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Life360 Privacy Policy previous to January 3, 2023

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Life360 Privacy Policy previous to November 4, 2022

Privacy Policy previous to January 3, 2023 

LIFE360 Privacy Policy

This Privacy Policy was last modified on November 4, 2022.

WELCOME

Life360, Inc ("Life360", "we", "our", or "us") is committed to protecting and respecting your privacy.

Life360 operates a service that allows you to speak to and share your location with other users in your family or friendship group (each group, a "Circle"), which we make available through our apps and our website https://www.life360.com (the "Service").

This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Service is available in many countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

This Privacy Policy is therefore made up of two parts:

• Part 1 sets out information applicable to users outside the European Economic Area, Switzerland or the UK; and
• Part 2 sets out information applicable to users in the European Economic Area, Switzerland or the UK.
• If you are a resident of the State of California in the United States, please click here for additional California-specific privacy information.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our Privacy Policy explains how we collect, use, disclose and protect information that is collected through our Service from users outside the European Economic Area,  Switzerland or the UK, as well as your choices regarding the collection and use of information.

This Part 1 of the Privacy Policy was last modified on November 10, 2021.

1. HOW WE COLLECT AND USE INFORMATION

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use.

We collect the following types of information about you:

Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number. We may collect a photo, if you or a Circle member associate a photo with your account. If you want to add a family member’s name to your account, we collect the family member’s name, email address, and mobile phone number. We may also collect billing information when you sign up for Premium service.

Data collected through use of the Service. After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite places and to provide alerts when family members leave and arrive.

Geolocation. We collect your location information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. If you enable the mobile app to use your Bluetooth signal, we may be able to determine location based on nearby Bluetooth-enabled devices, which helps us to improve location accuracy, identify other Life360 users and devices that have been in proximity to each other, and improve location updates for all devices in the Life360 network. Depending on your device settings, we collect location information in the background, even when you are not actively using the app. We collect and maintain location data to provide you the features and functionality of the Service. We may also share location information with our partners, such as Cuebiq and its Partners, for tailored advertising, attribution, analytics, research and other purposes, as described in Section 2 “Sharing of Your Information” below. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see “Your Choices About Your Information” below to learn more.

Driving Event Data. We collect, and may use a third party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. Your mobile device provider may refer to this information as “Motion and Fitness” data (description may vary according to device and platform). We may also share this information with third party partners for marketing, research, analytics and other purposes. If you want to opt-out of the collection of your sensory and motion, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data. Please see “Your Choices About Your Information” below to learn more.

Messages and User Content. We collect information when you message other members of your Circle through use of the service. We may also retain any messages you send to us.

We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Circle, crime alerts in your neighborhood, etc.

Social Media. When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Life360’s website or Service.

Identity verification. In limited circumstances, we may use identity verification services provided by a third-party provider Berbix to verify your age and/or to obtain verifiable parental consent for your child to use the Service. When identity verification is required, we will ask you to upload an image of your valid government-issued ID along with a selfie image. Our identify verification provider will use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." Life360 does not receive the biometric identifier generated from the images. It is generated and held by our identity verification provider until the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than 60 days after your last verification interaction with us.   For identity verification and security purposes, Life360 may have access to the information extracted from the identity scan of the ID document (such as a name and partial driver’s license number) as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, confirm appropriate parental consent, and protect against fraud and misrepresentation.  We do not use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider processes this information on our behalf strictly in accordance with our contractual agreements. Please note this service may not be available in all jurisdictions.

Information from third-party services. We collect information from third party services that you connect to your Life360 account. For example, if you link your Life360 account to a voice assistant platform to enable interaction with our service through voice commands, such as through the Life360 Google Action (“Action”) available on Google Assistant-enabled devices, we will collect the queries and commands applicable to Life360 that you make through the Action or other voice assistant platforms.

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:

• Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
• Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
• Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices athttp://www.google.com/policies/privacy/partners, and view its currently available opt-out options athttps://tools.google.com/dlpage/gaoptout.

We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.

If you prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time. 

We and our third party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.

2. SHARING OF YOUR INFORMATION

Personal Information: We share your personal information with third parties outside the Company and its controlled subsidiaries and affiliates in some circumstances, as follows:

• We share your personal information, including name, email, precise location and driving event data, with others within your Life360 Family and other Life360 circles. Depending on the features and functionality enabled, we may also share other information about your use of the Service with members of your Family Circle, such as whether you have logged in on a new device.
• We may share your personal information, including your precise location data, driving sensor data, unique identifiers or AD IDs and other data with our partners, such as Cuebiq and its Partners, for their marketing and business purposes, including without limitation, to inform and improve tailored advertising, attribution, analytics or research purposes. These third party partners may use this information according to their own privacy policies. Please see “Your Choices About Your Information” to learn how you may be able to limit some third-party data sharing.
• We share your personal information with Arity 875, LLC (“Arity”), which provides driving analytics behavior services to enable us to provide certain functionalities of the Service, such as driving event history and crash detection. We may share geolocation and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device) and application analytics, including IP address and device identifiers, driving event data and information provided by you during your registration of a Life360 account or as part of your use of our Services. Arity uses this information to analyze your driving behaviors, such as speed, change in speed and other aspects of how, how much, where and when you drive in order to predict driving risk and calculate a driving risk score. Arity also uses this information to improve its analytics and predictive driving behavior models and improving its service generally.
  For US users only, Arity may use this information to provide personalized content including targeted advertising, offer discounts, rewards or pricing offers by third parties such as insurance companies, and for other commercial purposes. Please see “Your Choices About Your Information” to learn how you may be able to limit some of this data sharing with Arity. To learn more about how Arity’s use of personal information, please review the Arity privacy policy, which is located at https://www.arity.com/privacy.
• We share personal information with third-party partners that provide certain features and services you may use in connection with our Service. For example, depending on the features of the Service you have enabled, we provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. The third parties that provide Premium service features may ask you for additional information in order to provide the full range of services to you. Any information provided to these third parties will be governed by that third party’s own privacy policy.
• We share personal information with third parties that you have connected to your Life360 account to facilitate the features or services. For example, if you enable the Life360 Action on any Google Assistant-enabled device or use other voice-assistant services, Life360 will respond to any query received through the Action and disclose your personal information we well as the personal information (such as name, current location, and other data) of your Circle members through screen display or audio response. Google and the equipment the Google Assistant is installed on, may record your interactions with the Action and the response data in accordance with your agreements with Google. You are solely responsible for the use of the Life360 Action to access information about your Circle members on your Assistant-enabled devices, including in the case of any unauthorized access to your device by a third party, and for the consequences of enabling the Action on any of your devices.
• Other users may share your personal information in certain circumstances. For example, if a member of your Circle enables the Life360 Action on a Google Assistant-enabled device, your personal information (including name, current location and other data) may be displayed on screen or via audio response on any device with the Life360 Action enabled. This means your information may be available to other individuals who have access to your Circle member’s Assistant-enabled device or who may overhear your Circle member interacting with the Action. To prohibit this data sharing, you must ask your Circle member to disconnect his or her account from the Life360 Action or you can leave the Circle.
• We use the hCaptcha anti-bot service by Intuition Machines, Inc. (“IMI”) on our website to check whether the data entered on our website has been entered by a human or by an automated program. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics (e.g. IP address, how long the visitor has been on the website or app, or mouse movements made by the user). This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website or app with hCaptcha enabled and hCaptcha may take place completely in the background in “invisible mode.” The information collected through hCaptcha is shared with IMI, which processes the information on our behalf. For more information about hCaptcha and IMI's privacy policy and terms of use, please visit the following links:https://hcaptcha.com/privacy/andhttps://hcaptcha.com/terms.
• Any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third party websites.

Other instances in which we may share your information: We may also share your information for business purposes, as follows:

• We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services, and to other third-party partners or service providers who contractually agree to process personal information solely as necessary to provide services or features to our users.
• We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
• We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of Life360, our Users or others.

Life360 is a USA-based organization and we store your personal information in the USA, which may be outside your jurisdiction of residence. Our partners and service providers may also store your personal information outside your jurisdiction of residence. Accordingly, your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such jurisdictions.

Linking Tile Accounts: Tile, Inc., a subsidiary of Life360, creates connected hardware devices that provide peace of mind by helping you keep track of the items you value most. The Tile services allows Tile hardware devices and Tile-enabled partner devices (collectively, “Tile Devices”) to be located using the Tile mobile app. You can learn more about Tile at Tile.com.

Life360 is now pleased to enable Tile customers to locate their Tile Devices within the Life360 app as well. To do so, you may link your Tile account with your Life360 account. Choosing to link these accounts will enable you to view and track your Tile Devices within the map shown in the Life360 App, and will allow your Circle members (if any) to view and track those Tile Devices as well. When you link those accounts, your use of the Life360 Services, and data collected about your Tile Devices will be shared with Life360 and subject to both these Terms of Use and the Life360 Privacy Policy, respectively. Notwithstanding anything in the Life360 Terms of Use or Privacy Policy, and for the avoidance of doubt, locations associated with your Tile devices whether in the Tile or Life360 mobile apps will not be sold or commercialized even in aggregated form. Note that use of Tile Devices, even when linked with your Life360 account, remains subject to the Tile Terms of Service and Tile Privacy Policy.

De-Identified Information:  We may also share your information with third parties in a form that does not reasonably identify you directly.  These third parties may use the de-identified information for any purpose.

3.  HOW WE PROTECT YOUR INFORMATION

Life360 cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4.  YOUR CHOICES ABOUT YOUR INFORMATION

You may, of course, decline to submit any personal information through the Service, in which case Life360 may not be able to provide its Services to you.

Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at [e-mail].

Close Your Account or Delete Personal Information: We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at [e-mail]. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.

Emails and Notifications: You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices).  You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests. 

Location and Movement Data Collection and Sharing: As described in Section 2, we collect precise location data and driving event and movement data (such as accelerometer data, magnetometer data, gyro data, etc.) from your device to provide the Life360 Services, and may share your personal information, including location and movement data, with other Life360 users in your Family Circle or other Circle 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:

• Limit location sharing with your Circle. You may turn location sharing “OFF” for one or more of your Circles through your App settings.  If you turn off location sharing in one or more of your circles, we will not share your location with such Circles; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services, to share your location with the other Circles, or to provide location-based advertising). Note: if you press “Check In” or “Automated SOS” in the App, your location will update in everyone of your Circles even if location sharing is turned off for one or more of your Circles.
• Limit Drive Detection. You can limit the collection and display of location and movement data through the Drive Detection feature in the in-App Privacy settings. When you turn Drive Detection “off,” your location is not visible to your Circles and your location and drive history will not show on Individual or Family Driver Reports. Please note that your Life360 app may not be able to provide all of our Services to you turn off Drive Detection. When Drive Detection is turned “off,” Crash Detection services will be disabled and safety services like SOS Help Alerts and 24/7 Dispatchers will not be available.  
• Limit data sharing with third party data partners through in-App Privacy Settings. To opt-out of Life360 sharing personal information (including location and movement data) with data partners for targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. If you opt-out, Life360 will continue to collect your device location and movement data and to share such data with your Circles and with third parties as needed to support and provide the Life360 services or other services you engage, but we will no longer share data about you with our third party data partners for their own advertising and other commercial purposes. Please note, some third party data partners may continue to send you location-based ads based on your previous location or may approximate your location based on other data.
• Limit driving event sharing with Arity. We share data with our partner Arity to support important App features like driving behaviour and Crash Detection. Arity also uses data for research, to improve its analytics and predictive driving behavior models and improve its performance generally. To opt-out of permitting Arity to use and learn from your data for its own research and to develop and improve its predictive behavior models and products and services generally, you can opt-out through the Driving Services page in the in-App Privacy Settings. To opt-out of permitting Arity to use data for its own commercial purposes, including marketing, advertising, and for US users only to provide and service insurance company products and ads, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security Settings.
• Disconnect Location Data and Movement Data in Device Settings. You may also be able to turn off device location data collection through your mobile device settings.  For example, depending on your mobile device, you may be able to “Turn location services ‘off,’ which restricts access to your device location data. You can also adjust your device settings to withdraw permission for the Life360 app to access device location data and/or motion data (depending on the device type, this may be called “Fitness and Motion” data), and you can also adjust your device settings to limit the app’s access to WiFi and Bluetooth information. Please note that your Life360 App may not be able to provide all of our Services to you if you disable access to location and movement data through your device settings.

Third Party Tracking and Online Advertising: We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices or advertising channels. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through tracking technologies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. These third parties use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

• To opt-out or control third-party tracking and advertising: Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of the use of your personal information to inform and display targeted advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).  You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.    
• Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
• Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
• To opt-out of Life360 sharing data with third parties for advertising purposes. To opt-out of Life360 sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. Please note, some third party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.

You may request access to, or correction of, your personal information by contacting us at [e-mail].

5.  CHILDREN'S PRIVACY POLICY

Life360 takes special precaution to protect the privacy of our younger users.  Life360 does not knowingly collect personal information from children under the age of 13 (a “child”) without verifiable consent of a parent or guardian and the Service is intended to be used by children under 13 only with significant parental involvement and approval.

If Life360 learns that we have inadvertently collected personal information of a child without parental consent, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Service without your consent, please alert us immediately by emailing [e-mail] so that we may delete that child’s personal information from our systems.

By enabling your child to create a user account and permitting your child to use the Service, you expressly agree to the practices described in this Children's Privacy Policy and you consent to the collection, use, and disclosure of your child's personal information as described herein.

Setting up a child account. If a parent wishes to add a user who is under 13 to the Service, we request the Parent provide verifiable consent through one of several methods, such as by verifying the Parent’s driver’s license or by submitting a parental consent form (available here) via mail or email.  The child will then be able to participate in most aspects of the Life360 Service.

Personal information we collect. We take special precautions to collect only as much information as is reasonably necessary for the child to use the Service. As further described in our Privacy Policy above, we collect various types of personal information from all users of the Service. For example, we collect profile information (username, email address and mobile phone number) when a user creates an account and other types of personal information the user may provide during the course of using the Service, such as a nickname, favorite location, and emergency contact information.  We collect information about a user’s device (e.g., IP address, device type/model/manufacture / operating system, and a unique ID that allows us to identify the browser, mobile device or account, such as a UDID, IDFA, Google AdID or similar)  as well as certain usage information about the use of the Service (for example, whether the user opens emails) and we collect analytics data. We collect geolocation data through the device IP address, WiFi, Bluetooth and GPS coordinates available through the user’s mobile device and through technologies and sensors that may be nearby. We also collect driving event data through sensory and motion data sensors in the user’s mobile device (e.g., data from a smartphone’s gyroscope, accelerometer, compass and Bluetooth) in order to calculate and detect driving events such as hard braking, speeding and crash detection. Please review the section of our Privacy Policy called “How We Collect and Use Information” to learn more.

Information sharing. Life360 may share or disclose a child’s personal information our third party vendors, service providers and business partners as described in our full privacy policy, including, for example, with third parties as needed to analyze and detect driving behavior data, perform analytics or otherwise , support the features and functionality of our Service such as crash detection. However, we do not share or sell personal information collected from the accounts of children under 13 for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. Please review the section of our Privacy Policy called “Sharing of Your Information” to learn more about how we share information with our vendors, service providers and others.

Sharing information with other Life360 users. The child’s profile information and location will be shared with other members of the Family Circle and any other Circle the child joins. Please note that if your child joins any other Circles, the child will be able to share his or her location with other members of that Circle and may exchange messages with those Circle members.You are responsible for monitoring your child’s account and location-sharing activity through the Service and for blocking or permitting location sharing features.  

Your Choices.

Contact Us. The Parent has a right to request to review or have deleted the child’s personal information and may withdraw consent for the Service to collect any further personal information from the child. Please contact us at [e-mail] to request to review and/or delete any personal information we have collected from the child, or to withdraw permission for Life360 to collect any additional information from the child. Please also review the section of the Privacy Policy called “Your Choices About Your Information” to learn more about how you may control or turn off certain data collection and sharing features of the Service.

6.  LINKS TO OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

7.  CHANGES TO OUR PRIVACY POLICY

Life360 may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how Life360 will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

8.  YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to you if you are a resident of the state of California (a “consumer”). California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.

Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, address, phone number, email address, unique device identifiers or other similar identifiers;
• California customer records, such as birth date and payment information;
• Commercial information, such as records of services purchased, obtained or considered;
• Internet/Network information, such as device information, logs and analytics data;
• Geolocation data, such as precise location data from your mobile device (e.g., GPS coordinates) or generated based on your IP address;
• Inferences about your interests and preferences, generated from your use of our services; and
• Other personal information, such as driving event and movement data collected from your mobile device, or content or messages you send through the Service.

We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.

Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) third party businesses that provide features or services you may use in connection with our Service; (iv) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, California customer records, Commercial information, Internet/Network information, Geolocation data, Inferences, and Other personal information.

In the previous 12 months, we have sold the following categories of personal information to third party data 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.

Your Rights and Choices.  As a California resident, you may be able to exercise the following rights (subject to certain limitations under law):

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources of the personal information; (iv) the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (v) the categories of personal information we have sold and the categories of third parties to whom the information was sold; and (vi) the business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination 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.

To Submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account.  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

• To exercise your Right to Know or your Right to Request Deletion: Submit a request through the App by clicking on “Additional Information for California Residents” page in your in-App Privacy & Security Settings. Then, select “Request Your Data” or “Delete Your Data” to submit your request. We will process your request and send an email confirmation once your request has been fulfilled.
• To exercise your Right to Opt Out of App-based Personal Information Sales: In the App, click on the “Do Not Sell My Personal Information” link in your in-App Privacy & Security Settings and adjust the Personal Information Sales toggle.
• To exercise your Right to Opt Out of web-based Personal Information Sales: On our website, please click the “Do Not Sell My Personal Information” link in the footer of the website and adjust the Personal Information Sales toggle.   Please note this setting does not affect App-based sales. If you wish to opt out from the sale of data that is collected through the Life360 mobile application, you must opt out separately by following the instructions above.
• To submit your request via email: Alternately, you may submit a request to exercise your California Consumer Rights via email by contacting us at [e-mail] and including your account name and mobile telephone number as well as the consumer right you would like to exercise. We may need to contact you to request additional information to verify your request.  For faster response times, we recommend users submit all requests through the in-App Privacy & Security Settings.

Authorized Agents. You may authorize another person (your “agent”) to submit a California consumer rights request on your behalf. Authorized agents must submit the request via email to [e-mail] and include a signed letter from the Life360 user confirming the agent has permission to submit the request on the user’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the user about whom the request is being made and/or to verify that the user has provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the Life360 user 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.

Additional Opt-Out Choices. Additionally, you may wish to opt out of the sale of your personal information (including Internet/Network Information, Commercial Information and Inferences) by third party advertising networks, social media companies and similar online advertising companies for targeted online advertising purposes.  By visiting here www.privacyrights.info or www.optout.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.   To learn more about how third parties collect information automatically on our Service and the choices you may have in relation to those activities, please see “Third-Party Tracking and Online Advertising section” of our Privacy Policy.

Minors. We do not sell the personal information of California consumers 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 [e-mail]. We may not be able to modify or delete your information in all circumstances.

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.

9.   YOUR NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To exercise your Nevada opt-out rights: In the App, click on the "Do Not Sell My Personal Information" link in your in-App Privacy & Security Settings and adjust the Personal Information Sales toggle. Alternately, you may send an email to [e-mail] with the subject line “Nevada Privacy Rights” and include your account name and mobile telephone number. We may need to contact you to request additional information to verify your request. For faster response times, we recommend users submit all requests through the in-App Privacy & Security Settings.

10.  HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at [e-mail]

Life360
ATTN: Privacy
1900 S. Norfolk St., St # 310
San Mateo, CA 94403

Part 2 – Privacy Policy for EEA and Swiss users

This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access our Service from the European Economic Area, Switzerland or the UK.

This Part 2 of the Privacy Policy was last modified on November 10, 2021.

Life360, Inc is the data controller of the personal information we hold about you.

1.  PERSONAL INFORMATION WE COLLECT ABOUT YOU

1.1  We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service.

1.2  We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

1.3  The table atAnnex 1sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.

1.4  We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.

1.5  The table atAnnex 2sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

1.6  We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

1.7  We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.

1.8  We will store the personal information we collect about you for no longer than necessary for the purposes set out inAnnex 1andAnnex 2and in accordance with our legal obligations and legitimate business interests.

2.  RECIPIENTS OF PERSONAL INFORMATION

2.1  We may share your personal information with the following:

(a)Others in your Life360 Family or other Life360 Circle: we may share your personal information, including your name, location and driving event data, with other users of our Service at your request and in accordance with your settings and preferences.

(b)Third parties for their marketing and related purposes with your consent.Where you have provided consent for us to do so, we may sell your personal information (specifically, your location data, driving sensor data, information about your device, and unique identifiers or AdIDs) to third parties for their marketing and business purposes, including without limitation, to inform and improved tailored advertising, attribution, analytics or market research purposes.

(c) Serviceproviders, business partners and advisors:we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, bot detection, web hosting, or providing analytic services.

(d)Third parties that provide features you use in connection with the Services:With your consent or on your instruction, we share personal information, including contact information and location data, with third-party partners that provide certain features and services you elect to use through or in connection with our Service. For example, we may provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. Similarly, we may share personal information with third parties that you have connected to your Life360 account to facilitate the features or services, such as Google if you have enabled the Life360 Action on any Google Assistant-enabled device. Any information provided to these third parties will be governed by that third party’s own privacy policy.

(e) Purchasersand third parties in connection with a business transaction:your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(f) Lawenforcement, regulators and other parties for legal reasons:we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Life360, its users or others.

2.2 Annex 1andAnnex 2contain further information about some of the parties with which we may share your personal information.

2.3 We may also share your geolocation and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device) and application analytics, including IP address and device identifiers, driving event data and information provided by you during your registration of a Life360 account or as part of your use of our Service s with Arity 875, LLC ("Arity"), which provides driving analytics behavior services to enable us to provide certain functionalities of the Service, such as driving event history and crash detection. Arity uses this information to analyze your driving behaviors, such as speed, change in speed and other aspects of how, how much, where and when you drive in order to predict driving risk and calculate a driving risk score. Arity is a data controller of this personal information, and processes it to the extent necessary for its legitimate business interests, namely improving its analytics and predictive driving behavior models and improving its service generally, as further described in their privacy policy, which can be found athttps://www.arity.com/privacy/. Please see “Your Choices About Your Information” to learn how you may be able to limit some of this data sharing with Arity.

3.  YOUR LOCATION

3.1 We collect information about your location in order to provide you certain functionalities of the Service.

3.2 We will collect your location where it is necessary for the purposes of providing you with the location-based services features of the app as well as for the legitimate interests of Life360 or our business partners, such as for data analytics into safe driving modelling. Where you have given us your consent to do so, we may also sell your location data to third parties for marketing and research purposes.

3.3 You can turn off location sharing in one or more of your Circles – if you do so, we will continue to collect your location information in order to provide you the Service. You can withdraw your consent  sharing your location with third parties for advertising purposes through the in-app Privacy & Security settings.

3.4 You can also stop sharing your location with us at any time by updating the settings on your mobile device to limit the app's access to your location information. Please note, however, that we may not be able to provide all of the functionalities of our Services to you if you disable access to location data.

3.5 If you no longer want to continue using the Service, uninstalling the Life360 app or logging out from the Service will also stop us from collecting your location.

4.  MARKETING MESSAGES AND NOTIFICATIONS

4.1 From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

4.2 We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.

4.3 You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

4.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.

5.  TARGETED ADVERTISING

5.1 We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices you may use. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, and information about your use of third party applications, and may combine this information with information they collect directly through tracking technologies or that they receive from other partners, both online and offline, so that they may recognise you across various devices you use, including computers, mobile devices and Smart TVs.

5.2 Where you have consented to us doing so, we may also share your precise geolocation data with advertising partners. We and our advertising partners use the information we collect about you to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

5.3 To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, athttp://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices.

5.4 You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.    

5.5 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out from receiving interest-based ads on that specific device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each device you use.

5.6To opt-out of Life360 sharing data with third parties for advertising purposes. To adjust your data sharing preferences and to opt-out of Life360 sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out or adjust your preferences through the Data Platform page in the in-App Privacy settings. Please note, some third-party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.

6.  STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

6.1 Security. We implement appropriate, commercially reasonable technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

6.2 International Transfers of your Personal Information. As we are located in the USA, any information we collect from you will initially be collected and stored in the USA. If you are in the EEA, Switzerland or the UK, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with applicable EEA and UK privacy law and this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.

6.3 Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union countries (including Lichtenstein, Norway and Iceland) and Switzerland transferred to the United States pursuant to the Privacy Shield ("Privacy Shield"). We have certified that we adhere to the Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement and liability ("Principles") with respect to such data. If there is any conflict between the policies in this policy and the Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. As of September 2020, the E.U.-U.S. Privacy Shield has been invalidated. Nonetheless, we have committed to adhere to these Principles with respect to the protection of personal data to ensure that your personal information is treated securely and in accordance with applicable laws.

6.4 Onward Transfer.Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage. In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

7.  USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

7.1  In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a)Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv) a copy of the personal information we hold about you.

(b)Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c)Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d)Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e)Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f)Right to object.You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

7.2 If you wish to exercise one of these rights, please submit your request through the GDPR Rights for EU Users section of your in-App Privacy Settings and click on the option to “Request my Data,” “Delete my Data,” or “Reset Your Data Sharing Settings,” respectively.

7.3 You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection and sharing of your driving event data and movement data, by updating your in-App Privacy Settings. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of motion data or driving event data.

7.4 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available athttp://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8.  CONSENT

8.1 We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.

8.2 We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.

8.3 If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.

8.4 Where we share your personal information with your consent with third parties for marketing and related purposes, you may withdraw consent at any time via our in-app Privacy Centre.

9.  COOKIES AND SIMILAR TECHNOLOGIES

9.1 Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.

9.2 Please see our for more information about the cookies we use on our website, and how to manage cookies.

9.3 Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

10.  JURISDICTION AND ENFORCEMENT

10.1 As part of our participation in the Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

10.2 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available athttp://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

11. CONTACT LIFE360 AND RECOURSE

11.1 In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at [e-mail].

11.2 In the event that you are concerned about how personal information you have provided to Life360 has been used, please address your inquiry or complaint first to us at the address listed above. Life360 takes all concerns about privacy and use of personal information very seriously, and shall endeavour to reply to you within 45 days of receiving a complaint.

11.3 We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism provided by JAMS. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information and to file a complaint. This service is provided free of charge to you.

11.4 If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshieldfiling.htmlfor more information and to file a complaint.

12.  LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

13.  OUR POLICY TOWARDS CHILDREN

13.1 The Service may only be used by children with the consent of a parent or person with parental responsibility over the child.

13.2 The age at which children need parental consent varies between EEA Countries. Please refer toAnnex 3to verify the minimum age at which children no longer need consent to use our Service (the "Minimum Age").

13.3 If you would like to grant your child access to the Service, you must provide consent through one of our available consent mechanisms, for example, by verifying your government-issued identity document (not available in all jurisdictions) or returning the consent form available athttps://www.life360.com/pdf/consent.pdfby mail or email using the contact details at the end of this policy.

13.4 We will use the personal information of users under the relevant Minimum Age as set out in this privacy policy. We do not, however, use or share personal information collected from accounts of children under the Minimum Age for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. We also do not contact, or permit third parties to contact any children under the Minimum Age who access or use our Service. However, other users with whom the child has added to his or her Circles will be able to contact the child.

13.5 If you become aware that your child has provided us with personal information without your consent, please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

13.6 If you would like to review or delete any personal information we have collected from the child, or to withdraw permission for us to collect any information from the child, please contact us [e-mail].

14.  CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

15.  NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

16.  CONTACTING US

16.1 Please contact [e-mail] if you have any questions, comments and requests regarding this Privacy Policy.

16.2 If you have any questions about the Arity services, please review the Arity privacy policy atwww.arity.com/privacy/or contact Arity [e-mail].

_________________________________________________________________

This Tile Privacy Policy was last modified on December 31, 2019.

Tile Privacy Policy

Tile is designed to make life easier and less stressful. This policy describes what information we collect from you and how we use it to accomplish that mission.

We take your privacy as seriously as you do, and because of that we take great care to collect only the information necessary to provide you with the best possible Tile experience.

As you review our policy, keep in mind that it applies to Tile Inc.’s (“Tile”, “We”, “Us”) website, mobile app, help center, and all other associated services that we provide (“Services”).

1. Information Tile Collects

The information Tile collects depends on what Tile services you use and how you use them. Please see below for more details. Note that failure to provide necessary information when requested may result in you not being able to fully utilise our Services.

A. Placing an order

i. Contact Information

When you place an order on our website, and otherwise when needed to respond to a specific request, you’ll need to provide an email address, a first and last name and/or a shipping address. In some cases, we may also require your phone number.

ii. Payment Information

In order to complete your order on our website, you’ll need to provide payment information, such as your credit card or PayPal account. This information is needed in order to process your order and is not stored on our servers.

B. Registering for the mobile app

You’ll need to use a valid email address and create a password to create an account for Services on the Tile app. You can choose whether or not you’d like to provide your first and last name.

We do not identify you personally to other users or make your account information available to any third parties in any way that could identify you without your prior consent.

C. Connecting with Social Networks

When you create a Tile account, you may choose to connect and interact with a third-party social networking service (“Social Network”). If you decide to interact with a Social Network when using our Services, we are permitted to collect information that you have already made public on your Social Network account. You can manage this information in the privacy settings of each Social Network.

D. Information from Your Use of the Services

i. Tile ID, Name, and Photograph

When you activate a Tile using the Tile app, that Tile’s unique identifier (or Tile ID) will be associated with your account. If you choose to name your Tile or add a photo of it, this information will also be associated with your account.

ii. Location Information

Tile is designed to tell you where your items are. In order to do that, it’s necessary to collect data about your location. We use the term “Location Information” to refer to the combined location data of your phone or device, and your Tiles.

While the app is running on your device, it periodically transmits your Location Information. This allows us to show you, on your map, the last place your Tile was seen by your device (“Last Place Seen”). It is one of the primary ways Tile helps you find your lost items.

Tile normally only displays the latest Location Information update for each of your Tiles in your app, to provide the Last Place Seen. For Tile Premium users, Location Information for each Tile is displayed in your app for up to 30 days, to support the Location History feature. In both cases, Tile does this so you can find the most recent Location Information for your Tiles, in case you lose them.

Location Information is archived separately from your account data in a way that, alone, it is not associated with your account or registration data using a process called pseudonymization. Tile keeps this archival data so we can answer general questions unrelated to any person, such as “How many Tiles were in London in 2016 versus 2017?”

We may also collect and update Location Information for your Tile(s) from other Tile users who are running the Tile app or from other third parties that are using an app or device that has integrated the Tile functionality (each, a “Tile Finder”) within Bluetooth range of your device. We do this to provide you with the most recent and accurate location of your Tiles, even if they are out of your devices’ Bluetooth range. These updates are fundamental to the Tile Community, which allows Tile Finders to help each other find their lost Tiles. Likewise, your app may anonymously help other community members find their Tiles! The Location Information is reported to Tile owners anonymously and does not identify the owner of a Tile to others and vice versa.

If you use a computer, phone, or other device to visit our website or help center, we use the IP address of that computer or device to determine an approximate location. We do this so that we can provide you with a better, more personal customer service experience.

We use your Location Information to provide the Services and may use your Location Information to promote the Services or provide you with offers. However, your Location Information is never shared with other users unless you choose to share it through our Services.

iii. Mobile And Windows Application Usage Information

We collect information about how, and how often you use our Services, including on our mobile and windows applications. For those using our mobile application, we also collect certain information that your mobile device sends when you use them for Services. This includes information such as your device’s model, operating system type and version, and the dates and times of your requests. We use this information to provide you with optimal services and support, and to collect statistics that help us understand our user base.

D. Information Collected Through Tile’s Support Services

We provide support services via live chat on our website, email request submissions, recorded outbound telephone calls and direct email. We collect any information you may choose to provide to our customer care team in the process. This includes, but is not limited to: your name, email address, phone number, and mailing address. We may use and process your information, including Location Information, to handle your support request and provide you with the best support possible. You may also choose to submit a diagnostic report to Tile’s support team for troubleshooting purposes

E. Human Resources Data

Tile collects information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.

We acquire, hold, use and Process Human Resources Data for a variety of business purposes including: workflow management, including assigning, managing and administering projects; human Resources administration and communication; payroll and the provision of benefits; compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs; job grading activities; performance and employee development management; organizational development and succession planning; benefits and personnel administration; absence management; helpdesk and IT support services; regulatory compliance; internal and/or external or governmental compliance investigations; internal or external audits; litigation evaluation, prosecution, and defense; diversity and inclusion initiatives; restructuring and relocation; emergency contacts and services; employee safety; compliance with statutory requirements; processing of employee expenses and travel charges; and acquisitions, divestitures, and integrations.

F. Information from Other Sources

We may receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an App Store or Social Network, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through App Stores or Social Network accounts may include your name, your Social Network user identification number, your Social Network user name, location, gender, birth date, email, profile picture, and your contacts on the Social Network. This supplemental information allows us to verify information that you have provided to Tile and to enhance our ability to provide you with information about our business, products, and Services.

2. Cookies and Other Web Technologies

A. Cookies

Cookies are small text files that are placed on your computer’s hard drive or onto your mobile device’s memory -- if your browser is set to accept cookies. Like many other online services, cookies and other tools like them help us collect and understand how you use our services.

Although most internet browsers automatically accept cookies, you can change your settings or use third-party tools to prompt you before accepting cookies from the websites you choose to visit, or to refuse cookies altogether. You can even delete them through your browser. Most browsers also have settings to prevent them from accepting new cookies, to notify you when you receive a new cookie, or to delete or disable cookies altogether. Some parts of our Services may not work for you if you disable cookies.

B. How We Use Cookies

We use cookie technology in various ways to help make it easier for you to use our Services. For example, we use cookies to remember you when you return to our website, identify you when you sign-in, authenticate your access, keep track of your in-app specified preferences or choices, tailor content to you or geographic region, display a personalized browsing history, and/or to provide specific technical support.

We may also use cookies to gauge site usage, conduct research and diagnostics to improve the content we provide you, our products and services, and to help us analyze general web traffic.

The cookies we use expire after they have fulfilled their purpose. Some cookies expire when you close your browser (i.e., session cookies) or after a set period of time (i.e., persistent cookies).

C. Web Beacons

Web beacons (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s hard drive, web beacons are typically embedded invisibly on web pages (or in an e-mail).

D. Do Not Track

While our website and the Tile app at this time do not recognize automated browser signals regarding tracking mechanisms, such as "do not track" instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser, as indicated above.

3. Collection of Your Information by Third-Party Services

Sometimes Tile uses third-party service providers. These third-party service providers may place cookies on your computer's hard drive or your mobile device's memory or use web beacons to collect or receive information from the Services and elsewhere on the internet and use that information to provide analytics and to target ads on Tile's behalf.

A. Web Analysis Services

We may use third-party web analysis services which use cookies or other web technologies to collect usage information, matched to an IP address, to help us analyze how our users use our website and some portions of the Tile app. We collect this information in order to improve overall experience of our Services for our users.

We utilize Google Analytics, a service provided by Google, Inc. to gather information about how users and visitors engage with our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can choose not to be included in Google Analytics at https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en.

These outside services may also collect information about your use of other websites over time. Since we do not link any information that you provide to us within the app to the information we store within the third-party analytics software, this additional information is stored in a way that does not directly identify you.

B. Social Plugins and Social Widgets

We may use social plugins, widgets and other features (each, a “Social Feature”) that are made available by and/or access third-party Social Networks. These Social Features allow these Social Networks to place cookies on your browser and to collect certain information, which may be associated with your name and personal Social Network account.

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.

If you do not wish to associate any information collected via the plugins, widgets and/or other features with your personal Social Network account information, you should refrain from using these Social Features and logout from your Social Network account before visiting our Services.

C. Third-Party Payment Processing

When you purchase a Tile, we process your payments through a third-party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and Social Networks such as Facebook. The third-party application may collect certain financial information from you to process a payment on behalf of Tile, including your name, email address, address and other billing information.

4. We Are Not Responsible for Content on Third Party Websites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service, or that is collected by a Third-party Service, is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

5. We May Use and Disclose Your Information to Provide, Improve, and Promote Our Services

A. How We Use Your Information

We may use your information to provide you with a better service, improve the quality of our products and Services, and promote our Services. We use and process your information, including Location Information, to create anonymous, statistical and aggregated data reports where individual users are not identified. The specific purposes for our acquisition, hold, use, and processing of your information include:

i. To Provide Products, Services, or Information Requested

Tile may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to: generally manage individual information and accounts; respond to questions, comments, and other requests; provide access to certain areas, functionalities, and features of Tile’s Services, including personalization; and contact you to answer requests for customer support or technical support.

ii. Administrative Purposes

Tile may use information about you for its administrative purposes, including to: measure interest in Tile’s Services; develop new products and Services; ensure internal quality control and optimize your experience; verify individual identity; communicate about individual accounts and activities on Tile’s Services and systems, and, in Tile’s discretion, changes to any Tile policy; send email to the email address you provide to us to verify your Account and for informational, transactional and operational purposes, such as Account management, customer service, or system maintenance; process payment for products or services purchased; process applications and transactions; prevent potentially prohibited or illegal activities; and enforce our Terms.

iii. Marketing Tile Products and Services

Tile may use information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Tile may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include: to tailor content, advertisements, and offers; to notify you about offers, products, and services that may be of interest to you; to provide Services to you; for other purposes disclosed at the time that individuals provide information; or otherwise with your consent.

You may contact us at any time to opt out of the use of your personal information for marketing purposes, as described in Section 9 below.

iv. Research and Development

Tile 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 or develop new products and Services. For instance, from time to time, Tile 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, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. 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 analysis purposes.

v. Direct Marketing

Individuals who provide us with personal information may receive periodic emails, newsletters, mailings, or phone calls from us, as allowed by applicable law, with information on Tile’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the individual by following the instructions further below.

vi. Australian Users

In Australia, we will only use and disclose your personal information for the purposes of marketing Tile Products and Services or services of third party organizations where you have consented to us doing so, or as otherwise permitted by law.

vii. Services via Mobile Devices

From time to time, Tile may provide Services that are specifically designed to be compatible and used on mobile devices. Tile will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, Location Information, mobile carrier, and the operating system of your device. Mobile versions of Tile’s Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Tile may enable individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit information to Tile to enable individuals to access accounts and to enable Tile to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Tile may use personal or non-identifiable information transmitted to Tile to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Tile provides.

viii. Anonymous and Aggregated Information Use

Tile may use information about you to create anonymized and aggregated information. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Tile may use such anonymous or aggregated information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Tile and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

ix. Sharing Content with Friends or Colleagues

Tile’s Services may offer various tools and functionalities. For example, Tile allows you to provide information about your friends through our referral services, such as “Refer a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Tile or any other third parties for any other purpose. You agree that you have that person’s permission to provide us with that information and for us to use it for this limited purpose.

x. Other Uses

Tile may use information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, ensuring the integrity and security of our services and systems, or any other purpose disclosed to you at the time you provide information or with your consent.

B. How We Disclose Your Information to Third Party Service Providers

Tile uses third-parties, including service providers and software solutions, including web hosting and other cloud based services, to provide you with the best possible experience. We may share your information with our third-party service providers or affiliates (e.g. cloud-based and hosting services, partners, technical service providers, consultants, mail carriers, communication agencies and customer support providers) in order to provide, improve, and promote the Services on our behalf.

For example, we may disclose information to our service providers in order to enable them to communicate with you on our behalf. We may also disclose information to platform providers, such as Facebook, in order to permit such providers to serve ads and promote the Services on our behalf on such platforms. To the extent possible, your personal information will be stored in hashed or obfuscated form.

The Services may also enable you to share your information with our third-party partners (“Partners”) in connection with the products and services offered by such Partners, with your permission. Any information shared with a Partner will be subject to the Partner’s then-applicable privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Partner. To protect your information we recommend that you carefully review the privacy policies of all Partners before sharing any information.

We will not share your personal information with independent third parties other than in the circumstances discussed above without your consent.

C. How We Use De-Identified Information

We may share with third parties, including advertisers and service providers, anonymized, aggregated data we collect about you and other users, such as de-identified demographic information, de-identified Location Information, and information about the computer or device from which you access the Services, or the results of hashing your email address.

D. Data Retention

Tile retains the information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

E. Privacy Shield

With respect to onward transfers to agents under Privacy Shield, Privacy Shield (as may other applicable laws) requires that Tile remain liable should its agents process information in a manner inconsistent with the Privacy Shield Principles.

6. We May Use and Disclose Your Information for Our Protection and the Protection of Others

A. How We Use Your Information

We may use and process your information including Location Information to prevent fraud, misappropriation, infringements, identity theft, and other illegal activities and misuse of our Services.

B. How We Disclose Your Information

Like other companies, we may disclose your personal information to government or law enforcement officials or private parties as we, in our sole discretion, believe is necessary to (i) comply with a law, regulation, or legal request; (ii) protect the safety of any person; (iii) address potential violations of our Privacy Policy or terms of service; (iv) investigate fraud, security, or technical issues; or (v) protect Tile’s rights or property, our employees, users and the public.

In addition, if we are acquired by a third-party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third-party, in the event we go out of business or enter bankruptcy, some or all of our assets - including any information collected from or about you - may be disclosed or transferred to a third-party acquirer in connection with the transaction.

7. You May Access, Modify, and Rectify Your Information

You can access and modify your contact information, such as your name, email address or phone number, within the Services, or by contacting us at [e-mail]. Where otherwise permitted by applicable law, you may send an e-mail or use any of the methods set out in this Privacy Policy to request to know the categories of 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 share personal information. All of this information is also set forth in this Privacy Policy.

You may also request that we provide access to and/or a copy of certain information we hold about you, seek rectification, or request erasure of certain personal information about you by Tile.

Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws. Under Privacy Shield or other applicable laws, you may also inquire as to whether Tile is processing personal information about you, request access to personal information, and ask that we correct, amend or delete it where it is inaccurate or has been Processed in violation of the Privacy Shield Principles.

Although Tile makes good faith efforts to provide individuals with access to their personal information, there may be circumstances in which Tile is unable to provide access and is not legally obligated to do so, including (depending on applicable law) but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where it is commercially proprietary. To protect your privacy, Tile will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personal information.

8. Your Account May Be Deleted Upon Your Request

If you want us to delete your account, please contact us at [e-mail] with your request. We’ll take steps to delete your requested personal information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required or permitted by law.

Please note, however, that if you delete your account or other personal information, the Location Information associated with any active Tile(s) may still be collected anonymously from other Tile users who are running the app within Bluetooth range of your device. However, any new Location Information that is collected will no longer be associated with your account. You may dispose of your Tiles at a local e-waste facility or contact customer care at [e-mail] for more information.

9. Communications and Opt-Out (Right to Object to Processing)

A. Communications

We may periodically send you promotional newsletters and emails. You have the opportunity 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, so you will not be able to opt out of those communications.

B. Opt-Out

i. General

You have the right to object to and opt out of certain uses of your information. Where you have consented to Tile’s Processing of your information, you may withdraw that consent at any time and opt out of certain Processing activities, such as targeted marketing communications, by contacting [e-mail]. Even if you opt out, we may still collect and use information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

ii. Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt and within timeframes required by law. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Tile and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms or this Privacy Policy).

We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

iii. Mobile devices

Tile may occasionally send you push notifications through our mobile applications with notices that may be of interest to you. You may at any time opt out from receiving these types of communications by changing the settings on your mobile device. Tile may also collect location-based information if you use our mobile applications. You may opt out of this collection by changing the settings on your mobile device.

iv. Human Resources Data

With regard to information that Tile receives in connection with the employment relationship, Tile will use such information only for employment-related purposes as more fully described above. If Tile intends to use this information for any other purpose, Tile will notify the individual and provide an opportunity to opt out of such uses.

v. “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

vi. Analytics

You can also choose not to be included in Google Analytics at https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en. This opt-out must be performed on each device and browser that you wish to have opted-out.

10. Information Posted to Our Blog and Community Forum Are Public

If you choose to submit your Tile success story or comment on our blog (“Feedback”), you should know that any information you submit there can be read, collected, or used by other users of those blogs, and could be used to send you unsolicited messages.

We are not responsible for the information you choose to provide in your Feedback or for any content or communications you receive as a result of sharing such information.

To request removal of your information from our blog or Tile success story, please contact us at [e-mail].

11. International Transfer

You agree that all information collected via or by Tile may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Tile, you explicitly consent to the storage of your information in these locations.

i. Australian Users

Except in some cases where we may rely on an exception under the Australian Privacy Act 1988 (Cth), we will take reasonable steps to ensure that such overseas recipients do not breach the Australian Privacy Principles in the Privacy Act 1988 (Cth) in relation to such information.

12. Privacy Shield

Tile complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively “Privacy Shield”), as set forth by the U.S. Department of Commerce and the Federal Trade Commission (“FTC”), regarding the collection, use, and retention of personal information transferred from the European Economic Area and Switzerland to the United States. Tile has certified to the Department of Commerce that it adheres to the Privacy Shield Principles and Supplemental Principles. To the extent that the Privacy Shield applies to your information, if there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Tile’s certification, please visit https://www.privacyshield.gov. Additionally, Tile may protect information through other legally valid methods, including international data transfer agreements.

“Privacy Shield” means the seven (7) principles of the Privacy Shield Framework:

1. notice,
2. choice,
3. accountability for onward transfer,
4. security,
5. data integrity and purpose limitation,
6. access, and
7. recourse, enforcement, and liability.

Additionally, it includes the sixteen (16) supplemental principles described in the Privacy Shield:

1. sensitive data,
2. journalistic exceptions,
3. secondary liability,
4. performing due diligence and conducting audits,
5. the role of the data protection authorities,
6. self-certification,
7. verification.
8. access,
9. human resources data,
10. obligatory contracts for onward transfers,
11. dispute resolution and enforcement,
12. choice – timing of opt-out,
13. travel information,
14. pharmaceutical and medical products,
15. public record and publicly available information, and
16. access requests by public authorities.

13. Accountability for EU or Swiss Citizens

If you are an EU or Swiss citizen and feel that Tile is not abiding by the terms of this Policy, or is not in compliance with the Privacy Shield Principles, please contact Tile at the contact information provided below.

In addition, Tile has agreed to refer unresolved complaints related to personal information to JAMS Privacy Shield Dispute Resolution Program and, with respect to employee and human resources data, has committed to cooperate with the panel established by local data protection authorities and comply with the advice given by the panel for EU citizens and with the Swiss Federal Data Protection and Information Commissioner’s authority and advice for such data of Swiss citizens. For more information and to submit a complaint regarding individual data to JAMS, a dispute resolution provider which has locations in the United States and EU, visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim.

Such independent dispute resolution mechanisms are available to citizens free of charge. If any request remains unresolved, you may contact the national data protection authority for your EU Member State.

You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEX-I-introduction. The FTC has jurisdiction over Tile’s compliance with the Privacy Shield.

14. We Take Security Seriously

We implement various systems, applications and procedures to secure your personal information, in order to reduce the risks of theft, damage, loss of information, or unauthorized access, disclosure, modification or use of information. Please be aware, however, that these measures cannot absolutely guarantee the security of your personal information. Therefore, although we take great efforts to protect your personal information, we cannot guarantee and you cannot reasonably expect that our databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

A. California Privacy Rights

i. Shine the Light

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. However, Tile does not share personal information with third parties for their own marketing purposes without your prior consent.

ii. California Consumer Privacy Act (CCPA)

California residents can make certain requests about their personal information under the CCPA. Specifically, if you are a California resident, you may request that we:

• provide you with information about: the categories of personal information we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we share personal information. Such information is also set forth in this Privacy Policy
• provide access to and/or a copy of certain information we hold about you;
• delete certain information we have about you; and/or
• provide you with information about the financial incentives that we offer to you, if any.

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 the Services to you; if you ask us to delete it, you will no longer be able to use the Services.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights under the CCPA.

The CCPA also sets forth certain obligations for businesses that “sell” personal information. We do not engage in such activity based on our understanding of the definition of sale under the CCPA and current guidance, and have not engaged in such activity in the past twelve months. We do share information as outlined in this Policy, including with other businesses through the use of website cookies, pixels, or other technologies in order to provide services including analytics and advertising and marketing our services on other sites or apps. You can control certain of these cookies through browser settings and other controls and as outlined in this Policy.

If you would like information regarding your rights under applicable law or would like to exercise any of them, please contact us at [e-mail] or via other means listed on https://tileteam.zendesk.com/hc/en-us/articles/205348827-How-do-I-contact-Customer-Care-. To protect your privacy and security, we take reasonable steps such as verifying your email address and specific information to verify your identity and request.

B. Australian Users

Except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information. Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

15. You Are Responsible for Maintaining the Accuracy and Confidentiality of Your Email Address and Password

You are responsible for keeping the secrecy of your password at all times. We recommend using a strong password that you do not share with other services.

If you believe the security of your account has been compromised, please change your password immediately via the Tile website or through your Tile app. You can also contact us at [e-mail] for assistance.

You are responsible for ensuring the email address associated with your account is accurate. We use that email to contact you about service updates, changes to our policies, and account activities such as requests for your information or locate attempts on your device. Tile is not responsible for information or data transmitted to a third party as a result of a user providing an incorrect email address.

16. We Post Updates on Our Website Whenever This Policy Changes

We may update this policy from time to time, so please review it frequently. We'll notify you of material changes via a notice on our home page (tile.com) thirty days before they go into effect. If we are required by applicable data protection laws 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 twenty days after their initial posting. We will make any immediate changes in order to comply with legal requirements.

If you object to any of the changes to this Privacy Policy, you must cease using our Services and may request us to erase your personal information. Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected.

17. Our Policy Toward Children

Our Services are not directed to children under 13 and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information of a child under 13, we will take steps to delete such information from our files as soon as possible.

18. Contact Us if You Have Any Questions or Concerns

If you have questions about our privacy practices, this Privacy Policy, or how to lodge a complaint with the appropriate authority, please contact us at [e-mail] or by postal mail:

United States: Tile, Inc., 2121 South El Camino Real, Suite 900, San Mateo, CA 94407

United Kingdom: Tile Europe, Ltd., 11th Floor, Whitefriars, Lewins Mead, Bristol, BS1 2NT

19. Right to Contact a Data Protection Authority

If you have a concern about how we collect and use information, please contact us as noted above. You also have the right to contact your local Data Protection Authority if you prefer. Contact details for Data Protection Authorities in the EU are available at ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

_________________________________________________________________

This Jiobit Privacy Policy was last modified on December 16, 2021.

Jio, Inc. Online Privacy Policy

1. INTRODUCTION  

Purpose.  The purpose of this Privacy Policy is to describe how Jio, Inc., a Life360, Inc. Subsidiary (“Company,” “we,” “us”), collects, uses and shares information about you through our U.S. online interfaces (e.g., websites) owned and controlled by us, including the www.jiobit.com website (the “Site”), the Jiobit mobile application (the “App”) and the wireless Jiobit device (the “Device”), and together with the App, collectively, (“the Service”).  Company’s Service consists of a wireless device, service, and mobile applications to help parents/guardians communicate with, monitor, track and locate their children. This is a data-driven service.  Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us or as described at the end of this Policy.

Our Privacy Policy explains:

• How We Use and Share Your Information
• Access to Your Information and Choices
• Security of Your Information
• Consent to Processing of Personal Data in the United States
• Changes to Our Privacy Policy
• Questions and How to Contact Us

Scope; Third Party Sites.  This Privacy Policy applies only to information we collect at and through the Site and the Service.  Our Site may also contain links to third-party sites that are not owned or controlled by the Company.  Please be aware that we are not responsible for the privacy practices of such other sites.  We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

2. INFORMATION THAT WE COLLECT

Information You Provide to Us. We collect information you provide to us, for example when you create or modify your account, register to use our Site or Service, purchase products or services from us, including the Device, request information from us, contact customer support, or otherwise communicate with us. This information may include:

• Name
• Home address
• Work address
• Billing address
• Shipping address
• Email address
• Telephone number
• Birth date
• Credit / debit card number (solely for payment purposes)
• Bank or financial account number (solely for payment purposes)
• User generated content (blog posts, feedback, comments, photos, videos, messages, social media)
• Wi-Fi access point passwords
• Device wearer's first name or nickname, date of birth, race and ethnicity and pet breed in the case of an animal
• Emergency information for device wearer including legal first and last name, height, weight, medications, allergies and medical conditions

Information We Collect Through Your Use of our Site and Service

Jiobit Location Data

When you use the Service, the Device will securely transmit its geolocation information to Jiobit servers.  Users can then use the smartphone or web-based app to locate, track and monitor the Jiobit wearer using this geolocation, information.  

Google Analytics / Zendesk / Amplitude / Survicate

We use Google Analytics, a web analytics service provided by Google, LLC. (“Google”) to collect certain information relating to your use of the Site and the Service. Google Analytics uses “cookies”, which are text files placed on your computer or mobile device, to help the Company analyze how users use the Site and the Service. You can find out more about how Google uses data when you visit our Site or use the Service byvisiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).  Please note that if you choose to opt out, you will continue to see ads on our Site and in the App, but they will not be based on how you browse, shop or otherwise interact with our Site or the Service.

We use Zendesk, an online customer communication platform suite, to collect certain information relating to your use of the Site in order to facilitate our communications with you and other users. For more information regarding Zendesk’s services, please visit the Zendesk website, and pages that describe Zendesk’s services and information collection practices.

We use Amplitude, a digital optimization reporting suite, to collect certain information relating to your use of the application in order to improve the product for you and other users. For more information regarding Amplitude services, please visit the Amplitude website and pages that describe Amplitude’s services and information collection practices.

We use Survicate, a survey tool, to collect certain feedback from our users relating to their use of the product and service in order to improve the product for you and other users. For more information regarding Surivate’s services, please visit the Survicate website and pages that describe Survicate’s services and information collection practices.

Information Collected Through Cookies and Similar Technologies

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site or the Service through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site or use the Service again, the cookie allows the Site or the App, as applicable, to recognize your browser. Cookies may store unique identifiers, user preferences, and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site or Service features or services may not function properly without cookies. We use cookies to improve the quality of our service, including storing user preferences, tracking user trends, and providing relevant advertising to you. (See, “Advertising” below.)

A Special Note About Children Under Age 13

We are committed to protecting the privacy of children.  In accordance with the Children’s Online Privacy Protection Act (“COPPA”), the Site is not designed or intended to attract the use of children under the age of 13.  If you are under the age of 13, you may not attempt to register with us at the Site or provide any personal information about yourself to us without verifiable consent from a parent or guardian. We intend to collect information about children under the age of 13 only as provided by the child’s parent or legal guardian on the Site, or through the use of our Service with the prior consent of a child’s parent or legal guardian.

The Device is intended to be worn and used by a child.  By providing the Device to a child, you represent and warrant to Company that you are authorized by such child’s parent or guardian to enable and permit Company to operate the Service and collect and use the information from the Device used by the child as stated in this Privacy Policy and the Terms of Service.  Location-based information gathered from any Jiobit user will never be used or sold for marketing purposes.  

If we have collected information from your child under the age of 13 with your consent as a parent or guardian, you may Contact Us using the information at the end of this policy in order to: (1) review any of your child’s personal information that we have collected; (2) request we delete some or all of your child’s personal information; and/or (3) refuse to allow further collection or use of your child’s personal information.  We will require you to provide us with sufficient identification before providing access to, or acting upon, such personal information.  If we are required or authorized by law to do so, we may refuse access or refuse to take such steps.  If you wish to prevent collection of your child’s personal information through use of the Service, you must prevent your child from using the Device.

If we learn that we have collected personal information from a child under the age of 13 without consent from such child’s parent or guardian, we will promptly delete that information.  If you believe we have collected personal information from a child under the age of 13 without such verifiable consent, please Contact Us using the information provided below.

3. HOW WE USE AND SHARE YOUR INFORMATION

Information Usage and Third Party Sharing: We will only use your information in a manner consistent with this Privacy Policy, unless you have specifically consented to another type of use, either at the time such information is collected or through some other form of consent from you or notification to you. Personal information and location-based information is treated as sensitive information by the Company and are subject to a heightened standard for sharing, as opposed to non-personal or de-identified information which may be shared with any number of parties that are required to provide Jiobit Servicewith other entities for purposes determined by Jiobit.  Personal information including location-based information, in aggregate or individualized, about any Jiobit user, will never be sold or shared with independent third parties for commercial purposes. Personal information, including location-based information, which may be shared at your consent with authorized third parties, including Life360, Inc, to enhance the Jiobit Service experience, but will never be sold or shared with by Jiobit to independent third parties for their own commercial purposes.  Nonetheless, independent third parties may use information subject to their own policies, which you should review prior to authorizing any such sharing. 

We may use your information to:

• provide products and access to services that you purchase using the Site or access using the Services;
• improve the Device or Service performance  or quality, analyze our products and services and how they are used, and develop new Devices and Services
• respond to your inquiries or requests;
• register your user account;
• contact you about your orders;
• process credit card and debit card transactions;
• ship products to you;
• send you information about the Service or our products (such as maintenance or security information, promotional materials, surveys, or other advertisements about the Service or products);
• comply with applicable law or legal process;
• comply with accounting and auditing standards and processes;
• provide to a collections agency and/or credit bureau(s) should you default on agreed-upon payments on contract plans;
• investigate suspected fraud, harassment, danger to persons or property or other violations of any law, rule or regulation, or the terms or policies for the Service or our business partners;
• share with law enforcement and other parties which users must consent to, in order to help to locate a lost person or animal;
• develop and enhance our own data, such as through tracking the location of your Device, provided that any disclosures of such data does not specifically identify you, your Device or your specific location;
• combine it with Wifi network data surrounding your Device to help with location accuracy.

Additional Sharing with Third Party Vendorsies.  We may provide information to third party vendors and subcontractors that help us operate and manage our Site, process orders, and fulfill and deliver products and the Service that you purchase from us. These vendors and subcontractors will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections, including obligations of confidentiality, to limit their use of that information to helping us provide the service.

Advertising.  We may use how you browse and interact with the Site and the Service in order to show you ads for Company or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our Site or third-party sites not owned by Company, or while you are using the App.

We belong to ad networks that may use your browsing history across participating websites to show you interest-based advertisements on those websites. Currently, our Site and the App may not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).

Your Consent.  In addition to the sharing described elsewhere in this Policy, we will may share personal information with companies, organizations or individuals outside of Company only when we have your consent to do so.

Affiliates and Subsidiaries. We provide access to or share your information with our corporate affiliates and subsidiaries for the purposes described in this Privacy Policy.

Legal Proceedings.  We will share personal information with third party companies, organizations or individuals outside of Company if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or enforceable governmental request.
• Enforce applicable Terms of Use and Terms of Service, including investigation of potential violations.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Company, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control.  If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business, the Site or the Service to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.

Auto Deletion of Data:  We may automatically delete data from a Device in connection with a returned or terminated account or device, or as necessary to protect against unauthorized access to the data.

Data Retention:  We may retain your information for as long as we feel that there is a business need or benefit to do so.  This will include retaining location-based information.

Data Access:  Data collected through use of the Device and/or the App, including location information, frequency of use and emergency contact information is generally not available to customers for their own, direct access.

How to Request Deletion:

If you would like us to delete personal information we have collected about you, please send an email to [e-mail] with your request.

Subscription:  Purchasing a subscription will enable and authorize Jiobit to collect personal information about persons or animals being tracked, including geolocation information, presence, images and access to this information will be made available to your authorized Care Team.  By making this purchase, you are acknowledging that one of the following applies:  a) you consent to this as the parent or guardian of such children or b) you have the authority (such as a school) to consent to this activity on behalf of the parent or guardian.

4. ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your online account by signing into your account and going to the “Account Management” website portal here.  If you have questions about personal information we have about you or need to update your information, you can Contact Us.  You can opt-out of receiving marketing and promotional emails from Company by clicking Unsubscribe here or by using the opt-out or unsubscribe feature contained in the emails.  Deactivating your child’s account is always possible by contacting Customer Care through our phone number, online through chat or by sending an email to [e-mail].  

5. SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information.  Jiobit uses the Jiobit TrustChip to deliver unmatched security and encryption, meeting or exceeding US-government standards.  The TrustChip is a dedicated security chip, a device without this chip cannot communicate with our secure servers.  The Jiobit Service refuses to download software that is not cryptographically signed by Jiobit.  This prevents malware or “rogue” software.  Jiobit location data is never sent “in the clear”.  Jiobit encrypts all data at rest and in transit.  Jiobit is also intrusion resistant - that means that no one can modify the software on the Device itself.  Unlike your phone, PC, smart home devices, security cameras, or routers, if you were to physically open up the Jiobit Device, it cannot be programmed - Jiobit burns away part of the circuit board used for physical software programming.  However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us.  There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.  It is your responsibility to protect the security of your login information.  Please note that e-mails and other communications you send to us through our Site or the App are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

6. CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES

If you are a resident of the European Economic Area (EEA), in order to provide our Site and the Service to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information.  We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site and the Service, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

7. CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.   We will obtain prior parental consent if any changes we make to this Policy affect children in a way that requires such consent under COPPA.  

8. QUESTIONS AND HOW TO CONTACT US

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us by email at [e-mail] or contact us by US postal mail at the following address:

Jio, Inc.

30 N Lasalle St. Suite 2630 

Chicago, IL 60602

+1-855-JIO-2848

_________________________________________________________________

This Life360 Privacy Policy was last modified on October 28, 2022.

Life360 Privacy Policy

WELCOME

Life360, Inc ("Life360", "we", "our", or "us") is committed to protecting and respecting your privacy.

Life360 operates a service that allows you to speak to and share your location with other users in your family or friendship group (each group, a "Circle"), which we make available through our apps and our website https://www.life360.com (the "Service").

This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our Service, as well as your choices regarding the collection and use of information.

Our Service is available in many countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.

This Privacy Policy is therefore made up of two parts:

• Part 1 sets out information applicable to users outside the European Economic Area, Switzerland or the UK; and
• Part 2 sets out information applicable to users in the European Economic Area, Switzerland or the UK.
• If you are a resident of the State of California in the United States, please click here for additional California-specific privacy information.

Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.

Part 1 – Privacy Policy for non-EEA users

This Part 1 of our Privacy Policy explains how we collect, use, disclose and protect information that is collected through our Service from users outside the European Economic Area,  Switzerland or the UK, as well as your choices regarding the collection and use of information.

This Part 1 of the Privacy Policy was last modified on November 10, 2021.

1. HOW WE COLLECT AND USE INFORMATION

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use.

We collect the following types of information about you:

Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number. We may collect a photo, if you or a Circle member associate a photo with your account. If you want to add a family member’s name to your account, we collect the family member’s name, email address, and mobile phone number. We may also collect billing information when you sign up for Premium service.

Data collected through use of the Service. After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite places and to provide alerts when family members leave and arrive.

Geolocation. We collect your location information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. If you enable the mobile app to use your Bluetooth signal, we may be able to determine location based on nearby Bluetooth-enabled devices, which helps us to improve location accuracy, identify other Life360 users and devices that have been in proximity to each other, and improve location updates for all devices in the Life360 network. Depending on your device settings, we collect location information in the background, even when you are not actively using the app. We collect and maintain location data to provide you the features and functionality of the Service. We may also share location information with our partners, such as Cuebiq and its Partners, for tailored advertising, attribution, analytics, research and other purposes, as described in Section 2 “Sharing of Your Information” below. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the app’s access to your location data. Please see “Your Choices About Your Information” below to learn more.

Driving Event Data. We collect, and may use a third party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. Your mobile device provider may refer to this information as “Motion and Fitness” data (description may vary according to device and platform). We may also share this information with third party partners for marketing, research, analytics and other purposes. If you want to opt-out of the collection of your sensory and motion, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data. Please see “Your Choices About Your Information” below to learn more.

Messages and User Content. We collect information when you message other members of your Circle through use of the service. We may also retain any messages you send to us.

We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Circle, crime alerts in your neighborhood, etc.

Social Media. When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Life360’s website or Service.

Identity verification. In limited circumstances, we may use identity verification services provided by a third-party provider Berbix to verify your age and/or to obtain verifiable parental consent for your child to use the Service. When identity verification is required, we will ask you to upload an image of your valid government-issued ID along with a selfie image. Our identify verification provider will use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." Life360 does not receive the biometric identifier generated from the images. It is generated and held by our identity verification provider until the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than 60 days after your last verification interaction with us.   For identity verification and security purposes, Life360 may have access to the information extracted from the identity scan of the ID document (such as a name and partial driver’s license number) as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, confirm appropriate parental consent, and protect against fraud and misrepresentation.  We do not use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider processes this information on our behalf strictly in accordance with our contractual agreements. Please note this service may not be available in all jurisdictions.

Information from third-party services. We collect information from third party services that you connect to your Life360 account. For example, if you link your Life360 account to a voice assistant platform to enable interaction with our service through voice commands, such as through the Life360 Google Action (“Action”) available on Google Assistant-enabled devices, we will collect the queries and commands applicable to Life360 that you make through the Action or other voice assistant platforms.

Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:

• Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
• Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
• Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.

We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.

We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.

If you prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time. 

We and our third party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.

2. SHARING OF YOUR INFORMATION

Personal Information:  We share your personal information with third parties outside the Company and its controlled subsidiaries and affiliates in some circumstances, as follows:

• We share your personal information, including name, email, precise location and driving event data, with others within your Life360 Family and other Life360 circles. Depending on the features and functionality enabled, we may also share other information about your use of the Service with members of your Family Circle, such as whether you have logged in on a new device.
• We may share your personal information, including your precise location data, driving sensor data, unique identifiers or AD IDs and other data with our partners, such as Cuebiq and its Partners, for their marketing and business purposes, including without limitation, to inform and improve tailored advertising, attribution, analytics or research purposes. These third party partners may use this information according to their own privacy policies. Please see “Your Choices About Your Information” to learn how you may be able to limit some third-party data sharing.
• We share your personal information with Arity 875, LLC (“Arity”), which provides driving analytics behavior services to enable us to provide certain functionalities of the Service, such as driving event history and crash detection. We may share geolocation and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device) and application analytics, including IP address and device identifiers, driving event data and information provided by you during your registration of a Life360 account or as part of your use of our Services. Arity uses this information to analyze your driving behaviors, such as speed, change in speed and other aspects of how, how much, where and when you drive in order to predict driving risk and calculate a driving risk score. Arity also uses this information to improve its analytics and predictive driving behavior models and improving its service generally.
  For US users only, Arity may use this information to provide personalized content including targeted advertising, offer discounts, rewards or pricing offers by third parties such as insurance companies, and for other commercial purposes. Please see “Your Choices About Your Information” to learn how you may be able to limit some of this data sharing with Arity. To learn more about how Arity’s use of personal information, please review the Arity privacy policy, which is located at https://www.arity.com/privacy.
• We share personal information with third-party partners that provide certain features and services you may use in connection with our Service. For example, depending on the features of the Service you have enabled, we provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. The third parties that provide Premium service features may ask you for additional information in order to provide the full range of services to you. Any information provided to these third parties will be governed by that third party’s own privacy policy.
• We share personal information with third parties that you have connected to your Life360 account to facilitate the features or services. For example, if you enable the Life360 Action on any Google Assistant-enabled device or use other voice-assistant services, Life360 will respond to any query received through the Action and disclose your personal information we well as the personal information (such as name, current location, and other data) of your Circle members through screen display or audio response. Google and the equipment the Google Assistant is installed on, may record your interactions with the Action and the response data in accordance with your agreements with Google. You are solely responsible for the use of the Life360 Action to access information about your Circle members on your Assistant-enabled devices, including in the case of any unauthorized access to your device by a third party, and for the consequences of enabling the Action on any of your devices.
• Other users may share your personal information in certain circumstances. For example, if a member of your Circle enables the Life360 Action on a Google Assistant-enabled device, your personal information (including name, current location and other data) may be displayed on screen or via audio response on any device with the Life360 Action enabled. This means your information may be available to other individuals who have access to your Circle member’s Assistant-enabled device or who may overhear your Circle member interacting with the Action. To prohibit this data sharing, you must ask your Circle member to disconnect his or her account from the Life360 Action or you can leave the Circle.
• We use the hCaptcha anti-bot service by Intuition Machines, Inc. (“IMI”) on our website to check whether the data entered on our website has been entered by a human or by an automated program. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics (e.g. IP address, how long the visitor has been on the website or app, or mouse movements made by the user). This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website or app with hCaptcha enabled and hCaptcha may take place completely in the background in “invisible mode.” The information collected through hCaptcha is shared with IMI, which processes the information on our behalf. For more information about hCaptcha and IMI's privacy policy and terms of use, please visit the following links: https://hcaptcha.com/privacy/ and https://hcaptcha.com/terms.
• Any information or content that you voluntarily post to the website or to our Facebook page will automatically be available to the public. We may publicly post your reviews and comments online on our website or mobile app or link your reviews to third party websites.

Other instances in which we may share your information: We may also share your information for business purposes, as follows:

• We may share your personal information with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Services, such as accounting, managerial, technical, marketing or analytic services, and to other third-party partners or service providers who contractually agree to process personal information solely as necessary to provide services or features to our users.
• We may at any time buy or sell/divest the company, or any combination of its products, services, assets and/or businesses. Personal information such as customer names and email addresses, and other user information related to the Service will likely be one of the items transferred in these types of transactions. We may also share, transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions or similar transactions or proceedings.
• We may disclose personal information to third parties (including law enforcement, other government entity, or civil litigant; excluding our subcontractors) when required to do so by law or subpoena or if in our sole discretion, we determine it is necessary to (a) conform to the law, comply with legal process, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) to enforce our Terms of Use, take precautions against liability, to investigate and defend ourselves against any claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property, or personal safety of Life360, our Users or others.

Life360 is a USA-based organization and we store your personal information in the USA, which may be outside your jurisdiction of residence. Our partners and service providers may also store your personal information outside your jurisdiction of residence. Accordingly, your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such jurisdictions.

De-Identified Information:  We may also share your information with third parties in a form that does not reasonably identify you directly.  These third parties may use the de-identified information for any purpose.

3.  HOW WE PROTECT YOUR INFORMATION

Life360 cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4.  YOUR CHOICES ABOUT YOUR INFORMATION

You may, of course, decline to submit any personal information through the Service, in which case Life360 may not be able to provide its Services to you.

Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at [e-mail].

Close Your Account or Delete Personal Information: We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at [e-mail]. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.

Emails and Notifications:  You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices).  You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests. 

Location and Movement Data Collection and Sharing:  As described in Section 2, we collect precise location data and driving event and movement data (such as accelerometer data, magnetometer data, gyro data, etc.) from your device to provide the Life360 Services, and may share your personal information, including location and movement data, with other Life360 users in your Family Circle or other Circle 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:

• Limit location sharing with your Circle. You may turn location sharing “OFF” for one or more of your Circles through your App settings.  If you turn off location sharing in one or more of your circles, we will not share your location with such Circles; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services, to share your location with the other Circles, or to provide location-based advertising). Note: if you press “Check In” or “Automated SOS” in the App, your location will update in every one of your Circles even if location sharing is turned off for one or more of your Circles.
• Limit Drive Detection. You can limit the collection and display of location and movement data through the Drive Detection feature in the in-App Privacy settings. When you turn Drive Detection “off,” your location is not visible to your Circles and your location and drive history will not show on Individual or Family Driver Reports. Please note that your Life360 app may not be able to provide all of our Services to you turn off Drive Detection. When Drive Detection is turned “off,” Crash Detection services will be disabled and safety services like SOS Help Alerts and 24/7 Dispatchers will not be available.  
• Limit data sharing with third party data partners through in-App Privacy Settings. To opt-out of Life360 sharing personal information (including location and movement data) with data partners for targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. If you opt-out, Life360 will continue to collect your device location and movement data and to share such data with your Circles and with third parties as needed to support and provide the Life360 services or other services you engage, but we will no longer share data about you with our third party data partners for their own advertising and other commercial purposes. Please note, some third party data partners may continue to send you location-based ads based on your previous location or may approximate your location based on other data.
• Limit driving event sharing with Arity. We share data with our partner Arity to support important App features like driving behaviour and Crash Detection. Arity also uses data for research, to improve its analytics and predictive driving behavior models and improve its performance generally. To opt-out of permitting Arity to use and learn from your data for its own research and to develop and improve its predictive behavior models and products and services generally, you can opt-out through the Driving Services page in the in-App Privacy Settings. To opt-out of permitting Arity to use data for its own commercial purposes, including marketing, advertising, and for US users only to provide and service insurance company products and ads, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security Settings.
• Disconnect Location Data and Movement Data in Device Settings. You may also be able to turn off device location data collection through your mobile device settings.  For example, depending on your mobile device, you may be able to “Turn location services ‘off,’ which restricts access to your device location data. You can also adjust your device settings to withdraw permission for the Life360 app to access device location data and/or motion data (depending on the device type, this may be called “Fitness and Motion” data), and you can also adjust your device settings to limit the app’s access to WiFi and Bluetooth information. Please note that your Life360 App may not be able to provide all of our Services to you if you disable access to location and movement data through your device settings.

Third Party Tracking and Online Advertising: We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices or advertising channels. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through tracking technologies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. These third parties use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

• To opt-out or control third-party tracking and advertising: Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of the use of your personal information to inform and display targeted advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).  You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.    
• Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
• Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
• To opt-out of Life360 sharing data with third parties for advertising purposes. To opt-out of Life360 sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. Please note, some third party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.

You may request access to, or correction of, your personal information by contacting us at [e-mail].

5.  CHILDREN'S PRIVACY POLICY

Life360 takes special precaution to protect the privacy of our younger users.  Life360 does not knowingly collect personal information from children under the age of 13 (a “child”) without verifiable consent of a parent or guardian and the Service is intended to be used by children under 13 only with significant parental involvement and approval.

If Life360 learns that we have inadvertently collected personal information of a child without parental consent, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Service without your consent, please alert us immediately by emailing [e-mail] so that we may delete that child’s personal information from our systems.

By enabling your child to create a user account and permitting your child to use the Service, you expressly agree to the practices described in this Children's Privacy Policy and you consent to the collection, use, and disclosure of your child's personal information as described herein.

Setting up a child account.  If a parent wishes to add a user who is under 13 to the Service, we request the Parent provide verifiable consent through one of several methods, such as by verifying the Parent’s driver’s license or by submitting a parental consent form (available here) via mail or email.  The child will then be able to participate in most aspects of the Life360 Service.

Personal information we collect.  We take special precautions to collect only as much information as is reasonably necessary for the child to use the Service. As further described in our Privacy Policy above, we collect various types of personal information from all users of the Service. For example, we collect profile information (username, email address and mobile phone number) when a user creates an account and other types of personal information the user may provide during the course of using the Service, such as a nickname, favorite location, and emergency contact information.  We collect information about a user’s device (e.g., IP address, device type/model/manufacture / operating system, and a unique ID that allows us to identify the browser, mobile device or account, such as a UDID, IDFA, Google AdID or similar)  as well as certain usage information about the use of the Service (for example, whether the user opens emails) and we collect analytics data. We collect geolocation data through the device IP address, WiFi, Bluetooth and GPS coordinates available through the user’s mobile device and through technologies and sensors that may be nearby. We also collect driving event data through sensory and motion data sensors in the user’s mobile device (e.g., data from a smartphone’s gyroscope, accelerometer, compass and Bluetooth) in order to calculate and detect driving events such as hard braking, speeding and crash detection. Please review the section of our Privacy Policy called “How We Collect and Use Information” to learn more.

Information sharing.  Life360 may share or disclose a child’s personal information our third party vendors, service providers and business partners as described in our full privacy policy, including, for example, with third parties as needed to analyze and detect driving behavior data, perform analytics or otherwise , support the features and functionality of our Service such as crash detection. However, we do not share or sell personal information collected from the accounts of children under 13 for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. Please review the section of our Privacy Policy called “Sharing of Your Information” to learn more about how we share information with our vendors, service providers and others.

Sharing information with other Life360 users.  The child’s profile information and location will be shared with other members of the Family Circle and any other Circle the child joins. Please note that if your child joins any other Circles, the child will be able to share his or her location with other members of that Circle and may exchange messages with those Circle members. You are responsible for monitoring your child’s account and location-sharing activity through the Service and for blocking or permitting location sharing features.  

Your Choices.

Contact Us.  The Parent has a right to request to review or have deleted the child’s personal information and may withdraw consent for the Service to collect any further personal information from the child. Please contact us at [e-mail] to request to review and/or delete any personal information we have collected from the child, or to withdraw permission for Life360 to collect any additional information from the child. Please also review the section of the Privacy Policy called “Your Choices About Your Information” to learn more about how you may control or turn off certain data collection and sharing features of the Service.

6.  LINKS TO OTHER WEB SITES AND SERVICES

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

7.  CHANGES TO OUR PRIVACY POLICY

Life360 may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how Life360 will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.

8.  YOUR CALIFORNIA PRIVACY RIGHTS

This section applies to you if you are a resident of the state of California (a “consumer”). California law requires us to disclose certain information regarding the categories of personal information we collect. For purposes of this section, “personal information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and does not include information that is publicly available, that is deidentified or aggregated such that it is not capable of being associated with an identifiable consumer or device.

Collection and use of personal information. We collect personal information from and about you for a variety of purposes explained in this Privacy Policy.

In the last 12 months, we have collected the following categories of personal information:

• Identifiers, such as your name, address, phone number, email address, unique device identifiers or other similar identifiers;
• California customer records, such as birth date and payment information;
• Commercial information, such as records of services purchased, obtained or considered;
• Internet/Network information, such as device information, logs and analytics data;
• Geolocation data, such as precise location data from your mobile device (e.g., GPS coordinates) or generated based on your IP address;
• Inferences about your interests and preferences, generated from your use of our services; and
• Other personal information, such as driving event and movement data collected from your mobile device, or content or messages you send through the Service.

We collect this information directly from you, from our business partners, from your browser or device when you visit our websites, download or use our mobile app, and from third parties that you permit to share information with us.

Disclosure of Personal Information. We share personal information with third parties for business purposes or we may sell your personal information to third parties, subject to your right to opt out of those sales (see Your Rights and Choices below). The categories of third parties to whom we disclose your personal information may include: (i) other users with whom you elect to share such information; (ii) our service providers and advisors, (iii) third party businesses that provide features or services you may use in connection with our Service; (iv) marketing and strategic partners; (iv) ad networks and advertising partners; (v) analytics providers; and (vi) social networks. To learn more about how we disclose personal information to third parties, please refer to Section 2 of this Privacy Policy.

In the previous 12 months, we have disclosed the following categories of personal information to third parties for a business purpose: Identifiers, California customer records, Commercial information, Internet/Network information, Geolocation data, Inferences, and Other personal information.

In the previous 12 months, we have sold the following categories of personal information to third party data 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.

Your Rights and Choices.  As a California resident, you may be able to exercise the following rights (subject to certain limitations under law):

• The Right to Know any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity: (i) the specific pieces of personal information we have collected about you; (ii) the categories of personal information we have collected about you; (iii) the categories of sources of the personal information; (iv) the categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (v) the categories of personal information we have sold and the categories of third parties to whom the information was sold; and (vi) the business or commercial purposes for collecting or selling the personal information.
• The Right to Request Deletion of personal information we have collected from you, subject to certain exceptions.
• The Right to Opt Out of Personal Information Sales to third parties now or in the future.

You also have the right to be free of discrimination 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.

To Submit your California Consumer Rights Requests. You may submit a request to exercise your California Consumer Rights through one of the mechanisms described below. We will need to verify your identity before processing your request, which may require us to request additional personal information from you or require you to log into your account.  In certain circumstances, we may decline or limit your request, particularly where we are unable to verify your identity or locate your information in our systems, or as permitted by law.

• To exercise your Right to Know or your Right to Request Deletion:   Submit a request through the App by clicking on “Additional Information for California Residents” page in your in-App Privacy & Security Settings. Then, select “Request Your Data” or “Delete Your Data” to submit your request. We will process your request and send an email confirmation once your request has been fulfilled.
• To exercise your Right to Opt Out of App-based Personal Information Sales: In the App, click on the “Do Not Sell My Personal Information” link in your in-App Privacy & Security Settings and adjust the Personal Information Sales toggle.
• To exercise your Right to Opt Out of web-based Personal Information Sales: On our website, please click the “Do Not Sell My Personal Information” link in the footer of the website and adjust the Personal Information Sales toggle.   Please note this setting does not affect App-based sales. If you wish to opt out from the sale of data that is collected through the Life360 mobile application, you must opt out separately by following the instructions above.
• To submit your request via email: Alternately, you may submit a request to exercise your California Consumer Rights via email by contacting us at [e-mail] and including your account name and mobile telephone number as well as the consumer right you would like to exercise. We may need to contact you to request additional information to verify your request.  For faster response times, we recommend users submit all requests through the in-App Privacy & Security Settings.

Authorized Agents. You may authorize another person (your “agent”) to submit a California consumer rights request on your behalf. Authorized agents must submit the request via email to [e-mail] and include a signed letter from the Life360 user confirming the agent has permission to submit the request on the user’s behalf. In certain circumstances, we may need to request additional information to verify the identity of the user about whom the request is being made and/or to verify that the user has provided the authorized agent permission to submit the request, and it may take additional time to fulfil agent-submitted requests. Please note that for privacy and security reasons, we will direct future communications to the Life360 user 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.

Additional Opt-Out Choices.  Additionally, you may wish to opt out of the sale of your personal information (including Internet/Network Information, Commercial Information and Inferences) by third party advertising networks, social media companies and similar online advertising companies for targeted online advertising purposes.  By visiting here www.privacyrights.info or www.optout.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices.   To learn more about how third parties collect information automatically on our Service and the choices you may have in relation to those activities, please see “Third-Party Tracking and Online Advertising section” of our Privacy Policy.

Minors.  We do not sell the personal information of California consumers 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 [e-mail]. We may not be able to modify or delete your information in all circumstances. 

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.

9.   YOUR NEVADA PRIVACY RIGHTS

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To exercise your Nevada opt-out rights: In the App, click on the "Do Not Sell My Personal Information" link in your in-App Privacy & Security Settings and adjust the Personal Information Sales toggle. Alternately, you may send an email to [e-mail] with the subject line “Nevada Privacy Rights” and include your account name and mobile telephone number. We may need to contact you to request additional information to verify your request. For faster response times, we recommend users submit all requests through the in-App Privacy & Security Settings.

10.  HOW TO CONTACT US

If you have any questions about this Privacy Policy or the Service, please contact us at [e-mail]

Life360
ATTN: Privacy
539 Bryant St. Suite 402
San Francisco, CA 94107

Part 2 – Privacy Policy for EEA and Swiss users

This Part 2 of our Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you access our Service from the European Economic Area, Switzerland or the UK.

This Part 2 of the Privacy Policy was last modified on November 10, 2021.

Life360, Inc is the data controller of the personal information we hold about you.

1.  PERSONAL INFORMATION WE COLLECT ABOUT YOU

1.1  We collect personal information that you voluntarily submit directly to us when you use our Service. This can include information you provide to us when you register for an account and user profile, create or edit your user profile on the Service, update your preferences, check-in at a particular location, correspond with us by phone, SMS, e-mail or otherwise, or use some other feature of our Service.

1.2  We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.

1.3  The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.

1.4  We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.

1.5  The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

1.6  We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.

1.7  We may de-identify any of the personal information we collect (so that it does not directly identify you) and use it for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features.

1.8  We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

2.  RECIPIENTS OF PERSONAL INFORMATION

2.1  We may share your personal information with the following:

(a) Others in your Life360 Family or other Life360 Circle: we may share your personal information, including your name, location and driving event data, with other users of our Service at your request and in accordance with your settings and preferences.

(b) Third parties for their marketing and related purposes with your consent. Where you have provided consent for us to do so, we may sell your personal information (specifically, your location data, driving sensor data, information about your device, and unique identifiers or AdIDs) to third parties for their marketing and business purposes, including without limitation, to inform and improved tailored advertising, attribution, analytics or market research purposes.

(c) Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, bot detection, web hosting, or providing analytic services.

(d) Third parties that provide features you use in connection with the Services: With your consent or on your instruction, we share personal information, including contact information and location data, with third-party partners that provide certain features and services you elect to use through or in connection with our Service. For example, we may provide your personal information and location data to emergency responders in the event we detect a crash. We also share personal information with third party partners that provide services and features available through our Premium subscriptions, such as Emergency Dispatch services. Similarly, we may share personal information with third parties that you have connected to your Life360 account to facilitate the features or services, such as Google if you have enabled the Life360 Action on any Google Assistant-enabled device. Any information provided to these third parties will be governed by that third party’s own privacy policy.

(e) Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

(f) Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of Life360, its users or others.

2.2  Annex 1 and Annex 2 contain further information about some of the parties with which we may share your personal information.

2.3 We may also share your geolocation and movement data, mobile device information (such as information generated by the gyroscope and accelerometer in your device) and application analytics, including IP address and device identifiers, driving event data and information provided by you during your registration of a Life360 account or as part of your use of our Service s with Arity 875, LLC ("Arity"), which provides driving analytics behavior services to enable us to provide certain functionalities of the Service, such as driving event history and crash detection. Arity uses this information to analyze your driving behaviors, such as speed, change in speed and other aspects of how, how much, where and when you drive in order to predict driving risk and calculate a driving risk score. Arity is a data controller of this personal information, and processes it to the extent necessary for its legitimate business interests, namely improving its analytics and predictive driving behavior models and improving its service generally, as further described in their privacy policy, which can be found at https://www.arity.com/privacy/. Please see “Your Choices About Your Information” to learn how you may be able to limit some of this data sharing with Arity.

3.  YOUR LOCATION

3.1 We collect information about your location in order to provide you certain functionalities of the Service.

3.2 We will collect your location where it is necessary for the purposes of providing you with the location-based services features of the app as well as for the legitimate interests of Life360 or our business partners, such as for data analytics into safe driving modelling. Where you have given us your consent to do so, we may also sell your location data to third parties for marketing and research purposes.

3.3 You can turn off location sharing in one or more of your Circles – if you do so, we will continue to collect your location information in order to provide you the Service. You can withdraw your consent  sharing your location with third parties for advertising purposes through the in-app Privacy & Security settings.

3.4 You can also stop sharing your location with us at any time by updating the settings on your mobile device to limit the app's access to your location information. Please note, however, that we may not be able to provide all of the functionalities of our Services to you if you disable access to location data.

3.5 If you no longer want to continue using the Service, uninstalling the Life360 app or logging out from the Service will also stop us from collecting your location.

4.  MARKETING MESSAGES AND NOTIFICATIONS

4.1 From time to time, we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

4.2 We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.

4.3 You can change your preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters.

4.4 Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Service.

5.  TARGETED ADVERTISING

5.1 We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices you may use. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, and information about your use of third party applications, and may combine this information with information they collect directly through tracking technologies or that they receive from other partners, both online and offline, so that they may recognise you across various devices you use, including computers, mobile devices and Smart TVs.

5.2 Where you have consented to us doing so, we may also share your precise geolocation data with advertising partners. We and our advertising partners use the information we collect about you to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.

5.3 To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices.

5.4 You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.    

5.5 Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out from receiving interest-based ads on that specific device, but you may still receive interest-based ads on your other devices. You must perform the opt-out on each device you use.

5.6 To opt-out of Life360 sharing data with third parties for advertising purposes. To adjust your data sharing preferences and to opt-out of Life360 sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out or adjust your preferences through the Data Platform page in the in-App Privacy settings. Please note, some third-party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.

6.  STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

6.1  Security. We implement appropriate, commercially reasonable technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

6.2  International Transfers of your Personal Information. As we are located in the USA, any information we collect from you will initially be collected and stored in the USA. If you are in the EEA, Switzerland or the UK, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will implement appropriate safeguards to ensure that your personal information is treated securely and in accordance with applicable EEA and UK privacy law and this privacy policy, including: (i) ensuring that we use your personal information in accordance with standard data protection clauses adopted by the European Commission for transfers of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to the same standards. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this privacy notice.

6.3  Privacy Shield. We comply with the EU-U.S. Privacy Shield framework and Swiss-U.S. Privacy Shield framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union countries (including Lichtenstein, Norway and Iceland) and Switzerland transferred to the United States pursuant to the Privacy Shield ("Privacy Shield"). We have certified that we adhere to the Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity, purpose limitation, access, and recourse, enforcement and liability ("Principles") with respect to such data. If there is any conflict between the policies in this policy and the Principles, the Principles shall govern. To learn more about Privacy Shield, please visit the U.S. Department of Commerce Privacy Shield website: https://www.privacyshield.gov/. As of September 2020, the E.U.-U.S. Privacy Shield has been invalidated. Nonetheless, we have committed to adhere to these Principles with respect to the protection of personal data to ensure that your personal information is treated securely and in accordance with applicable laws.

6.4  Onward Transfer. Where we transfer personal information to a third party, will take reasonable and appropriate steps to ensure the third-party processes personal information for limited and specified purposes and in a manner consistent with our Privacy Shield obligations. Where the transfer is to a third-party agent acting on our behalf, we may be liable if such third parties fail to meet those obligations, and we are responsible for the event giving rise to the damage. In certain situations, we may be also required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

7.  USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

7.1  In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

7.2 If you wish to exercise one of these rights, please submit your request through the GDPR Rights for EU Users section of your in-App Privacy Settings and click on the option to “Request my Data,” “Delete my Data,” or “Reset Your Data Sharing Settings,” respectively.

7.3 You may also review and edit your contact and profile information by logging into your account on the app, and opt out of certain processing activities, such as the collection and sharing of your driving event data and movement data, by updating your in-App Privacy Settings. Please note that we may not be able to provide some functionalities of our Services to you if you opt-out of the collection and/or sharing of motion data or driving event data.

7.4 You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

8.  CONSENT

8.1 We are not required to obtain your consent for most of the processing activities that we undertake in respect of your personal information.

8.2 We may, however, need your consent for certain processing activities. If we need your consent, we will notify you of the personal information we intend to use and how we intend to use it.

8.3 If you have provided consent for certain processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our processing of your personal information before your withdrawal.

8.4 Where we share your personal information with your consent with third parties for marketing and related purposes, you may withdraw consent at any time via our in-app Privacy Centre.

9.  COOKIES AND SIMILAR TECHNOLOGIES

9.1 Our websites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website or access any of our other websites and also allows us to improve our websites.

9.2 Please see our for more information about the cookies we use on our website, and how to manage cookies.

9.3 Deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

10.  JURISDICTION AND ENFORCEMENT

10.1 As part of our participation in the Privacy Shield, we are subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

10.2 You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

11. CONTACT LIFE360 AND RECOURSE

11.1 In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the Privacy Shield. European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact us at [e-mail].

11.2 In the event that you are concerned about how personal information you have provided to Life360 has been used, please address your inquiry or complaint first to us at the address listed above. Life360 takes all concerns about privacy and use of personal information very seriously, and shall endeavour to reply to you within 45 days of receiving a complaint.

11.3 We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism provided by JAMS. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim for more information and to file a complaint. This service is provided free of charge to you.

11.4 If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions specified by the Principles, you may also be able to invoke binding arbitration to resolve your complaint. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://go.adr.org/privacyshieldfiling.html for more information and to file a complaint.

12.  LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

13.  OUR POLICY TOWARDS CHILDREN

13.1 The Service may only be used by children with the consent of a parent or person with parental responsibility over the child.

13.2 The age at which children need parental consent varies between EEA Countries. Please refer to Annex 3 to verify the minimum age at which children no longer need consent to use our Service (the "Minimum Age").

13.3 If you would like to grant your child access to the Service, you must provide consent through one of our available consent mechanisms, for example, by verifying your government-issued identity document (not available in all jurisdictions) or returning the consent form available at https://www.life360.com/pdf/consent.pdf by mail or email using the contact details at the end of this policy.

13.4 We will use the personal information of users under the relevant Minimum Age as set out in this privacy policy. We do not, however, use or share personal information collected from accounts of children under the Minimum Age for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. We also do not contact, or permit third parties to contact any children under the Minimum Age who access or use our Service. However, other users with whom the child has added to his or her Circles will be able to contact the child.

13.5 If you become aware that your child has provided us with personal information without your consent, please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

13.6 If you would like to review or delete any personal information we have collected from the child, or to withdraw permission for us to collect any information from the child, please contact us at [e-mail].

14.  CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

15.  NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

16.  CONTACTING US

16.1 Please contact [e-mail] if you have any questions, comments and requests regarding this Privacy Policy.

16.2 If you have any questions about the Arity services, please review the Arity privacy policy at www.arity.com/privacy/ or contact Arity at [e-mail].