Privacy Statement for Level Products and Services

At Level, we take your privacy seriously.

This Privacy Statement for Level Home Inc Products and Services (“Privacy Statement”) describes information that Level Home, Inc. and its subsidiaries and affiliates (collectively, “Level,” “we,” “us,” or “our”) collect, use, disclose, and store information relating to the operation of Level-branded products such as smart devices for homes (“Level Products”) and related services, including our home automation services and software, such as our mobile apps and websites (”Services,” and together with the Level Products, the “Level Products and Services”).

This Privacy Statement applies to information relating to users, including Owners and Authorized Users, of the Level Products and Services (“Users,” “you,” or “your”) processed in or through any products or services where this Privacy Statement is linked or referenced and in our offline interactions where this Privacy Statement is referenced. It does not apply to personal information collected and processed by our partners who sell Level Products and Services to you, or by Owners if you are an Authorized User. For purposes of this Privacy Statement, “Owner” means the individual who creates a Level account or enters into a written agreement with Level for the provision of the Services. Owners may include, but are not limited to, owners or managers of a property (including a multifamily or other housing community) where Level Products may be installed. Owners may designate and specify to Level which tenants in specific units of the Owner's property are authorized to access and use the Level Products and Services (“Authorized Users”), and this Privacy Statement will apply to such Authorized Users’ personal information collected from the applicable Level Products and Services.

In addition to this Privacy Statement, please reference our Terms of Sale which apply to your purchase of Level Products and our Terms of Service which controls the use of the Services, including this website (collectively, “Level Terms”). By using the Level Products or Services, you consent to our collection and use of your information as described in this Privacy Statement as well as the Level Terms. If you are an Authorized User, you also agree that the Owner for your property may, to the extent permitted by law, access and use information collected in connection with your use of the Level Products and Services.

What information does Level collect?

In order to provide you with the best user experience, Level collects:

• Setup information you provide

• Profile and contact information

• Direct actions to the device, mechanically and remotely

• Technical information from the device

• Mobile location data

• Bluetooth data

• Cookies and similar tracking information

Setup information you provide: We collect information about each of the Level Products installed at your property. When you install a Level Product, you’ll be asked several questions in order to enable remote operation using a mobile app. For example, we’ll ask for information like your home address or ZIP code, and to upload a photo of your door/home. This information helps us to customize your experience by, for example, showing you actionable notifications when you arrive home.

Profile and contact information: When you create a Level account, we collect and store your name, address, email address and mobile phone number. From that point forward, your email address and/or your phone number will be used for communications from Level. In addition, Level may provide you with the ability to share access to your Level Products and Services with other individuals as additional Authorized Users. We will ask you for the email address or mobile phone number of any such individuals and automatically send an invitation on your behalf. Level stores this information to send this invitation, to register your friend if your invitation is accepted, and to track the success of our invitation services.

Your Level account allows you to provide certain basic profile information like your name and profile photo. Names and profile photos may be shown to others in connection with the Services, like people you share access to your home with.

Direct adjustments to the device: If you operate the Level Product mechanically or remotely via a mobile app, it records and communicates that information to the Level Services so that you may see an updated status of your product.

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with a Level Product, we record your Level Product model and serial number, software version, and technical information such as battery level.

Mobile location data: For a better user experience in Level mobile apps, you may choose to share location data from your mobile device. If you grant this permission, the Level app uses standard location services built into iOS and Android. This data may be processed to enable you to receive notifications when you arrive/leave home.

Bluetooth data: Level Products are Bluetooth-enabled and broadcast an identifying signal wirelessly. This is used to connect with your Bluetooth-enabled devices (such as your mobile device).

Cookies and similar tracking information: Whenever you use Services such as our websites or apps, we may collect information from your browser or device using cookies or similar tracking technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. The information we may collect by automated means may include, but is not limited to, the following:

• Information about the device or browser you use to access the Services that does not identify you directly (such as the IP address, type of device, cookie or device identifier, operating system, and browser);

• Dates, times, and duration of use of the Services (including whether you are a repeat or first time visitor); and

• Information on actions taken before or while using the Services (such as the referring URL, page views, and site or app navigation patterns).

We may also collect some of this information using third-party website analytics tools (such as Google Analytics) that collect information about user traffic on the Services.

How does Level use the information it collects?

We may use your information for the following purposes:

Providing the Level Products and Services: to provide, develop and improve Level Products and Services, including to make assessments about product use and enhance the user experience.

Managing your account and transactions: to manage your account, process payments and transactions, communicate with you, and provide customer service.

Security and integrity: to protect the security or proper functioning of the Level Products and Services, or to protect the safety of our users, employees, other parties, and members of the public.

Marketing and advertising: to send you product recommendations or information about new Level offerings, ask you to participate in surveys about your usage of Level Products, and to send you other communications like newsletters or company updates from Level.

Legal obligations and rights: to comply with applicable legal requirements and industry standards, and to enforce our agreements and policies.

Deidentified or aggregate information: in a deidentified form for any purpose, including but not limited to research purposes and to help us make sales, marketing, and business decisions. For example, we may use and disclose aggregate user information about the number of time a front door is open/close a day on average across hundreds or thousands of homes.

Other uses: in any other ways for which we provide specific notice at the time of collection.

How does Level protect my information?

We use industry-standard methods to secure your information while it is transmitted over your home network and through the Internet to our servers. We also take organizational, technical, and physical measures to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information involved. Despite all reasonable practices, no method of transmission over the internet, and no means of electronic or physical storage, is absolutely secure.

In what circumstances does Level share my information?

We do not share your directly identifying personal information for commercial or marketing purposes unrelated to the activation and delivery of Level Products and Services without asking you first. We do not rent or sell our customers’ contact information. The following are the limited situations where we may share personal information:

• To affiliates: We disclose personal information to our affiliates when it is reasonably necessary or desirable, such as to help provide the Level Products and Services to you or to analyze and improve the services we or they provide.

• For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage. We have agreements with these parties to restrict how they may share your information. For example:

  • Payment and shipping: If you make a purchase through the Services, our third-party payment processors may collect or receive certain personal information about you, including your payment details as well as your name, address, and other personal information. We may also share your information with service providers to deliver Level Products that you order through the Services.

  • Customer service: We may use service providers to provide you with customer service.

  • Technical support: We may use technicians to assist with monitoring our servers for technical problems. These technicians (as well as Level employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-Level purposes.

  • Integrated third-party services: We may also share personal information with retail or service partners to the extent that their servers or mobile apps are integrated with Level Products as part of providing you support for your Level Product.

  • Advertising and marketing: We may use service providers to send marketing or other communications on our behalf. We may also use advertising and analytics providers to provide you with relevant advertising or to measure and analyze the effectiveness of our ads.

• To Owners: If you are an Authorized User, the Owner for your account may be able to see and manage your account and the information associated with it, including your usage of Level Products and Services. This may include the days and times you access the Level Products and Services.

• As part of business transitions: We may share personal information during negotiations in contemplation of a business transaction. Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.

• For legal reasons: We will share personal information with third parties if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process or enforceable government request; (ii) enforce Level policies or contracts, including investigation of potential violations; (iii) detect, prevent or otherwise address fraud, security or technical issues; (iv) protect against harm to the rights, property or safety of Level, our users, or others as required or permitted by law.

• With consent: with your consent and as permitted by law, we may disclose your data to any other third parties in any other circumstances.

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish trends about home entry. This information may also be shared with other users to help them better understand their own patterns compared to others in the Level community, or help us generally improve our system.

If you select an outside party for the purchase, installation or service of your Level Product and share your personal information, we cannot control the collection, storage or sharing of information collected by that party. For example, if you buy a Level Product from a retailer, the retailer may collect personal information as part of the transaction. Or the party that installed the device may retain information that you provided to them to assist them in servicing the device if needed. Always check the privacy policies for any company that collects your personal information.

Online Analytics and Tailored Advertising

We may allow third-party advertising technologies to place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our websites and other sites and (b) report how our marketing content impressions and interactions with these marketing impressions are related to visits to our websites. We also allow other unaffiliated parties (e.g., ad networks and ad servers such as Google Analytics) to serve tailored marketing to you and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. Those parties that use these technologies may offer you a way to opt out of targeted advertising as described below. You may receive tailored advertising on your computer through a web browser. Cookies may be associated with de-identified data linked to or derived from data you voluntarily have submitted to us (e.g., your email address) that we may share disclose to a vendor in hashed, non-human-readable form.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative's (“NAI”) Consumer Opt-Out Link and the Digital Advertising Alliance's (“DAA”) Consumer Opt-Out Link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for Display Advertising or customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that to the extent advertising technology is integrated into the Services, you may still receive advertising content even if you opt out of tailored advertising. In that case, the advertising content may not be tailored to your interests. Also, we do not control any of the above opt-out links and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. If your browsers are configured to reject cookies when you visit these opt-out pages, or you subsequently erase your cookies, use a different computer or change web browsers, your opt-out may no longer be effective.

What choices do I have and how can I delete my personal information?

Account information: Level generally stores your personal information on Level’s servers until you delete or edit it, or for as long as you remain a User in order to provide you with Level Products and Services. In addition, Level may store your personal information to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.

You can access, amend or delete your profile and contact information through the controls available for your account in the Level mobile app. Level customers can also submit requests regarding their Level data by emailing privacy@level.co or calling 1-833-453-8354.

Please note that, for technical reasons, there is likely to be a delay in deleting your personal information from our systems when you ask us to delete it. If you ask us to delete certain information, you may no longer be able to access or use the Level Products or Services.

Level device information: As described above, some information is processed and stored directly on the Level device. Personal information from Level devices is encrypted while it is being transmitted to Level. You can delete the information on the Level device by resetting it to the defaults.

Marketing communications: If we have sent you a marketing email, you may choose not to receive subsequent marketing emails from us by following the unsubscribe instructions in each email. Please note that if you unsubscribe from marketing emails, we may still send you administrative emails regarding Level Products or Services, including, for example, notices of updates to the Level Terms or this Privacy Statement.

Website information from cookies: Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of the features in the Services.

You may opt out of the use of your data by Google Analytics by visiting https://tools.google.com/dlpage/gaoptout and downloading and installing the Google Analytics Opt-out Browser Add-on.

How Level retains data we collect?

Data we retain until you remove it or delete your account

Some data is kept until you choose to remove it or delete your account. We provide you various ways to correct or delete data stored in your Level account. For example, you can:

• Edit your profile information including your name, profile and home photos

• Remove homes and authorized members

• Delete your Level account and directly identifying information associated with it (note that deletion may take up to 45 days)

Data we retain for extended periods for limited purposes

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when Level processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for longer periods of time include:

• Security, fraud & abuse prevention

• Financial record-keeping

• Complying with legal or regulatory requirements

• Ensuring the continuity of our services

• Resolving disputes

• Enforcing the Level Terms and other agreements

Third-party sites and services.

The Services may link to third-party sites. If you click on a link from the Services to a third-party site, you will be taken to a website we do not control. This Privacy Statement does not apply to the privacy practices of that website, which may collect information from you. We are not responsible for third-party websites or their policies. Read the privacy policy of other websites carefully. If you access a third-party website from the Services, you do so at your own risk.

Minors.

Our Services are not intended for use by individuals under 18 years of age (“Minors”). Only individuals aged 18 and older are permitted to act as Owners of Level accounts. Authorized Users must be over the age of 13 (or equivalent minimum age in the jurisdiction where they reside). Minors may use the Level Products or Services only under the supervision of a parent or legal guardian and only if the parent or guardian agrees to be bound by the Level Terms and this Privacy Statement on the Minor’s behalf. Parents and guardians of Minors are responsible for their Minors’ use of the Level Products and Services and should take appropriate precautions to protect Minors, including monitoring their use. Level Products and Services do not knowingly collect or store any personal information from anyone under the age of 13.

International data transfers.

Your personal information may be collected, processed and stored by Level or its service providers in the United States and other countries where our 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. In addition, we may further transfer your personal information outside the United States for the purposes described in this Privacy Statement. By submitting any personal information or by using the website and without limitation to any other rights or obligations we have, you consent to such transfer to, and processing in, the United States and these other countries, and acknowledge that your information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions. Currently the Level Products and Services are not intended to be used outside of the United States but if you choose to use Level Products and Services 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 Level operates.

Additional information for certain states.

If you reside in one of the following states, the applicable Privacy Notice below (“Notice”) also applies to the processing of your personal information. To the extent there is a conflict between the state-specific language below and the provisions above, the provisions below control to the extent of that conflict.

California Privacy Notice

The California Consumer Privacy Act (CCPA) requires that we make certain disclosures to California residents. This California Notice applies to you only if you are a resident of the state of California and only applies to personal information that Level controls as a “business” (as defined in the CCPA). It does not apply to personal information collected and processed by our partners who sell Level Products and Services to you. It also does not apply to information collected about employees, former employees, candidates, or independent contractors. In this California Notice, the terms “personal information,” “sensitive personal information,” and terms in quotations have the meanings set forth in the CCPA.

Categories, purposes of use, and disclosures.

The following table provides information about our practices in the 12 months leading up to the effective date of this Privacy Statement in relation to the categories of personal information that we generally collect from California residents, the purposes for which we use the information, and the categories of third parties to whom we disclose personal information for a business purpose or to whom we “sell” or “share” personal information for “cross-context behavioral advertising.”

We also collect the following categories of “sensitive personal information”: (1) account log-in and password or other credentials allowing access to your account; and (2) precise geolocation of the Level Product.

For more information about each category, purpose of use, and the third parties to whom we disclose information, please see the sections “What information does Level collect?,” “How does Level use the information it collects?,” and “In what circumstances does Level share my information?” above in this Privacy Statement.

Your Choices Regarding “Sales” and “Sharing”: We provide personal information to advertising providers to provide more relevant and tailored advertising to you, and to analytics providers to assist us in understanding how our Users interact with the Level Products and Services. These disclosures may be considered a “sale” of your personal information or “sharing” of your personal information for purposes of “cross-context behavioral advertising” as defined by the CCPA and current regulatory guidance. To opt out of “sales” and “sharing” of your personal information for these purposes, please contact us as indicated below.

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if it is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt out under the CCPA.

Do Not Track: Level currently does not respond to “Do Not Track” signals sent by browsers or mobile apps due to a lack of standardization regarding how that signal should be interpreted. Learn more about Do Not Track.

California “Shine the Light” Law: Under the California's "Shine the Light" law, Civil Code section 1798.83, some California customers may opt out of the sharing of certain personal information to third parties for their direct marketing purposes. We do not share such personal information with third parties for such purposes.

Additional Rights: California law may permit you to request that we:

• provide access to your personal information, including categories of personal information we have collected or disclosed about you and the reason we collected or disclosed such information;

• correct the personal information that we have about you that is inaccurate; or

• delete certain information we have about you.

You may also have the right to receive information about the financial incentives that we offer to you (if any), and the right to not be discriminated against (as provided for in the CCPA) for exercising certain of your rights.

For information about the additional rights you have with respect to your personal information and how to exercise them, please see the section “What choices do I have and how can I delete my personal information?” above in this Privacy Statement.

Certain information may be exempt from such requests under applicable law. For example, we need certain types of information so that we can provide the Level Products and Services to you and for compliance with applicable law.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at privacy@level.co or 1-833-453-8354. If you purchased Level Products or Services from a partner on whose behalf we process your information as a service provider, we will redirect your inquiry to such partner in response to your request.

When you exercise certain rights, we may take reasonable steps to authenticate your identity before fulfilling your request (such as verifying your email address or payment instrument). You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with a signed, written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Privacy Notice for Other States

Depending on where you live, state law may require that we make certain disclosures to you and provide additional rights regarding your personal data. This Notice for Other States applies to you only if you are a resident of such a state and only applies to personal data that Level controls as a “controller” (as defined by applicable state law). It does not apply to personal data collected and processed by our partners who sell Level Products and Services to you. In this Notice for Other States, the term “personal data” or “personal information” has the meaning set forth in applicable state law.

In addition to the rights in the section “What choices do I have and how can I delete my personal information?” above in this Privacy Statement, you can ask us to:

• confirm we are processing your personal data; and

• opt out of processing or sharing of your personal data for online targeted advertising purposes.

If you would like further information regarding your legal rights under applicable state law or would like to exercise any of them, please contact us at: privacy@level.co. Certain information may be exempt from such requests under applicable law. If we deny your request to exercise your rights in whole or in part, you may have the right in some states to appeal the decision. In such circumstances, you can contact us at the email address above with the Subject “Data Privacy Request Appeal” to provide us with information about why you are appealing the decision.

If you purchased Level Products or Services from a partner on whose behalf we process your information as a processor, we will redirect your inquiry to such partner in response to your request.

Can the Privacy Statement be changed?

We reserve the right to change this Privacy Statement from time to time. We will provide notice of any changes on our website or by contacting you. The changes will be effective upon posting on our website.

How can I contact Level?

You can email us at privacy@level.co.