STARFISH Canada Specific Schedule to Mobile Privacy Policy

Effective Date: 21 Jan, 2021

Updated: 21 Jan, 2021

This Canada specific privacy policy (“Canada Privacy Schedule” or “Schedule”) serves to clarify and/or supplement parts of the STARFISH Mobile Privacy Policy (“Privacy Policy”) main Privacy Policy for users who are located in Canada. The provisions of this Schedule reflect the strictest requirements under provincial, and, where applicable, federal privacy legislation in Canada (collectively, “Canadian Privacy Legislation”).

The capitalized terms used in this Schedule that are not specifically defined herein have the same meaning as set forth in the Privacy Policy.

Where any term or provision of this Schedule conflicts with or is inconsistent with any term or provision contained in the Privacy Policy, the terms and provisions of this Schedule, as they apply to Canadian users of the Products, shall prevail.

Purpose for Processing Personal Data

We collect your Personal Data for the following purposes:

Provide Our Products: We process your account and profile data, device information, usage data, location information, and information related to your Smart Devices to provide you with our Products that you have requested or purchased.
Improve Our Products: We process your device information, usage data, location information and information related to your Smart Devices to ensure the functions and safety of our Products, to develop and improve our Products, to analyze the efficiency of our operations, and to prevent and trace fraudulent or inappropriate usage.
Non-marketing Communication: We process your Personal Data to send you important information regarding the Products, changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications.
Marketing Communication: We will ask you when you first log in to the STARFISH App whether you would like to receive any special offers or promotions relating to our Products. We collect your Personal Data to send you these communications, depending on the options you choose. If you would like to receive updates and offers related to the Products, please log in to your STARFISH account and select “Communication Preferences”. You can unsubscribe to receiving these communications anytime by visiting your “Communication Preferences” in your STARFISH App account, or by clicking “unsubscribe” and/or “update your email preference” at the bottom of any promotional email you receive from us. Please consult the “Managing Your Preferences” section in the Privacy Policy for additional information about unsubscribing to these communications.
Legal Compliance: We may process your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including you; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

International Transfers of Personal Data

As we explain in our Privacy Policy, there may be times when we need to share your Personal Data with others, including others located outside of Canada. In this section, we explain in what circumstances we may transfer your Personal Data outside of Canada, the countries outside Canada that may receive your Personal Data and the purposes for which your Personal Data is transferred.

We share your Personal Data with the following service providers, located in the following countries:

Service Provider	Country	Personal Data shared	Purpose for sharing Personal Data
Tuya Hangzhou (subsidiary of Tuya Inc.)	China	All data including personal data	Data processing activities are managed by Tuya Hangzhou. Such data processing activities include: collection, operation, structuring, storage, adaption or alteration, retrieval, consultation, use, alignment, combination, destruction, erasure, destruction, encryption, desensitization all of which allows Satco Products, Inc. and Tuya Inc. to operate the STARFISH App and collect, use and disclose user personal information for the purposes set out in this privacy policy.
Amazon Web Services, Inc.	United States	All data including personal data	Data hosting and storage
Nexmo LLC	United States	Phone number	To enable app users to receive phone notifications (voice and SMS) and to authenticate user identity. .
The Dark Sky Company, LLC.	United States	Longitude and latitude	Weather service: DarkSky receives user longitude and latitude data so that personalized weather information can be reported on the App.
Geetest - Wuhan Jiyi Network Technology Co., Ltd.	China Data processing is in US	IP address	For security purposes and specifically for user identity verification.

We may engage additional or different service providers from time to time and will update the above list on a regular basis to ensure that this Schedule accurately reflects the affiliates, subsidiaries, service providers and countries to which your Personal Data is disclosed. If you have any questions or concerns about the transfer of your Personal Data outside of Canada, please contact our Privacy Officer at the contact information provided below.

Please note that when your Personal Data is in the custody or control of a third party in another country, including the service providers noted above, it is subject to the laws of that jurisdiction and may be accessed by the courts, law enforcement and national security authorities in that jurisdiction.

Your Rights Relating to Your Personal Data

As set out in the Privacy Policy, we respect your rights and control over your Personal Data.

If you are located in Canada, you have the right to:

request access to the Personal Data that we process about you;
request that we correct inaccurate or incomplete Personal Data about you;
opt in or out of receiving special offers and promotional information from us about the Products; and
make a complaint or ask us questions about your Personal Data. If you have any questions, complaints or concerns about our practices or this Schedule, please contact us using the contact information provided below under “Contact Us”.

Requests to Access or Correct Your Personal Data

Users located in Canada have the right to access certain Personal Data in our custody or under our control, including information about the use and disclosure of your Personal Data, unless the information requested is subject to an exception under applicable law. Exceptions may apply, for example, where the information is covered by legal privilege or where the information would disclose the Personal Data of other individuals who have not provided their consent to the disclosure. We will advise you of the reason for the refusal if we do not provide you with access to certain Personal Data.

It is also important that your personal information is up to date and accurate. If you wish to request access to your Personal Data or wish to correct or update your Personal Data, please contact us by:

sending us a message via the “Profile – Personal Center” in your STARFISH App account;
emailing us at starfish@satco.com; or
sending us a letter at Satco Products, Inc. 110 Heartland Blvd, Brentwood, New York 11717.

Your access request must be made in writing and must provide sufficient detail to allow us to respond to your request. We may require you to pay a reasonable fee to process your request and we will aim to respond you within 30 days. Please note that we may ask you to verify your identity before taking further action on your request, for security purposes.

If you have any questions, complaints or concerns about our practices or this Schedule, or you wish to access or correct your Personal Data, please contact our Privacy Officer at:

STARFISH

Postal Mailing Address: Satco Products, Inc. 110 Heartland Blvd. Brentwood, New York 11717

Email: starfish@satco.com