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”) collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).

This document focuses on information related to the operation of Level Home products and services, including our related mobile apps (collectively, “Level Products”).

We provide additional details about how we collect and use information from our public websites in our Privacy Policy for Level Home Websites.

In addition to this Privacy Statement, please reference our Terms of Sale which apply to your purchase of Level Products and our Terms of Use which controls the use of this website. By using this site and/or the Level Products, you consent to the terms of this Privacy Statement as well as the Privacy Policy for Level Websites, Terms of Service and Terms of Sale (collectively, “Level Terms”).

Our Pledge:

1. We will be transparent about the different types of information we collect and how we use them.
2. We will ask your permission before sharing your personal information with third parties for purposes other than at your request or to provide Level Products or services in support of Level Products, and to do so only when we think they will provide you with a welcome additional service.
3. We will use best-in-class data security tools to keep your data safe and protect the Level Products from unauthorized access.

Your Permission: Permission for data collection and processing. By using Level Home Products, you agree to allow us to collect and process information as described in this Privacy Statement.

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. Currently the Level Products are not intended to be used outside of the United States but if you choose to use Level 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 Level operates.

What information does Level Product collect?

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

• Setup information you provide
• Contact information
• Direct actions to the device, mechanically and remotely
• Technical information from the device
• Mobile location data
• Bluetooth data

Setup information you provide: When you install a Level Home 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.

Contact information: When you create a Level account, we collect and store your 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 with other individuals your Level Product 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 service 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 the Level app, 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 a your mobile device).

How does Level use the information it collects?

We use this information to provide, develop and improve Level Products , including to make assessments and recommendations about product use. We may use your contact details to send you this information, or to ask you to participate in surveys about your usage of Level Products, and to send you other communications from Level.

We may also use this information in a non-identified form for research purposes and to help us make sales, marketing, and business decisions. For example, we may use aggregated user information about the number of time a front door is open/close a day on average across hundreds or thousands of homes.

We may use service providers to perform some of these functions. Those service providers are restricted from sharing your information for any other purpose.

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. Depending on your location and type of data, Level may process your personal information on servers that are not in your home country.

In what circumstances does Level share my information?

Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the activation and delivery of Level Products without asking you first. We do not rent or sell our customer lists. The following are the limited situations where we may share personal information:

• For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also 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. 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.
• As part of business transitions: 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 the public as required or permitted by law.

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.

What choices do I have and how can I delete my personal 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 Level customer in order to provide you with Level Products. 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.

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.

You can access, amend or delete your personal information from Level’s servers through the controls for your account in the Level Mobile App. Level customers can also request their Level data by emailing privacy@level.co

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 entirely.

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
• Your direct communications with Level

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) and may use the Level Products only under the supervision of a parent or legal guardian and only if they agree to be bound by the Level Terms on your behalf. Level Products do not knowingly collect or store any personal information from anyone under the age of 13.

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 info@level.co