Last Updated: May 15, 2025

Smarter Technologies LLC (“Smarter Technologies”, “we”, “our”, or “us”) is committed to protecting your personal information. This Privacy Policy (this “Privacy Policy”) explains how Smarter Technologies collects, uses, and discloses information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). We may obtain Personal Information directly from you when you interact with us on our website at www.smarter-technologies.com (our “Website”) or when you engage with us in other ways.

This Privacy Policy is incorporated into and made part of our Terms of Service, at www.smarter-technologies.com (“Terms”). By accessing and using the Website, you agree and consent to the collection, use, processing, and disclosure of your Personal Information as outlined in this Privacy Policy. If you have any questions about this Privacy Policy or the Terms, please contact us using the contact information located in the “Contact Us” section below.

PLEASE NOTE: Smarter Technologies does not diagnose or treat any disease or disorder. Smarter Technologies does not recommend or endorse any particular medical treatment but encourages patients to seek the advice of their clinicians.

Personal Information We Collect

We and designated service providers may collect and process the following categories and examples of Personal Information about you:

• Identifiers, such as your name, email address, physical address, telephone number, fax number, unique personal identifier, online identifier, or other similar identifiers.
• Professional Information, such as your name, address, telephone number, education, employment, employment history, credit card number, or any other financial information.
• Protected classification characteristics under California or federal law, such as your age, race, citizenship, marital status, sex, veteran, or military status.
• Commercial information, such as your account activity, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies.
• Internet or other similar network activity, such as browsing history, search history, information on a consumer's interaction with a website, application, or advertisement (e.g., visitor domain name, IP address, web browser, operating system, internet service provider, the pages visited, clickstream data, and time and date of visit).
• Sensitive Information, such as personal information collected and analyzed concerning a consumer’s health and genetic data, from collaborators and service providers.
• Other Information You Choose to Provide, such as when you otherwise engage with us, including by email, phone, mail, or in person.

Sources of Personal Information

Smarter Technologies collects the above categories of Personal Information from:

• Your communications with us;
• Service providers;
• Affiliates;
• Business and marketing partners;
• Collaborators, which may include nonprofit and for-profit organizations;
• When you visit our offices or facilities;
• Nonprofit organizations;
• Government entities;
• Business transferees;
• Automatically via cookies and similar advertising technologies.

How We Use Personal Information

Smarter Technologies uses Personal Information for various purposes, including to:

• Set-up, validate, and administer your account on our Website;
• Provide, operate, maintain, plan, and improve our Website, programs, services, and products;
• Process donations, registrations, job applications, or requests for information;
• Create reports and analytics for our customers;
• Monitor and analyze trends, usage, and activities in connection with our Website, including to conduct data analytics so that we can better understand the individuals we serve, better communicate with you, and improve our services;
• Communicate with you about events, products, or services, and to provide news and information we think will be of interest to you;
• Help you engage with other individuals with similar interests to help mobilize people, organizations, and networks for public good;
• Send you technical notices, updates, security alerts, and support or administrative messages;
• Respond to your comments, questions, and requests, or to provide customer service;
• Detect, investigate, and prevent security incidents, fraudulent transactions and other illegal activities and protect the rights and property of Smarter Technologies and others;
• Maintain appropriate records for internal administrative purposes; and
• Carry out any other purpose described to you at the time the information was collected.

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located at the bottom of our e-mails or contacting us using the “Contact Us” section below.

We may also de-identify and aggregate the information that we collect. De-identified and aggregated information can no longer reasonably be linked to the identity of a person and is no longer Personal Information.

We do not sell any personal data to third parties. We may share personal data for purposes of cross-context behavioral advertising. You may opt-out of the sharing of your personal data by updating your cookie preferences as described below in the “Cookies” section.

How We Disclose Personal Information

We may disclose Personal Information, as follows, or as otherwise described in this Privacy Policy:

• With our collaborators and customers;
• With vendors, consultants, contractors, and other service providers who need access to such information to carry out work or perform services on our behalf;
• In response to requests from local, state, provincial, or federal law enforcement officials, or any judicial, administrative, or similar proceeding or order, such as a subpoena, if we believe disclosure is in accordance with applicable law;
• To protect the rights, property, and safety of Smarter Technologies and others;
• To investigate suspected violations of our terms or policies, fraud, harassment, physical threats, or other violations of any law, rule, regulation, or the rights of third parties, or to investigate any suspected conduct which we deem improper;
• In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
• Between and among Smarter Technologies and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;
• With your consent or at your direction;
• To comply with transparency or other public reporting obligations; and
• As otherwise permitted or required by law, rule, regulation, court order, governmental official, legal authority, or similar requirements.

We may also use and disclose aggregated or de-identified information, which cannot reasonably be linked to the identity of a person, for lawful business purposes.

U.S. Consumer Privacy Rights

In some jurisdictions, applicable law may entitle you to certain rights regarding your personal data. The rights available to you depend on our reason for processing your personal data and the requirements of applicable law (i.e., your rights will vary depending on where you are located; for example, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the “CCPA”) provides California residents with certain rights regarding their personal data held by businesses to which the CCPA applies). These rights may not apply to Personal Information that is subject to certain other legal regimes when held by us, such as protected health information that we hold as a business associate that is covered by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”).

• Know and Access: The right to confirm whether we are processing your personal data and know what of your personal data we are processing, and to request access to your personal data.
• Correction: The right to request that we correct your personal data if that information is inaccurate, taking into account the nature of the personal data and the purposes of our processing of the personal data.
• Deletion: The right to request that we delete personal data you have provided or that we have obtained about you.
• Portability: The right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily useable format that allows you to easily transmit the data to another controller, subject to certain exceptions.
• Non-Discrimination: The right to not be discriminated against for exercising your privacy rights.
• Opt-out of Sale and Targeted Advertising: The right to opt-out of the sale or sharing of your personal data for cross-context behavioral advertising. Like many companies, we use services that help deliver interest-based ads to you. Our use of some of these services may be classified under California law as “sharing” personal data with the advertising partners that provide the services. You can submit requests to opt-out of this “sharing” by emailing us at help@smarter-technologies.com.
• Sensitive Information: The right to limit the use and disclosure of sensitive personal information collected about you.

Submitting Consumer Requests

If you wish to exercise any of the consumer privacy rights mentioned above, please email help@smarter-technologies.com with the phrase “U.S. Consumer Rights” in the subject line.

We will review your requests and respond accordingly. The consumer privacy rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. Additionally, if we retain your Personal Information only in de-identified form, we will not attempt to re-identify your data in response to a consumer privacy rights request.

If you make a consumer privacy rights request, we may need to verify your identity. To do so, we will request that you match specific pieces of information you have provided us previously. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If we are unable to verify your identity, we will need to deny your request.

If you make a consumer privacy rights request through an authorized agent, we will require written proof that the agent is authorized to act on your behalf. In addition, we will ask you to either (1) verify your identity directly with us in the manner described above or (2) directly confirm with us that you have provided the agent permission to make the request on your behalf.

Children’s Privacy

Smarter Technologies is committed to protecting the privacy of children. Our Website is not intended for or designed to attract children. In addition, we do not knowingly collect through our Website Personal Information from any person known by Smarter Technologies to be a child under the age of 13.

Security and Retention

We seek to use reasonable physical, technical, and administrative measures designed to protect Personal Information within our organization. Unfortunately, no data transmission, processing, or storage system can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any Personal Information or other information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately notify us in accordance with the “Contact Us” section below.

Your Personal Information will be retained for as long as you maintain a business relationship with us and afterwards in accordance with our legal and regulatory obligations. When deciding how long to retain your Personal Information, we take into account our legal and regulatory obligations, the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means. We may also retain your Personal Information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.

Links to Third-Party Websites

Our Website may reference or provide links to third-party websites. Other websites may also reference or link to our Website. Because these websites are not controlled by Smarter Technologies, we are not responsible for the third-party websites. We encourage our users to be aware when they leave our Website to review the privacy policies posted on other websites that may collect Personal Information. Please be aware that Smarter Technologies does not control, endorse, screen, or approve, nor are we responsible for, the privacy policies or information practices of third parties or their websites or mobile applications. Visiting these other websites is at your own risk.

Cookies

We use cookies to enhance your use of the Website and to better adapt the Website to your preferences. Cookies enable us to show you the pages you have most recently visited from the Site, to gather specific information from your previous visits to the Website and to recall features that you may have customized on your browser. We use Google Analytics to provide analytics services. Google Analytics may use cookies and similar technologies to collect information about your use of the Site, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information to help us analyze how visitors use our Site. For more information on Google Analytics, including how Google Analytics collects, uses, and discloses information, refer to the following page: https://policies.google.com/technologies/partner-sites. If you do not wish us to collect information via the cookies on your computer, you should configure your browser to choose not to have cookies stored; most browsers allow you to do this. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Website.

We do not respond to Do Not Track (“DNT”) signals to the extent received from a web browser. Because there currently is not a universally accepted technological or legal standard for recognizing or honoring DNT signals as reflections of user choice, we do not respond to them at this time.

Updating Your Information

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You may update, correct, modify, or delete information about you at any time by contacting us using the “Contact Us” section below. Please note, we may continue to store information about you as required by law or for legitimate business purposes.

Additional Notice for California Residents (California Shine the Light)

If you are a California resident, California Civil Code Section 1798.83 permits you to request information about our practices related to the disclosure of your Personal Information to certain third parties for their direct marketing purposes. You may be able to opt-out of our sharing of your Personal Information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. Smarter Technologies does not currently share Personal Information with third parties for such third parties’ direct marketing purposes.

Updates to this Privacy Policy

We reserve the right to change the terms of this Privacy Policy at any time by posting the new Privacy Policy on the Website. All changes to the Privacy Policy will be effective when posted (or as otherwise indicated at the time of posting), and your continued use of the Website after any such revision is posted will be deemed acceptance of such changes. It is important to review this Privacy Policy periodically for the most current version.

United States Only

The Website is intended for use only in the United States of America. We are based in the U.S. and the information we collect is governed by U.S. law. By accessing or using the Website or otherwise providing information (including Personal Information) to us, you consent to the processing and transfer of such information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Where this is the case, we will take appropriate measures to protect information about you in accordance with this Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or concerns about the way Smarter Technologies processes your information, or require assistance in managing your privacy choices, please contact us at help@smarter-technologies.com.

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