Last Updated and Effective as of: December 21, 2021

PRIVACY STATEMENT FOR BEAGLE SERVICES, INC.

At Beagle, we take your privacy seriously.

This Privacy Statement for Beagle Products and Services (“Privacy Statement”) describes information that Beagle Services, Inc., and its subsidiaries and affiliates (collectively, “Beagle”), collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information). By accessing our sites or providing us your information when you contact us, you are consenting to the information collection and use practices described in this privacy statement.

This document focuses on information related to the use of all Beagle products and services, including www.beagleservices.com and other products from Beagle (collectively, “Beagle Products”). In this Privacy Statement, the expression “Beagle Products” also includes our Beagle Guarantee as defined in the Beagle Guarantee Terms and Conditions.

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

We reserve the right to change this Privacy Statement at any time, so please review it periodically. We may notify you in the event we make changes to this Privacy Statement. If you have any questions regarding this Privacy Statement, you can contact Beagle by email at support@beagleservices.com or by telephone at +1 (424) 226 - 6101.

Our Pledge

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

2. We will use data responsibly. When using or sharing data with third parties, we'll generally do so for purposes of providing or enhancing Beagle Products, and when we think they will provide you with a welcome additional service. In certain circumstances, a third party (such as your home insurer, home warranty provider, or plumber) may pay for the Beagle Products, subsidize, discount or pay for part of the Beagle Products, and/or some or all of the Beagle Products (a “Third-Party Payer”). In that circumstance, you are deemed to have consented to permit Beagle to share data collected from the Beagle Products, including your personal information, with that Third-Party Payer.

3. We will use industry standard data security tools to keep your data safe and protect the Beagle Products from unauthorized access. Beagle is committed to protecting the security of your personal information and data. We use a variety of security technologies and procedures to help protect this information from unauthorized access, use or disclosure.

Your ConsentConsent to data collection and processing

By using Beagle Products, you agree to allow us to collect and process information as described in this Privacy Statement. You acknowledge that monetizing data is part of Beagle's business model, and helps allow Beagle to provide the Beagle Products and Services; as such, you consent to Beagle using and monetizing your data.

Consent to data export

Your personal information may be collected, processed and stored by Beagle or its service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. If you are using Beagle Products in the European Union or other regions with laws governing data collection and use that may differ from United States law, you consent to the transfer of your personal data to the United States and other countries where Beagle operates.

What information does the Beagle Device collect?

The Beagle Device may collect:

∙ Setup, account and on-boarding information you provide, or as provided by a third party, including but not limited to your name, email, password, home address, phone number, and other home plumbing or construction information.

∙ Data from third-party products that Beagle may install on your property, including but not limited to alarms, notifications, user preferences, settings, and user actions.

∙ Other data collected by Beagle via third party systems you’ve authorized Beagle to collect.

Setup information you provide

When you first use the Beagle Products, you may be asked several questions in order to help us create your user experience. For example, we mayl ask for information about your property type (i.e. a single family home), the number of occupants and size of the home, or your home address or postal/ZIP code, or other information about your home plumbing and/or construction. This information helps us to customize your experience to help protect your home. We will also collect information as you use the Beagle Product – whether by using the Beagle website, contacting customer support, or providing information to our employees.

Technical information from third party products

In order to improve your experience over time and help troubleshoot any problem you may encounter with third party products, we may record the model numbers and serial numbers, software versions, and other technical information about internet of things products and plumbing fixtures or appliances at your property.

How does my Beagle information or account interact with third parties?

Beagle may use third parties to provide some services on its behalf. For example, Beagle may use third parties to host its websites, send you notifications, conduct surveys, or process transactions, among other services. Beagle may share information with third parties in order to deliver Beagle’s services efficiently to you.

To perform certain services, track issues, improve our customer experience, and assist in analyzing how our Service is used, Beagle may use third party services that may collect information used to identify you.

Additional information about the limited circumstances in which information from your Beagle account may be shared with third parties is described below in the section titled “In what circumstances does Beagle share my information?”

Any Beagle data that you choose to share with a third party is governed by that third party’s privacy policy while in that party’s possession. Although Beagle tries to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites or third parties.

Any data that Beagle receives from third-parties will be processed and stored by Beagle and will be treated in accordance with this Privacy Statement. This information may be processed in the same ways as any other data that is a part of your Beagle account.

Basic Customer Information

When you become a Beagle customer, we collect and store information which may include your name, phone number, address and/or email address. From that point forward, your information is used for communications from Beagle. In addition, Beagle may provide you with the ability to enable individuals to access your account as additional authorized users, or to invite other individuals such as friends or family to share access to your content. We will ask you for the email address of any such individuals and automatically send an email invitation on your behalf. Beagle stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation services. Names and other information may be shown to others in connection with the Services. For example, if you invite someone as an additional authorized user, he or she may be able to see your name.

How does Beagle use the information it collects?

We may use this information to provide, develop and improve Beagle’s products and services, including to make assessments and recommendations about products, safety, water use, water security, water damage prevention, or other related products and/or services. We may use your contact details to send you this information, or to ask you to participate in surveys about your Beagle use, and to send you other communications from Beagle.

We may also use this information in an aggregated, non-identified form for research purposes and to help us make sales, marketing, and business decisions.

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

We use industry-standard methods to keep this information safe and secure while it is transmitted over your home network and through the Internet to our servers. Depending on your location and type of data, Beagle may process your personal information on servers that are not in your home country. Although the laws that protect personal information in those countries may differ from the laws where you live, we will take reasonable steps to ensure that your privacy is protected. By contacting us, using our Beagle Products, or using our Services, you consent to the transfer of the data outside of your country.

In what circumstances does Beagle share my information?

We do not share personal information for any commercial or marketing purpose unrelated to the activation, enhancement, research, services and delivery of Beagle products and services without asking you first, except as otherwise stated in this Privacy Statement.

The following are the limited situations where we may share personal information:

∙ With your explicit consent:
We may share personal information when we have your consent. One example of this would be if you invite another person to interact with Beagle on your behalf. Another example is if you sign up for programs offered by our partners (e.g., water utility, home warranty or insurance companies); if you do this, we may share certain information with the partner. This could include things like your enrollment information, service data and the activation status of your device. Also, as described above, in certain circumstances, a Third-Party Payer (such as your home insurer) may pay for the installation of products by Beagle, in which case you are deemed to have consented to permit Beagle to share data collected from the Beagle Products, including your personal information, with that Third-Party Payer.

∙ For certain transactions:
In connection with certain transactions, we may disclose some or all of your personal information to commercial partners, insurers, financial institutions, government entities and shipping companies or postal services involved in fulfillment of the transaction without further notice to you. Disclosures may occur on an ongoing basis pursuant to Beagle's agreements with such commercial partners, insurers, financial institutions, government entities and shipping companies or postal services.

∙ For external processing:
We may use vendors, service providers, and technicians to help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring Beagle systems to facilitate our operations.

∙ As part of business transitions:
Circumstances may arise where, for strategic or other business reasons, Beagle decides to sell, buy, merge or otherwise reorganize its businesses or commercial partnership. Such transactions may involve the disclosure of personal information to prospective or actual purchasers, or the receipt of personal information from sellers. We may disclose information we maintain about you to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of Beagle’s assets. Upon the completion of such a transaction, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.

∙ For legal reasons:
We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, to respond to legal process, or comply with state and federal laws (or the applicable laws of foreign countries other than the United States).

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. For example, we may publish trends about adoption rates of smart home plumbing technology. This information may also be shared with other users to help them better understand different smart plumbing solutions in the Beagle community, raise awareness about safety or conservation issues, or help us generally improve our products and services. We may also share non-personal information with our partners. We will take steps to keep this non-personal information from being associated with you and we require our partners to do the same.

Additional Information Regarding Insurance Pilots:

You may have agreed to participate in a pilot project between us and a third party involving the sharing of data collected by Beagle. In this case, Beagle and the insurance partner may have entered into an agreement in which Beagle will be providing to the insurance carrier, with your consent hereunder, data generated from your use of Beagle. By using Beagle through one of these pilots, you acknowledge that you have read, understood, accepted, agreed to be bound by and to comply with this Privacy Statement and the terms and conditions:

1) You agree to allow the insurer to access your information. Such information may include, but not be limited to, personally identifiable information about you, your property, the functioning of the plumbing equipment in your property, and other data that might provide the insurer with information about the risks of future water leaks in your property (collectively hereafter, “Data”). You agree and consent to allow us to license the Data to the insurer. Initially, the insurer may use the Data from the services offered by Beagle to the insurer. The use of the Data can be expanded into purposes, including underwriting/rating purposes, such as providing discounts to customers who enroll in an insurer's policy or discounting programs. Your consent to sharing the Data with the insurer is voluntary. Should you decide at any time to discontinue your participation in the sharing of Data with the insurer, you may do so by notifying Beagle of your intent to withdraw your consent.

2) Except as described in this Policy, Beagle will not share your Data without first explicitly asking your permission, usually in the form of a web page or email requiring you to indicate your acceptance of the terms.

Does Beagle save my personal information?

Beagle stores your personal information on Beagle’s servers in order to provide you with Beagle products and services. Personal information is encrypted as it is transmitted to Beagle and cannot easily be accessed. We may share, as described in this Privacy Statement, information with our affiliates and subsidiaries, and third parties. We may disclose information in response to legal process and lawful requests by public authorities in the United States and other countries for the purposes of law enforcement and national security. Please note that this Privacy Statement may change from time to time. If you have any questions, please contact us at support@beagleservices.com .