SafePath® Privacy Notice

Last updated: June 27, 2023

Smith Micro Software, Inc. and its subsidiaries (collectively, “we,” “us,” or “Smith Micro”) are committed to maintaining your trust by respecting and protecting your privacy. In furtherance of our continuing commitment to transparency, this SafePath Privacy Notice (this “Notice”) provides information about how and why our SafePath Service collects, uses, and shares your personal data. This Notice is in addition to and supplemental to Smith Micro’s general Privacy Policy, which you should read as part of this Notice. For more information about our data processing practices and any rights you may have, please see our general Privacy Policy.

Our SafePath solution is a family location and parental controls service developed and made available to our wireless carrier and cable service provider customers and their subscribers. The SafePath service (“SafePath” or the “Service”) is delivered through a mobile application (the “SafePath App”), a web interface, and access to a cloud-based platform, and, only when you use SafePath Home, a software application installed on your wireless router or modem. References in this Notice to SafePath and/or the Service include all of these components.

SafePath allows the original creator of an account to use the Service (the “Account Owner”) to invite additional family members to join their account to use the Service (“Account Users”). As you read through this Notice, please note that “you” and “your” refers to the individual user of SafePath, whether as Account Owner or Account User.

Before accessing or using SafePath, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this Notice and in our general Privacy Policy.

WHAT THIS NOTICE COVERS

This Notice applies to personal data that we collect or otherwise process when you access, use or sign up for the Service or when you communicate or interact with us in connection with the Service. Personal data is defined as data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be used to identify an individual person. Personal data includes data such as your name, address, email address, and phone number, as well as other data, such as your SafePath password, demographic data, device data, and profile data. It also applies to data that is considered sensitive personal data, which includes things like precise geolocation data. For purposes of this Notice, personal data includes “personal information” and similar terms as defined under applicable privacy laws.

This Notice does not apply to data that is not personal data, including anonymous, de-identified, or aggregated data, even when such data has been derived from personal data.

By accessing or using the Service or otherwise engaging with us, you acknowledge our collection, use, and sharing of personal data as described in this Notice and in our general Privacy Policy. Accordingly, we encourage you to read this Notice and our general Privacy Policy carefully.

Future Changes

We may update this Notice and/or our general Privacy Policy from time to time. If we make changes, we will notify you by revising the “last updated” date at the top of the Notice or Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our SafePath web interface or sending you a notification). Your continued use of the Service after we have notified you of changes indicates your acknowledgement and acceptance of these changes.

HOW AND WHY WE COLLECT PERSONAL DATA ABOUT YOU

We collect personal data about you in connection with your access and use of the Service primarily in three ways: directly from you, automatically from your use of the Service, or from unaffiliated third parties.  The types of personal data we collect , the purposes for which we use it and how long we store it are described below and in our general Privacy Policy under the heading “How We Use Personal Data.”  We do not sell your personal data or share it with unaffiliated third parties for their marketing purposes.

Personal Data You Provide Directly to Us

We may collect personal data directly from you in a variety of ways, including when you sign up for the Service, create or modify an account, fill out a form or survey, interact with our representatives, or submit information through the Service. The personal data we collect directly from you may include:

  • Account information, such as your name, username or alias, passwords, telephone number, email address, and the dates on which you sign up for and/or unsubscribe from the Service.
  • Your account settings, such as the SafePath features you elect to use, parental controls parameters, and safety zones.
  • Demographic information that you choose to provide, which may include your selected language, if the Service is offered in multiple languages.
  • Your photograph, if you choose to assign a photograph to your profile.
  • Other information you choose to provide, such as when you submit a survey response or contact our representatives.

This information is processed for the purposes of account creation and authentication and otherwise to deliver the Service to you and your related users, and is retained for the lifetime of your account in the Service.

Personal Data We Collect Automatically

We automatically collect personal data associated with your the use of the Service. The personal data we collect automatically may include:

  • Information about the device(s) you use in connection with the Service, including network access indicator, IMEI and/or other device unique identifiers. This information is processed for the purpose of delivering the Service to you and your related users and is retained for the duration of your account in the Service.
  • Usage information about your use of the Service, including your wireless carrier, the Internet Protocol (“IP”) address, websites and URLs visited, mobile apps installed or used or that interact with your device, and other network analytics and Wi-Fi usage data. This data is processed for the purpose of delivering the Service to you and your related users, and is retained for a period of seven days.
  • Device and service performance and diagnostic information, including reports from your device about signal strength, data speeds, app and service performance, data failures, geolocation information associated with such events, and device data such as battery strength, settings, language preferences, and software versions. This data is processed for the purpose of delivering the Service to you and your related users and is retained for as long as the device is associated with your account.
  • Parental controls settings, including the user-selected filter type, sites filtered, bedtimes, off times, and time limit, including the user-selected filter type, sites filtered, bedtimes, off times, and time limits, and iOS screen time. This data is processed for the purpose of delivering the parental controls features of the Service to you and your related users and is retained for the duration of your account in the Service.
  • Device geolocation data, specifically data that identifies the approximate or precise location of your mobile device and any Internet of Things (“IoT”) devices that you use with the Service. . The data is processed for the purpose of delivering the location-based features of the Service to you and your related users and is retained for the duration of your account in the Service.
  • Contact list data, if you invite your selected contacts to participate in features of the Service with you, we collect data from the contact list entries that you select, such as first and last name, email address, phone number, and contact photo, to make it easier for you to configure the settings for these features, which may include location-based services and/or check-in functionality.
  • Driving data, which includes things like driving behaviors and events, if you have SafePath Drive features enabled. The data is processed for the purpose of delivering the location-based features of the Service to you and your related users and is retained for the duration of your account in the Service.

Personal Data We Collect from Other Sources

We may collect personal data about you from other sources that are unaffiliated with us. For example, we may obtain some of your personal data from the carrier or other third party company through or in relation to which you are being provided access to the Service. This information could include contact information, demographic information, geolocation information, and information about your interests, preferences, or behaviors. We use this data to facilitate third party evaluation of our Service and for things like Service improvement and promotion. For more information see the “How We Use Personal Data” section of our general Privacy Policy.

 

* * * * *