GLOBAL NETWORKING LABS PTE LTD (“Macard”) has designed a home WiFi system, consisting of a combination of WiFi network hardware devices (“Macard Device(s)”) and Macard Device software that can be accessed via the Macard mobile application (the “Application”). This Privacy Notice applies to Personal Data (defined below) collected via the Macard Devices, Macard Application and the online services that we provide to users of Macard Devices and Macard Application(s) (“Services”) (Services together with the Macard Devices and the Application, the “Products”).

We provide additional details about how we collect and use information from our public web sites in our Privacy Notice for Macard Websites.

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Our Privacy Promise (as described in detail in this Privacy Notice):

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• We will be clear about the different types of information we collect and how we use them.

• We will ask your permission before sharing your personal information with third parties in ways not described in this Privacy Notice.

• We will use world-class data security tools to keep your data safe and protect the Macard Devices from unauthorized access.

 

International data transfers: by using our Products and providing us with data, you acknowledge and agree that your Personal Data may be collected, processed and stored by Macard or its service providers in the United States and other countries where our or our service providers’ servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using Products in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, you agree to the transfer of your Personal Data to the United States and other countries where Macard operates.

 

Questions; contacting Macard; reporting violations.

If you have any questions, concerns or complaints about our Privacy Notice or our data collection or processing practices, please contact Macard Customer Support via e-mail at privacy@macard.com. If you want to report any security violations to us, please review our Security team contact information: (https://www.themacard.com/contact).

1. User consent
   By submitting Personal Data through our Products, you agree to the terms of this Privacy Notice, and you consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Notice.

2. A note about children
   The administration, configuration, and management of the Macard Products (e.g. via the Application) is intended for use by adults over the age of 18. We do not require nor knowingly collect any information regarding minor children in order to manage Macard Devices or provide the Services. If you believe that we might have any Personal Data from a child under 13, please contact us at legal@themacard.com.

3. A note to users outside of the United States
   If you are a non U.S. resident, by using our Products and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Notice. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

4. Types of data we collect
   “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data, and may also include Device Data. “Device Data” means product and performance data that are automatically collected when you use Macard Devices and Application(s) to the extent that such data is associated with or linked to data that allows someone to identify or contact you, for example:

   1. performance statistics, including network speeds, network internet service provider (ISP), and other Macard Device data (e.g., temperature, CPU, memory),

   2. network bandwidth usage statistics (i.e. the volume of data transferred and the protocol of packets),

   3. MAC addresses for Macard Devices and connected devices, IP addresses and network SSID and password,

   4. family profile names, device hostnames, firmware data, Application clickstream, Application crash data, WiFi channel usage information, types of connected devices, the association of devices with a specific family profile, and WiFi signals from other WiFi systems in the area.

5. “Anonymous Data” means data that, either in its original form or as the result of anonymization procedures that we perform on Personal Data, is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data as described below.
   We aim to ensure that any Personal Data we have collected is accurate, complete and current as required for the purposes for which the information is used. However, we require your assistance to help us. If we have Personal Data about you that is not accurate, please let us know at the contact information provided above.

   1. Information you provide to us
      We may collect Personal Data from you, such as your first name, last name, e-mail, city, province/state, and telephone number(s) when you register your Macard Device(s) or create an account to log in to our Services (“Account”).
      Our Application lets you store your Application preferences. We may associate these choices with your Account or the mobile device, and you can edit these preferences at any time in our Application.
      When you order or request Macard Products through the Application, we, or our payment processors, will collect all information necessary to complete the transaction, including your name, phone number, credit card information, billing information and shipping information. This information may be shared with third parties who help process and fulfill your purchases.
      If you provide us feedback or contact us via phone or e-mail (for example, for support purposes), we will collect your name, phone number and/or e-mail address, as well as any other content included in the e-mail, in order to send you a reply. When you participate in one of our surveys, we may collect additional profile information.

   2. Information collected via technology

      • Information collected by Macard Devices
        If you use Macard Devices, we will collect Device Data. When you sync or manage Macard Device(s), Macard Device(s) will upload Device Data to our Application(s) and our servers. We use Device Data as described in Section 5 below.

      • Mobile Services
        If you use our Services on your mobile device, including through our Application(s), we may collect your mobile device’s unique device ID number and manufacturer, MAC address, hostname, IP addresses, and how you use the Application(s). This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Application(s) and information about the type of device you use. In addition, in the event our Application(s) crashes on your mobile device, we may receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s). Crash-related information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

      • Broadband Benchmarking Companies
        We use third parties (“Broadband Benchmarking Companies”), to perform speed tests to measure and collect the performance (“Benchmarking Results”) of user networks that are maintained through Macard Devices (“Network(s)”). We use the Benchmarking Results we obtain from these Broadband Benchmarking Companies to improve our Products. The Broadband Benchmarking Companies add anonymized Benchmarking Results to the databases they maintain and may issue reports regarding network performance. The Broadband Benchmarking Companies may also transfer the Benchmarking Results to third parties where required to do so by law, or where such third parties process Benchmarking Results on their behalf. Each Broadband Benchmarking Companies' ability to use and share the Benchmarking Results is restricted by such company's Terms of Use and Privacy Notice. A full list of Broadband Benchmarking Companies is available here.

6. Use of your Personal Data

   1. In general, Personal Data you submit or that we collect from Macard Devices and Application(s) is used to respond to requests that you make, to aid us in serving you better, and to provide the Products to you. Examples of how we use your Personal Data include:

      • Facilitate the creation of and secure your Account on our network;

      • Identify you as a user in our system;

      • Provide and improve products and services;

      • Improve the usability and performance of Macard Devices and the quality of experience when you interact with our Services;

      • Improve the security of Networks maintained through Macard Devices;

      • Troubleshoot problems with Macard Devices;

      • Measure the performance of our users’ internet service;

      • Send alerts, reminders, and other notifications to you (e.g., notification that a device has joined your Network);

      • Tailor our Products to your interests;

      • Perform research and analysis about your use of, or interest in, our products and services;

      • Manage our business;

      • Send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;

      • Send you administrative e-mail notifications, such as security, or support and maintenance advisories; and/or

      • Send newsletters, surveys, offers, and other promotional materials related to our Services and services made available by third parties and for other marketing purposes of Macard.

   2. Creation of Anonymous Data
      We may create Anonymous Data records from Personal Data by using various procedures to remove or obscure information (such as your name, email address, phone number or IP address) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services. We reserve the right to use Anonymous Data for other purposes and disclose Anonymous Data to third parties in our sole discretion.

7. Disclosure of your Personal Data
   We disclose your Personal Data as described below and as described elsewhere in this Privacy Notice.

   1. User consent or direction
      We may share or disclose your Personal Data at your direction, such as when you authorize a third party web client or application to access your Account or when you direct us to share your feedback with a business. When you use OAuth 2.0 to link your Macard Account to a third party application, you are directing us to share certain pieces of your information, including the locations of your connected Macard Devices, the time that a Device was last connected to your Network and which Macard Device it connected with, guest network passwords, confirmation of actions performed by us on your Network (i.e., pausing a Network, turning off an Macard Device light), and help and error responses, with that application. We have no control over, do not review, and cannot be responsible for these third party web clients and applications.

   2. Third party service providers and companies

      • Macard’s Service Providers. We may share your Personal Data with third party service providers and other companies to:

        • provide you with the Services that we offer you, including fulfilling orders, processing credit card payments, or other functions necessary for our business;

        • provide you with additional Services that we offer you through the Macard Secure service, including VPN software, antivirus software, password management software, and other offerings;

        • analyze how our users use our Products and Services;

        • provide marketing services;

        • conduct testing and measure the performance of our users' Networks and of the Products and Services;

        • facilitate creation of Accounts;

        • provide technical support; and/or

        • provide other services, including but not limited to services on behalf of Macard.

      • Your Service Provider. Certain Macard consumers purchase or rent their Macard Devices from third party service providers such as ISPs, telecommunications companies, home security system companies, or professional audio-visual or network system integrators (“Your Provider”). If you purchase or rent your Macard Device from Your Provider, we may share your Device Data and Personal Data with Your Provider in order to enable Your Provider to provide you with customer network support and service enhancements or improvements for the Macard Device(s) and the services that they provide to you. In addition, Your Provider may share Personal Data about you with Macard to enable Macard to provide the Services and service enhancements or improvements for the Macard Products as described in Section 5 above, and, if applicable, to allow Your Provider and Macard to track and reconcile the accounting of any applicable subscription fees for the Macard Secure service. Your Provider may continue to have access to Device Data for Macard Devices that you received from Your Provider even if you no longer continue to receive services from Your Provider. If you no longer receive services from Your Provider but have purchased or otherwise properly retained your Macard Device(s) and intend to continue using your Macard Device(s), please contact customer support using the contact information specified in the “Help” section of your Application (or Macard at legal@themacard.com if you want to disable the sharing of your Device Data with Your Provider.

   3. Affiliates
      We may share some or all of your Personal Data with our affiliates, if any, that are either subject to this Privacy Notice or will use your Personal Data consistent with the practices described in this Privacy Notice.

   4. Corporate restructuring
      We may share some or all of your Personal Data in connection with or during negotiation of any business transaction, including merger, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Notice.

   5. Custom Audiences.
      We may use marketing tools such as Facebook's Custom Audience and Lookalike Audience program that enables us to display personalized ads to consumers with characteristics similar to those of our existing Macard customers. To determine relevant characteristics of our existing customer base, we may process your email address and/or phone number through Facebook’s “hashing” local browser application that converts this information to a string of alphanumeric data that is then sent to Facebook to enable Facebook to identify other Facebook users with similar profile characteristics. You may opt-out of future participation in our Facebook Custom Audience and Lookalike Audience program by sending an email, from the email address you are opting out of, to the email address provided in our contact information above. For your opt-out to be effective, you must: (i) place the following text in the subject line of the email - "Opting Out of Facebook Website Custom Audience Ads", and (ii) in the body of the email, include your name and email address. We will remove your name and email address from all of our future Facebook Custom Audience and Lookalike Audience datasets. In addition, you can use the Facebook advertiser preferences and settings available through Facebook’s account and privacy management features to hide any future ads from Macard.

   6. Other disclosures
      Regardless of any choices you make regarding your Personal Data (as described below), Macard may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Macard or as otherwise permissible by law; (c) to protect or defend the rights or property of Macard or its users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Notice, or our Terms of Service.

8. Third party websites
   Our Application may contain links to third party websites. When you click on a link to any other website or location, you will leave our Application and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for these outside websites or their content. Please be aware that the terms of this Privacy Notice do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

9. Your choices regarding your information
   You can access your information, including your name, email address, phone number, network settings, assigned names and profiles for connected devices, and SSID and password for your network, in the Application. The Application also includes settings that provide you with options concerning notifications.
   We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Products or those of our affiliates. You have the option to decline promotional communications from Macard by changing your settings in the Application at any time. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information above). However, despite your indicated e-mail preferences for promotional messages, we may continue to send you service-related communications, including notices of any updates to our Terms of Use or Privacy Notice.

   1. Location information
      We may request Coarse Location permission from your Android mobile device in connection with making a Bluetooth connection between your mobile device and an Macard Device (e.g. for setup or configuration changes). If you do not want location information collected by us, you can disable location services on your mobile device.

   2. Changing, accessing or deleting your Personal Data
      You may correct any of your Personal Data in your Account by editing your profile within your Account or by sending an e-mail to privacy@themacard.com. You may also update certain categories of Personal Data by editing the information within the Application. You may request a copy of your Personal Data from us, or deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that you will not be able to use your Macard Devices if we have deleted the Personal Data in your Account, and that we may be permitted or required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our backups. We may also retain your information for fraud prevention or similar purposes.

   3. Applications
      You can stop all collection of information by the Application(s) by uninstalling the Application(s) and by unplugging all of the Macard Devices. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

10. Safeguarding your Personal Data
    We take reasonable measures to ensure that Personal Data is kept safe from loss or theft, unauthorized access, use, copying, disclosure or modification. Safeguards include physical, organizational and technical measures appropriate to the sensitivity of the Personal Data.

11. Retention of Personal Data
    We only keep Personal Data for as long as it is required for the reasons it was collected or as otherwise legally required or permitted. The length of time we retain information varies, depending on the Service, the nature of the information, and any business or legal requirements. The retention period may extend beyond your relationship with us. When retaining your Personal Data is no longer required or otherwise permitted, the information is either destroyed, deleted or de-identified.

12. Changes to this Privacy Notice
    This Privacy Notice may be updated from time to time for any reason and the current version applies to all Personal Data that we collect, use and retain. We will notify you of any changes to our Privacy Notice by posting the new Privacy Notice at www.themacard.com/legal/privacy and we will change the “Last Updated” date above. You should consult this Privacy Notice regularly for any changes.

 

California Consumer Privacy Act Disclosures

The Macard Privacy Notices describe the personal information that we collect, the sources from which we collect it, the purposes for which we use it, the limited circumstances under which we share personal information, and with whom we share it. These additional disclosures are required by the California Consumer Privacy Act:

1. Categories of personal information collected. The personal information that Macard collects, or has collected from consumers in the twelve months prior to the effective date of this Disclosure, fall into the following categories established by the California Consumer Privacy Act, depending on which Macard Product is used:

   • identifiers such as your SSID and IP address;

   • personal information such as your name, email address and phone number;

   • age, gender, or other protected classifications, for example if you respond to a customer survey;

   • commercial information, such as purchases of Macard Products and Services;

   • Internet or other electronic network activity information, such as types of connected devices and MAC addresses, ISP bandwidth speeds, and wifi network password;

   • geolocation data, such as the IP address of the network to which your Macard Device is connected;

   • audio or visual information, such as voice recordings when you contact customer service in connection with Macard Products;

   • professional information, for example contact and job title information for technicians installing Macard Devices on behalf of ISPs or other network equipment installers; and

   • inference data, such as the optimal configuration for your network based on peak usage.

2. Categories of personal information disclosed for a business purpose. The personal information that Macard disclosed to the third parties identified in the “Disclosure of your Personal Data” section for a business purpose in the twelve months prior to the effective date of this Disclosure fall into the following categories established by the California Consumer Privacy Act, depending on which Macard Product is used:

   • identifiers such as your SSID or IP address, for example if you received your Macard Product from a service provider such as an internet service provider;

   • personal information, such as your name, email address, or phone numbers, for example if you sign up for an email list that we administer using a third party service provider;

   • your age, gender, or other protected classifications, for example if you choose to participate in a survey distributed by a survey provider;

   • commercial information, such as the details of a product or service you purchased if a third-party service provider is assisting to provide that product or service, or associated customer support, to you;

   • internet or other electronic network activity information, such as if you received your Macard Product from an internet service provider or other service provider that is providing customer support to you;

   • geolocation data, such as IP address of the network to which your Macard Device is connected;

   • audio or visual information, for example if a service provider reviews recordings of customer service phone calls for quality assurance purposes; and

   • professional information, for example if we provide an installation technician’s contact and job title information to the ISP or other network equipment installer that dispatched the technician.

3. Right to Request Access to or Deletion of Personal Information: You may have the right under the California Consumer Privacy Act to request information about the collection of your personal information by Macard, or access to or deletion of your personal information. If you wish to do any of these things, please contact privacy@themacard.com. Depending on your data choices, certain services may be limited or unavailable. If you do not have an Macard account, or if you are an authorized agent under the California Consumer Privacy Act, please email privacy@themacard.com to make your request.

4. No sale of personal information. In the twelve months prior to the effective date of this Disclosure, Macard has not sold any personal information of consumers, as those terms are defined under the California Consumer Privacy Act.

5. No Discrimination. Macard will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.