Privacy policy

Last modified on 23.04.2015.

At Smartfrog we take privacy seriously. We want you to understand and be comfortable with the ways in which we collect, process and use personal data (also called “personal information”) that we collect through our apps, websites, services, equipment and products (collectively, “our services”). This Privacy Policy explains how we collect personal information, and what we do with it. Please make sure that you read this Policy carefully. By using our services you consent to us using your personal information in the ways described below.

Without your consent to use your information in the ways set out in this Policy, we will not be able to provide you with our services.

1. Our Privacy Principles

Your privacy is important to us. When you use our products, we appreciate that you trust us to keep the personal information we collect and process safe and secure. We are committed to earning and maintaining that trust. We do this by following a set of basic privacy principles. These principles are a set of “dos” and “don’ts” that underpin how we think about privacy and how we operate our business.

These are our privacy principles:

  • We don’t sell personal information.
  • We don’t share your Video Feeds with unauthorised third parties.
  • We don’t collect personal information that we don’t need.
  • We are transparent and upfront about the ways in which we use personal information.
  • We only retain personal information for so long as is necessary, and then we delete it.
  • We delete personal information upon request (unless we’re required by law to keep it).
  • We deploy appropriate security to keep personal information safe and secure.
  • We adopt a “privacy by design” philosophy: privacy influences how we think about and build our products.

2. What information do we collect and process?

There are two broad categories of personal information that we collect and process: information you give us or which we infer from your registration and use of our services (“User Information”) and audio and video footage and images captured by our services (“Video Feeds”).

2.1 What User Information do we collect and use?

We collect two types of User Information:

  • Information you provide to us; and
  • Information collected by our services or other devices.

Information you provide to us

During the registration process you will directly provide us with certain information, such as your name, email address and any services that you are subscribing to. You may also provide us with address details if we are shipping equipment or products to you.

You may provide us with additional personal information if you email or call us.

Our services may allow you to invite other people, such as friends or family, to share access to your Video Feeds, or to use our services. You should get their permission before you send us this information. If you avail of this option you will provide us with that person’s email address and other details so that we can send an email invitation on your behalf.

We presently use a trusted third party payment provider and do not collect payment card information.

Information sent by our services or other equipment

When you use the internet it is customary and standard for certain information to be sent from your device to the server that you are accessing. This enables your device and that server to communicate with one another. Our services work in the same way. In other words, certain personal information is automatically sent to us when you interact with our services or visit our website on your computer or other device, including IP address, browser information and the web pages that you have requested on our website.

Similarly, technical information is obtained from devices and equipment that are connected to our services (either a camera or other equipment that we supply to you or another device that you have installed our app or software on). This may include device identifiers, software version, wifi strength and other technical information. Information about your app settings may also be received.

Data is received from our websites and apps through the use of cookies, SDKs and related technologies. This is explained in more detail in our Cookies Policy.

2.2 What Video Feeds do we process?

When you enable the recording or streaming features of our services, Video Feeds will be received and processed, subject to your settings. These Video Feeds consist of the video and audio content collected by your device.

3. How do we use the information we collect?

User Information

We process User Information:

  • To provide and administer our services – for example we will use the information you provide to create your account, make sure you receive the product you have requested, processing billing etc. We may also use the technical information we receive to identify and correct issues.
  • To contact you – your contact details may be used to contact you with service announcements or promotional messages (in accordance with applicable laws). These promotional messages may relate to our services or those of our trusted and handpicked partners. You can change your preferences around promotional messages at any time, but we reserve the right to contact you in connection to service related issues.
  • To send invitations – if you invite friends or family to view your Video Feeds, or to use our services, we use the information provided by you to send the email, to register your friend or family member if your invitation is accepted, and to track the success of our invitation services.
  • To improve our services – User Information provides us with insights into how our services are used. For example, it helps us understand what features people like and dislike. This allows us to continually improve our existing products, to create new ones, and to serve you better. This may involve providing you with customised content or options.
  • For security purposes and fraud prevention purposes – we may use User Information to keep our systems and users safe. For example, we may analyse transactions to identify potential cases of fraud.

Video Feeds

We process Video Feeds for a narrow set of purposes.

We primarily process Video Feeds to provide you with the services that you have requested. In other words, the Video Feeds are processed to enable you to review and playback the content captured by the camera and any related sound recordings.

In addition, Video Feeds may be processed to develop, improve and provide you with enhanced or value added features, products and services. For example, Video Feeds may be processed to identify motion or other events to send you appropriate notifications, or to offer or provide you with customised and related products, services and content.

Our services may allow you to share Video Feeds with third parties, or to stream such content live. We only share your Video Feeds in this way at your request. You need to realise that if you share Video Feeds with others and subsequently delete your account, those who have received your Video Feeds may continue to have copies of this content.

4. Do we share your information?

We keep your information private. We don’t sell your personal information. However, in very limited circumstances we may be required to share your information with third parties. These are set out below:

  • With your consent: We will share your information with a third party in circumstances where you have told us that it is okay to do so. For example, if you ask us to stream your Video Feed or provide a third party with access to it, we may do so.
  • With our service providers: To a limited extent, we may share personal information with our trusted service providers, particularly where this is necessary to provide our services to you. These service providers will be subject to non-disclosure obligations and are required to keep your personal information safe and secure. For example, if we supply a camera to you, we may provide your address to our delivery company. Similarly, if you purchase one of our products, we may share information with our payment processor to complete the transaction. We may also share personal information with our legal counsel, particularly in cases where there has been a breach of our Terms of Service.
  • For legal and safety reasons: We may provide information to a third party if we believe in good faith that we are required to so for legal reasons or that this is necessary to prevent harm or injury to our users, members of the public, our staff, or ourselves, or if we need to do so to defend our legal rights or to enforce or Terms of Service. For example, we may provide personal information if we are ordered by a court to do so.

We may share non-personal information (particularly aggregated data) publicly. For example, we may release information about the number of people who use our products, or total hours of video captured by users in a certain jurisdiction. Finally, note that there are a number of third party cookies on our website and software development kits (SDKs) contained in our app. Third parties may directly obtain information through these tools. Additional information is provided in our Cookies Policy.

5. How long do we keep personal information?

We keep personal data for so long as is necessary in light of the purpose for which it was originally collected or lawfully further processed. We generally store your User Information for the duration of your account with us. We do this to provide you with our products. Video Feeds may also be stored for up to this length of time. This enables you to review and access your Video Feeds. You can deactivate your account at any time through the user interface made available in our services. Deactivation puts your account on hold for a period of 1 year. You can reopen your account during this time period and we will continue to hold your User Data for this length of time. After 1 year we will delete your account and your User Data. We also allow you to delete your account at any time. To do this, please send an email to privacy@smartfrog.com. It generally takes us about 30 days to fully delete your personal information. We may retain personal information for a longer period of time if we are required to do so by law.

6. How do we keep personal information secure?

We deploy appropriate organisational and technical security measures to keep personal information secure.

We regularly monitor our system for possible vulnerabilities and attacks. We also store personal information on a tier-one secured-access data centre, and we encrypt the Video Feeds. However, the internet is not a 100% secure environment, so we cannot guarantee the security of personal information.

Please play your part in keeping your personal information secure by choosing a strong password and by keeping your login details secret.

7. What are your rights?

We operate in accordance with European and Irish data protection law, including, in particular, the rules set out in the Data Protection Acts 1988 and 2003. You enjoy a number of rights under data protection law. These include the right to access, and in some circumstances to amend and delete, your personal information.

You can access, amend or delete much of your personal information and deactivate your account through our user interface on our services.

If you have any questions about your rights please email us at privacy@smartfrog.com.

8. What are your responsibilities?

Our services allow you to capture, store and review Video Feeds so, when you use our products, you should take care to ensure that you act in accordance applicable data protection and privacy laws. For example, if you are based in Europe, and use our services outside of the purely domestic sphere, you may be obliged to comply with your local data protection laws and to register with or notify your local data protection authority.

You are also required to comply with the Acceptable Use rules in our Terms of Service.

9. Where do we store personal information?

We generally store personal information on servers located inside the European Economic Area. However, in certain cases it may be necessary for us to transfer data to servers located outside of the EU. The privacy protections in these jurisdictions may not be equivalent to those in Europe. We will only transfer personal data outside of the EEA where permitted to do so by European law and we will take steps to ensure that the personal information continues to enjoy appropriate protections.

10. Will we occasionally update this policy?

Yes. We are constantly working to develop new and exciting services which we hope that you will enjoy. We may also change our practices over time as our business and technology evolves. Occasionally, this means that we will need provide you with new or additional information about the ways in which collect, process and use personal information. As a result, we may amend this Privacy Policy from time to time.

If we materially change our Privacy Policy we will take steps to inform you of the change in advance. We may do this through an email, SMS, notices in our products or other means (or a combination of these means). If you are unhappy with the changes that we propose, you are free to close your account with us. Alternatively, you can continue to use our products. If you continue to use our services after the date any revised Privacy Policy comes into force, you will be deemed to have consented to the revised Privacy Policies.


smartfrog Limited
registered in Ireland with company number 559717
registered office: Pembroke House, 28-32 Pembroke Street Upper
Dublin, D02 EK84, Ireland

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