This Notice of Collection of Personal Information was last modified on June 27th, 2023.
This Supplemental Privacy Notice supplements the information in our Privacy Policy and applies solely to California residents. It applies to personal information we collect on or through the Products and Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees or job applicants.
California law, including the California Consumer Privacy Act of 2018, as amended (the “CCPA”), and the California Privacy Rights Act of 2022 (the “CPRA”), require us to disclose information regarding the personal information that we have collected about California consumers.
Table of Contents
I. Categories of Personal Information Collected
B. Marketing Life360 Products and Services
D. Connecting with Social Media
E. Information Collected Automatically Through the use of Tracking Technology
III. Your California Privacy Rights Under the CCPA and CPRA
IV. California Consumer Information Sold in the Last 12-Months
V. How to Exercise My California Privacy Rights
A. Modifying, Correcting, Reviewing and Deleting Your Information
B. Communications from Life360
C. Location and Movement Data Collection and Sharing in the Life360 App
D. Web-Based Personal Information Sales
VII. Third Party Tracking and Online Advertising
IX. California’s “Shine the Light” Law
XI. Changes to this Notice of collection
XII. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS
I. Categories of Personal Information Collected
Depending on your use of our Services, the following categories of personal information may have been collected in the preceding 12 months (as these processing activities are defined under applicable privacy laws, such as the California Consumer Privacy Act “CCPA” and the California Privacy Rights Act “CPRA”):
- Identifiers; such as a real name, user name, account name, account information, ID verification information, telephone number, email address, online identifiers, device identifiers, IP address, mobile device identifiers, shipping address;
- Purchase information; such as payment card number, payment account details, billing address, and other payment information;
- Characteristics of Protected Classifications under state or federal law; such as age, gender, ethnicity, and race;
- Commercial Information; such as products or services interaction, motion and fitness information, and purchase history;
- Internet or Electronic Network Activity information; such as, browsing history, search history, and information regarding interactions with our Products and Services, websites, mobile apps, and/or advertisements;
- Geolocation Information; such as location data derived from IP address or device settings;
- Inferences; such as consumer preferences drawn from the above
If you would like more detailed information about the information we have, shared, sold, or disclosed please see our Service Provider and Third-Party Processing Chart which provides more information about the entities to whom we may disclose your information. This list includes the following information: (i) the name of the third-party service provider or business partner, (ii) the name of the privacy officer, contact information and a link to the third party’s privacy policy, (iii) the purpose of the disclosure and how the information may be used by such entity, (ii) the categories or specific items of information disclosed, (iii) the country to which the information will be transferred or stored, (iv) the timing and method of transfer of information, (v) the legal basis for such sharing, and (v) the amount of time the information will be retained by such third parties.
II. Notice of Collection
We, our service providers and business partners may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):
A. Administrative Purposes
We may use information about you for our administrative purposes, including to:
- Provide the Products and Service to you;
- Measure interest in Life360’s Products and Services;
- Develop new products and Services;
- Ensure the integrity, security and perform internal quality control and optimization of our Products and Service;
- Verify individual identity;
- Communicate about individual accounts and activities utilizing Life360’s Products, Services, and systems;
- Make changes to any Life360 policies;
- Send messages to the email address you provide to us to verify your Account;
- For informational, transactional, marketing and operational purposes, such as Account management, customer service, or system maintenance;
- To process payment for products or services purchased;
- To process applications and transactions;
- To prevent potentially prohibited or illegal activities; and
- To enforce our Terms of Use and this Privacy Policy.
B. Marketing Life360 Products and Services
Life360 may use information, and Individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls from us, as allowed by applicable law, for marketing purposes such as to:
- Provide you with information related to Life360’s or our business partners’ products and services that may be of interest to you;
- Notify you of upcoming special offers/events we believe may be of interest;
- Conduct individual or market research;
- Conduct research and drive marketing analytics;
- Conduct online behavioral advertising;
- Tailor content, advertisements and offers that may be of interest to you;
- Introduce new content, features, Products or Services; and
- For other purposes disclosed at the time that you provide us your information; or otherwise with your consent.
C. Research and Development
We may use information to create non-directly identifiable information that we may use alone or in the aggregate with information obtained from other sources as set forth herein, in order to:
- Help us to optimally deliver our existing Products and Services;
- To develop new Products and Services;
- For research, and internal analysis;
For instance, from time to time, Life360 may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf (all survey responses are voluntary). The survey responses may be utilized to:
- Determine the effectiveness of our Products and Services,
- Perform various types of communications, advertising campaigns, and/or promotional activities.
- Learn more about our members and potential members and their individual and collective needs
If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analytics purposes.
D. Connecting with Social Media
If you use these Social Features the supplemental information provided will allow us to verify information that you have provided to Life360 and to enhance our ability to provide you with information about our business, products, and Services.
These Social Features are operated solely by the respective Social Networks, and their service providers, and we recommend that you carefully read their privacy policies before you decide to use them. We have no control over or access to the information collected, stored or used by such Social Networks, and the information practices of such Social Networks are not covered by this Privacy Policy.
E. Information Collected Automatically Through the use of Tracking Technology
We use information collected through the use of Tracking Technologies (e.g. cookies and web beacons) to:
- Remember information so that you will not have to re-enter it during your visit or the next time you visit our website our use our Services;
- Authenticate your access;
- Keep track of your in-app specified preferences or choices;
- Display a personalized browsing history
- Provide custom, personalized content and information, including targeted content and advertising;
- Record your device’s location and movements;
- Identify and contact you across multiple devices;
- Provide and monitor the effectiveness of our Services and our marketing campaigns;
- Monitor aggregate metrics such as total number of visitors, members, traffic, and demographic patterns;
- Provide specific technical support (diagnose or fix technology problems reported by our members or engineers that are associated with certain IP addresses or User IDs;
- Detect or prevent fraud or other harmful activities;
- Automatically update our mobile application on your system and related devices; and
- Otherwise plan for and enhance our Services.
Examples of these types of uses are identified below and discussed more generally in our Privacy Policy.
III. Your California Privacy Rights Under the CCPA and CPRA
California residents can make certain requests about their personal information under the CCPA and CPRA. Specifically, if you are a California resident, you have the right to request any or all of the following information relating to your personal information we have collected and used in the last 12 months, upon verification of your identity:
Right to Know |
|
Right to Opt-Out of Personal Information Sales |
You have the right to direct us not to sell or share personal information we have collected about you to third parties now or in the future. Additionally, if you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such information sales or sharing. |
Right to Limit the Use of Sensitive Personal Information | You have the right to direct us to limit the use of your sensitive personal information. |
Right to Correct | You have the right to request that we correct inaccurate personal information we maintain about you. |
Right to Request Deletion |
You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions. |
Right to Non-Discrimination |
You have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner. |
“Shine the Light” | California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83). |
Certain information may be exempt from such requests under applicable law. For example, we may retain certain information for legal compliance and to secure our Services. We may need certain information in order to provide our Services to you; if you ask us to delete it, you will no longer be able to use our Services.
IV. California Consumer Information Sold in the Last 12-Months
In the previous 12 months, if you were a Life360 member (excusing information related to our Tile and Jiobit Products) we have sold the following categories of personal information to third party partners and advertising partners for targeted marketing, attribution, analytics and research purposes (subject to your settings and opt-outs): Identifiers, Internet/Network information, Geolocation, Inferences, and Other personal information, including driving event and movement data. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.
V. How to Exercise My California Privacy Rights
We believe in transparency and providing you with the opportunity to make important decisions about how your information is used, processed, stored and shared as outlined our Privacy Policy. If you would like to exercise any of your privacy rights for your Life360, Tile or Jiobit account, please submit a request through the App by making adjustments to the appropriate toggles or making request via your in-App privacy or security settings.
A. Modifying, Correcting, Reviewing and Deleting Your Information
You may modify your account information, update or amend your personal information (e.g. name, email address or phone number), or change your password by logging in to your App, clicking on “Settings” and then “Account” (for Life360) or “Manage Account” (for Tile or Jiobit Apps).
You may review the information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information and the categories of third parties with whom we disclose personal information, or request that your information be deleted by submitting a request as described below. Please note that the information provided via the in-App links described in this section does not include technical information or support records. If you would like to request information related to your support records, please contact us directly at privacy@life360.com).
In the Life360 app, you may:
- Exercise your right to Opt In or Opt Out of App-based personal information sales or sharing by clicking on the “Do Not Sell or Share My Personal Information” link in your in-App Privacy & Security settings and adjusting the personal information sales toggle.
- Request a copy or deletion of your personal information under the “Additional Data Rights” page, then, select “Request Your Personal Information” or “Delete Your Account” to submit your request. We will process your request and send a confirmation email.
In the Tile and Jiobit apps, you may:
- Request deletion of your personal information through the Tile app by clicking on “Settings”, then “Manage Account”, and finally by clicking on “Delete Account” and following the on-screen instructions.
- Request deletion of your personal information through the Jiobit app by clicking on “Menu”, then “Account”, then “Manage Account, and finally by clicking on “Delete My Data” and following the on-screen instructions.
- To exercise your other rights related to the Tile or Jiobit Products and Services please contact us as further described below with your detailed request.
You may also request the closure and deletion of your account by contacting us at privacy@life360.comwith your deletion request. Please include your full name, email address associated with your Account, the service you are using, and a detailed description of your deletion request.
Note: prior to deletion of your Tile account, you may transfer your Tiles to another Tile customer by following the instructions found in our support pages covering the Transfer of a Tile. Tile may only be transferred from or to active accounts.
Please note, we will retain minimum information as required by applicable law, as outlined below in Section VII(F) (Data Retention).
For Tile customers: If you delete your account or other personal information, the location information associated with active Tile Products may still be collected anonymously from other Tile Community members who are running the app and are within Bluetooth range of your device. Any such new location information will no longer be associated with your account (to completely disable this type of information collection we recommend you transfer the Tiles prior to account or data deletion, remove the battery from or disable your Products).
B. Communications from Life360
We may periodically send you promotional newsletters and emails. You have the ability to opt-out of these by following the unsubscribe instructions provided in the emails you receive. Certain communications, like billing information and Service updates are necessary for you to receive, you will not be able to opt out of those communications. For more information about the types of communications Life360 may send, and for detailed instructions on how to opt-out please see the following (note, some jurisdictions may require your consent prior to receiving promotional messages):
- Email and Telephone Communications;
- Mobile Devices and In-App Messaging; and
- “Do Not Track”, Cookies and Web Beacons.
C. Location and Movement Data Collection and Sharing in the Life360 App
As described in Section 2, we collect precise location data and driving event and movement data from your device to provide the Life360 Services, and may share your personal information, including location and movement data, with other Life360 members in Circles you belong to, and with third parties for crash detection, research, analytics, attribution and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings. For more information on how to control these setting please see the following:
- Limit Location Sharing with Your Circle(s);
- Limit Drive Detection;
- Limit driving event sharing with Arity; and
- Disconnect Location Data and Movement Data in Device Settings.
If you no longer want to continue using the Products and/or Services, uninstalling the Life360, Tile or Jiobit app (as applicable), removing the battery from or disable the Products and logging out from our Service will also stop us from collecting your location.
D. Web-Based Personal Information Sales
You may also exercise your Opt In and Opt Out rights related to web-based personal information sales or sharing via all of our website, please click the “Do Not Sell or Share My Personal Information” link in the footer of the website and adjust the toggles as applicable.
Please note these setting must be completed for each browser on each device you use and for each of our websites (Life360.com, Tile.com and Jio.com) separately, and will not affect App-based settings. If you clear your cookies or your browser is set to do so, you will have to exercise the choice again. If you wish to modify how data is collected through the Life360, Tile or Jiobit application, you must do so separately by following the instructions above. If you have not visited our sites, no action is required.
VI. Data Retention
Life360 retains the information we receive as described in this Privacy Policy for as long as you use our Products or Services or as otherwise necessary to fulfill the purpose(s) for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business interests, enforce our agreements, and to comply with applicable laws. Our retention is based upon the amount, nature and sensitivity of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information may dictate different retention periods for the same types of information.
VII. Third Party Tracking and Online Advertising
We utilize third parties to engage in online advertising. These ad networks, social media companies and other third-party businesses collect your personal information directly from your browser or device through cookies or similar tracking technology when you visit or interact with our website, use our apps or otherwise engage with us online. These third parties use your personal information to serve relevant ads on our websites, on other websites or mobile apps, or on other devices you may use, or to personalize content and perform other advertising-related services such as reporting, attribution, analytics and market research. These third-party businesses may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties, including other advertising networks.
Please see our Privacy Policy for more information about how third parties use cookies and related technologies to collect information automatically on our websites and other online services, and the choices you may have in relation to those practices.
VIII. Minors Generally
We do not sell the personal information of members we know to be less than 16 years of age. If you are under the age of 18 and you want to remove your name or comments from our website or publicly-displayed content, please contact us directly at privacy@life360.com. We may not be able to modify or delete your information in all circumstances.
IX. California’s “Shine the Light” Law
California's "Shine the Light" law (Civil Code Section § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please click the “Do Not Sell My Personal Information” link available in the in-App Privacy & Security Settings and adjust the Personal Information Sales toggle.
X. Annual Metrics
California law requires us to compile metrics for the previous calendar year regarding consumer requests and responses. Below are certain metrics for requests we received from all individuals (including California residents) between January 1, 2022 and December 31, 2022.
Request Type | Number of Requests Received | Number of Requests Denied (Due to No Verification) | Number of Requests Verified and Processed | Mean Number of Days for Processing Verified Requests |
Know/Access (requests to know/access) | 21,336 | 16 | 21,320 | 10.3 |
Delete (requests to delete) |
7,472 | 0 | 7392 | 12.4 |
Request Type | Number of Requests Received | Mean Number of Days for Processing Verified Requests |
Opt-Out (request to opt-out of sale of personal information) |
Verified: 1,761,372 Unverified: 6,633* |
3-5 days |
Limit (requests to limit the sharing of sensitive personal information) |
Life360 does not differentiate between regular Opt-Outs and Requests to Limit Sharing, all are treated the same way. |
* Unverified requests are received from automated tools and Life360 is unable to verify both the authenticity and the member making such requests. Life360 takes no action for requests that cannot be verified.
XI. Changes to this Notice of collection
We may update this Notice of Collection from time to time, so please review it frequently. We'll notify you of material changes thirty days before they go into effect. If we are required by the CCPA or CPRA to give you enhanced notice or seek out consent to any such changes, we will do so. Otherwise, changes to this policy will be effective when posted.
If you object to any of the changes to this Notice of Collection or our full Privacy Policy, you must cease using our Products and/or Services, and may request us to erase your personal information. Any information that is collected through your use of our Products or Services is covered by the Privacy Policy in effect at the time such information is collected.
XII. CONTACT US IF YOU HAVE QUESTIONS OR CONCERNS
If you have any questions about our privacy practices, this Privacy Policy, our Products or Services, please contact us at privacy@life360.com or by postal mail:
Life360, Inc.
ATTN: Privacy
1900 S. Norfolk Street, #310
San Mateo, CA 94403
United States
A. Authorized Agents
You may authorize another person (your “agent”) to contact us on your behalf. Authorized agents must submit the request via email to privacy@life360.com and include a signed letter from the Life360 member confirming the agent has permission to submit the request on the member’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the member about whom the request is being made and/or to verify that the member has provided the authorized agent permission to submit the request, and it may take additional time to fulfill agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the Life360 member on whose behalf the request was made. We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.