PRIVACY POLICY FOR EMERSON HOME CAM AND DOORBELL APP

Effective Date: May 24, 2022

This Privacy Policy (“Privacy Policy” or “Policy”) describes the types of personal information gathered by Emerson Radio Corp. (“Emerson”, “us”, “we” or “our”) in providing the Emerson Home Cam application, Emerson Doorbell application and supporting services, information, tools, functionality, and updates (collectively, the “Services”), how we use it, with whom the personal information may be shared, what choices are available to you regarding collection, use and distribution of personal information and our efforts to protect the personal information you provide to us through the Services. By using the Services, you hereby consent to allow us to process information in accordance with this Policy.

This Privacy Policy only describes Emerson’s practices in relation to the Emerson Home Cam app and Emerson Doorbell app. If you have other Emerson products or services, Emerson may provide other or supplemental privacy policies to individuals for other products or services that we offer, including at the time we collect personal information.

This Policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Services and/or otherwise making you aware of the changes. Please refer to the “Effective Date” above to see when this Policy was last updated.

Personal Information We Collect

Information you provide to us. We collect certain personal Information about you or about those you identify, which may be supplied when you interact with the Services, register for the app, complete a survey, make a purchase, when you request services or otherwise when you submit such information. The information collected may include one or more of the following:

· Contact data, such as your first name, last name and email address.

· Profile data, such as the username and password that you may set to establish an online account with us and any other information that you add to your account profile.

· Communications that we exchange with you, including when you contact us with questions or feedback, through the Services or otherwise.

· Visual and audio signals and data, such as the recording or streaming features of the Services that you may enable. We may record and process video and/or audio recordings from the device in accordance with your instruction, configuration and settings. If you instruct us by setting up the Services and choosing to receive mobile notifications, we may process information from you to send you alerts.

· Third Parties’ contact data, such as the contact information that you provide to us to allow the Services to share information with the third parties you’ve indicated at your instruction through the Services.

· Error log data, such any errors or functionality problems experienced by the you that you share with us through the Services or otherwise.

· Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic Data Collection

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Services, our communications and other online services, such as:

· Device data, such as your mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

· Activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, and access times and duration of access.

· Mobile Location data when you authorize the Services to access your device’s location to enhance the Services features such as features that require WiFi connectivity.

How We Use Personal Information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service Delivery. We may use your personal information to help us provide, operate and improve our Services, establish and retain your user profile on our Services, enable security features of the Services, fulfill your requests, send materials to you, communicate with you about the Services, tailor our Services to meet your interests, and for other purposes permitted by law.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Services and our business.

Compliance and protection. We may use your personal information to:

· comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

· protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

· audit our internal processes for compliance with legal and contractual requirements or our internal policies;

· enforce the terms and conditions that govern the Service; and

· prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

Cookies and similar technologies. We may use these for the purposes outlined in the “Cookies and similar technologies” section above.

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as 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, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it or isolate it from further processing.

How We Share Your Personal Information
We may share your personal information with our business associates, consultants, service providers, third parties designated by you, professional advisors and affiliates in order for them to provide services to us, to you, and to enable us to provide the Services. For example, with third parties that provide services on our behalf or help us operate the Services or our business such as hosting, information technology, customer support, email delivery, and consumer research.

Further, we may disclose personal information, to the extent we believe it necessary to comply with the law, such as in response to a subpoena or court order, to defend a legal claim or establish or protect our legal rights or otherwise as permitted by applicable law. We may disclose any information in our possession in the event that we believe it necessary or appropriate to prevent criminal activity, personal injury, property damage or bodily harm.

Additionally, we may transfer your information to a successor in interest, which may include but may not be limited to a third-party in the event of an acquisition, sale, asset sale, merger or bankruptcy. The policies applicable to your information thereafter may be determined by the transferee.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.Your Choices

Access or update your information. If you have registered for an account with us through the Services, you may review and update certain account information by logging into the account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

Other Sites and Services
The Services may contain links to other websites. We are not responsible for the privacy practices of such other sites. When you leave our Service to visit another website or application, please read the privacy statements of websites that may collect personally identifiable information. This Privacy Policy applies solely to information collected by us through the Services.

Security
We employ procedural and technical safeguards that are designed to secure your personal information against loss, theft, alteration, and unauthorized access, use and disclosure. We also employ security procedures that are designed to protect your information from unauthorized access by users inside and outside the company.

Regardless of the precautions we take, no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. We cannot ensure or warrant the security of any information you transmit to us.

Territoriality
Regardless of where our servers are located, your personal information may be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY USING THE SERVICES, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND THAT U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

E-Mail and Electronic Newsletters
We may offer electronic newsletters and e-mails concerning our Services, as well as new products and services, or may provide other marketing materials as a service to our users. Users may receive newsletters and e-mails concerning promotions and marketing of ours, after registering with the Services or after engaging with us in person or through our agents.

If you have received a message from us, and you no longer wish to receive such materials, you may opt-out by following the unsubscribe instructions included in each electronic newsletter and e-mail.

Please note that you may be required to separately opt out of any e-mails sent by our business associates.

Children and Privacy
We do not knowingly permit users to use our Services if they are under 13 years old, and therefore do not request personal information from anyone under the age of 13.

If we become aware that a user or customer is under the age of 13 and has registered without verifiable parental consent, we will remove his or her personal information from our files. If you are the parent or guardian of a person under the age of 13 who has provided personal information to us without your approval, please inform us by contacting us at the e-mail address below and we will remove such information from our database.

Do Not Track
At present, the Services do not specifically respond to browser do-not-track signals.

Contact Information
If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at internet@emersonradio.com.