences based on such information (such as whether an individual is a frequent visitor or a delivery person).

Additional Processing of Data

If you opt-in to let us use your videos to improve our products services we may use your shared video content to improve our Artificial Intelligence (AI), Machine Learning (ML) and Computer Vision (CV) models, features, and functionality of our products and services and to develop new features or products as discussed further in our AI Video Sharing Addendum at simplisafe.com/legal/ai-addendum. You may opt-out at any time and this is not required to use SimpliSafe Active Guard. 

Biometric Data

You acknowledge and agree you will not use SimpliSafe Active Guard facial recognition features in Illinois, Texas, Oregon (City of Portland), or outside of the United States. If you reside in a location that restricts the collection, processing, or storage of biometric data, you will not be able to enable automatic Face Matching or Familiar Faces in your SimpliSafe app.  

To provide SimpliSafe Active Guard, we are utilizing facial recognition features (referred to as “Face Matching”) in your SimpliSafe app. When Face Matching is enabled, we may disclose your videos and images collected via your equipment with third party service providers to enable Face Matching. In such an event, these third party service providers will only be permitted to access, use, and retain biometric information to provide SimpliSafe Active Guard as described herein and only in a manner consistent with this Privacy Supplement and applicable law.

Unless otherwise stated, if you elect to use Face Matching, we will not sell, lease, share, trade, or otherwise improperly profit from your audio, video, images, or any biometric information. Your biometric information will not be used for any additional purposes, unless we provide you with notice of those additional purposes and gather your consent or unless we are required to make a disclosure by Legal Proceedings, as further described in the SimpliSafe Privacy Policy.

How to Enable, Disable, and Delete Biometric Data

Frame Prediction and Profiles - When one of your cameras enrolled in SimpliSafe Active Guard detects motion, your equipment will automatically transmit video to a service which creates image thumbnails to help illustrate the event on your timeline and enable you to review the event in your SimpliSafe app. You can create a collection of these system generated images and may manually upload images in the SimpliSafe app to aid with identification of an individual (the “Familiar Faces” feature). If you wish to create Familiar Faces, we allow you to add nicknames to your Familiar Faces to help you sort through event videos and assist SimpliSafe Active Guard monitoring agents. If the facial recognition feature detailed below (“Biometric Profiles” section) is turned off or disabled, you can still manually create Familiar Faces and add nicknames. In this case, no biometric information is stored or retained relating to your thumbnail images. You may individually delete Familiar Faces from within the SimpliSafe app or choose to delete all Familiar Faces associated with a particular location.

Biometric Profiles and Embeddings - Where the facial recognition feature (referred to as “Face Matching” in the SimpliSafe app) is available and enabled, we will create biometric embeddings from thumbnails to systematically identify and compare with individuals that are detected by the system. All of your stored biometric embeddings can be deleted at any time in your SimpliSafe app by toggling “Face Matching” off and selecting “Delete Data”. When facial recognition functionality is disabled or unavailable based on location, the system will never create or store any biometric profiles.

If you create a Familiar Face for a child and enable Face Matching, you represent and warrant that you are their parent or legal guardian capable of giving such consent or that you have obtained consent from the parent or legal guardian of the child.

Where required by law, if you create Familiar Faces for a friend, family member, or other person and enable biometric profiles, you represent and warrant that you obtained their consent, such as a written release, to store and use a Familiar Face profile after notifying them how their biometric information is being collected, stored, and used.

When Face Matching functionality is enabled, SimpliSafe may collect and analyze biometric information regarding unrecognized data subjects when analyzing images for matches to Familiar Faces associated with your account.

How we Protect Biometric Data

We use commercially reasonable physical, technical and administrative security measures and safeguards to protect the confidentiality and security of any Familiar Faces that you create as well as biometric embeddings. To the extent that Familiar Faces and biometric embeddings are created we will store, transmit, and protect such information in the same manner that we protect other confidential and sensitive information.

How we Retain and Destroy Biometric Data

If you create a Familiar Face in your SimpliSafe app, we will retain your Familiar Face and any associated biometric embeddings for no longer than is reasonably necessary to provide you SimpliSafe Active Guard, comply with our legal obligations, resolve disputes, and enforce our agreements. 

The criteria used to determine our retention periods includes: (a) the length of time we have an ongoing relationship with our customers and provide services, (b) whether there is a legal obligation to which we are subject, and (c) whether retention is necessary to support our legal positions (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

SimpliSafe Active Guard Video Retention Period

In accordance with our Privacy Policy, we will retain your SimpliSafe Active Guard videos for a maximum of 30 days, unless we are required by law to hold them longer or you grant us specific permission to retain shared video content to improve our products and services. 

To delete shared video content, you may opt-out of Recording Access for AI Improvement in your SimpliSafe app, submit an account deletion request through your SimpliSafe app, or submit a state deletion request through our form posted at https://simplisafe.com/access-delete-info.

Changes to our Privacy Supplement

Our Privacy Supplement may change from time to time, at minimum it will be reviewed on a yearly basis. We will not reduce your rights under this Privacy Supplement without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will send you an e-mail and provide a more prominent notice as we deem appropriate.

Questions and How to Contact Us

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please use this contact form or write to us by US postal mail at the following address:

SimpliSafe, Inc. 100 Summer St, 3rd Floor Boston, MA 02110 Attention: Legal