SmartThings Privacy Notice

Effective Date: February 24, 2021

At Samsung Electronics Co., Ltd. (“Samsung”), we know how important privacy is to our customers. Samsung is the data controller for SmartThings. We created this Privacy Notice to make sure you understand how we collect and use your personal information.

Our Privacy Policy at https://account.samsung.com/membership/terms/privacypolicy also applies to your use of SmartThings. Our Privacy Policy contains more information about how we use your data. It also includes information about your rights and how to contact us. Please read our Privacy Policy in addition to this Privacy Notice. However, this Privacy Notice shall always prevail over the Privacy Policy in relation to how we use your information for SmartThings.

WHAT INFORMATION DO WE COLLECT?

Through SmartThings, Samsung obtains and maintains information about you in various ways.

Information You Provide Directly

• Your Account Information: SmartThings will collect your account information, which is necessary to initiate and provide the SmartThings service to you. This will include information such as your name, Samsung account ID, email address, mailing address, phone number, username and password. Your account information will not only include the information that you enter in the SmartThings app to create a Samsung account, but also the account information in apps from third-party service partners which you allow to access SmartThings.

Information About Your Use of SmartThings

In addition to the information you provide, we will collect information about your use of our SmartThings through software on your devices and by other means. We will collect:

• App Usage Information: We will collect your usage information created during your use of the SmartThings app, such as app logs, groups, rules and location names, along with configuration information.

• Home IoT Device Information: As SmartThings may consist of several sets of home appliances, sensors, SmartThings hubs, smart bulbs, products, home monitoring cameras and other devices connected to SmartThings (“Home IoT Devices”), SmartThings will also collect usage information related to your Home IoT Devices, such as Home IoT Device model, name, group name or nickname, location name and other settings assigned to the device, event and event settings (for example, if you set up a schedule reminder to display on your Home IoT Device), the network connection information and the surrounding network environment information, mobile country code, mobile network operator, OS version, IP address and IMEI, sensor and configuration data, error and malfunction logs, device identifier (e.g. ICCID) and the device and automation name. The main purpose for processing such information is to provide the service you have requested (though it may also be used for data analysis and to enable us to provide customized marketing communications, where you have given us your separate consent). Examples relating to the use of your information to provide you with the service are set out below. For example, when you use a motion sensor, SmartThings will collect the information detected by the sensor (such as logs indicating movement in your home, that the lights have been automatically turned on or off, or if there is unexpected movement in your home) to enable an alert to be sent. SmartThings will also collect the usage/settings information of home appliances connected to SmartThings, if you turn on these features. For example, the temperature information inside your refrigerator, the time information showing how long you have used the air conditioner, and other information about the functions you have selected will be collected not only to display the device/appliance status through your mobile app, but also to understand your use of Home IoT Devices and thus continue to improve the our services. In addition to the above mentioned personal data, we will collect your dump logs, which are files listing the technical errors of your devices. These dump logs will only be used to provide you with the technical assistance you need and to improve the SmartThings app and Home IoT Devices.

• Video and Audio Clips Recorded by the Home Monitoring Camera: If you connect video or audio recording devices to SmartThings, SmartThings will collect the video or audio clips recorded by such device, based on your choices, to provide the service you request in the SmartThings app.

• Images, video clips: If you choose to share your images or video clips (not recorded by the Home Monitoring Camera) stored on your device with other SmartThings users or devices, SmartThings will collect the images and video clips.

• Voice Information: If you use voice commands to control SmartThings, information about your conversations, including voice commands, will be relayed through SmartThings servers to process your command.

• Location Information: If you consent to the collection and use of location data, your geolocation data is collected to provide the service or feature that requires location information. If you do not processing your location information to be processed, you can turn it off in the SmartThings settings.

• Smart TV Information: If you connect a Samsung Smart TV to SmartThings, information will be collected about the Smart TV content you purchase, including voucher or gift card numbers and information you provide to set reminders and calendar notifications on your Smart TV.

• SmartThings Cooking Information: If you use SmartThings Cooking, we will collect information about your use of SmartThings Cooking, including your favorite ingredients and cuisines, dietary preferences, and cooking experience, and information you receive from Family Hub such as responses, answers and content. Any information you enter into SmartThings Cooking will override the existing information in your Family Hub. For example, if you input your dietary preferences through SmartThings Cooking, your Family Hub will be updated to include those dietary preferences. You can add, remove, or change your dietary preferences using either SmartThings Cooking or Family Hub.

We will also collect information about your Smart TV and other devices you add and connect to with the SmartThings app and the SmartThings Hub, and your use of these devices, in ways that we will describe to you at the time of collection or otherwise with your separate consent.

We do not knowingly or intentionally collect any sensitive personal data from you. However, please note that we cannot guarantee that sensitive information is not unintentionally shared with us while using the SmartThings app and other Home IoT Devices, such as the content of your audio or video recordings when you connect audio or video recording devices to SmartThings. If you submit information to SmartThings that is sensitive in nature, that will also be collected and processed for the purposes listed below, however we will not use that data for marketing, to provide customized recommendations, or for the improvement of our services.

We also may collect other information about you, your devices and apps, and your use of SmartThings in ways that we describe to you at the time of collection or otherwise with your consent.

HOW DO WE USE YOUR INFORMATION?

We use the information collected for the following purposes:

• to identify and authenticate you;
• to enable you to control your Home IoT Devices in the SmartThings app;
• to provide services the or features you request in the SmartThings app;
• to respond to your requests and questions, and to communicate with you about SmartThings;
• to provide assistance when you request technical support for the SmartThings app or Home IoT Devices and other maintenance services;
• to provide you with remote maintenance service for errors related to Home IoT Devices connected to SmartThings if you contact a customer service center;
• to link your account information or otherwise interact with selected apps, devices, features and services of third-party service partners;
• to operate, evaluate and improve our business (including developing new products and services; enhancing and improving our products, services and SmartThings; analyzing our products and services, aggregating and anonymizing data and data analytics and performing accounting, auditing and other internal functions);
• to provide customized recommendations related to Home IoT Devices and other useful services or features;
• if you turn on Customization Service in your Samsung account, to use data collected through the SmartThings app for the purposes herein. You can learn more about our Customization Service by clicking here;
• if you have a Samsung Smart TV, to (i) enable you to purchase Smart TV digital content, (ii) provide a history of purchased Smart TV digital content, (iii) let you set reminders for Smart TV digital content, and (iv) enable you to receive calendar notifications on your Samsung Smart TV;
• where you have separately consented to receive marketing communications from us, we may combine information about your device and the Home IOT Devices which you connect to SmartThings, with data which we have collected about you from other sources, in particular your Samsung Account, to provide you with more relevant marketing;
• to comply with laws, regulatory obligations, and legal processes; and
• to protect the rights, property and/or security of Samsung Electronics, or any of our affiliates, business partners and/or customers.

Samsung processes personal information for the purposes described above. Samsung’s legal basis to process personal information is outlined below:

WHO DO WE SHARE YOUR INFORMATION WITH?

We will disclose your information internally within our business and to the following entities, but only for the purposes described above.

• Affiliates: other Samsung Electronics Group companies which we control or own;
• Business partners: partners who we work together with to provide you with SmartThings, such as third-party products or services you can connect to SmartThings to control those products or services. These business partners control and manage your personal information;
• Service providers: carefully selected companies that provide services for or on behalf of us, such as cloud platform providers who maintain data on our behalf. These providers are also committed to protecting your information;
• Other parties when required by law or as necessary to protect SmartThings: for example, it may be necessary by law, legal process, or court order from governmental authorities to disclose your information. They may also seek your information from us for the purposes of law enforcement, national security, anti-terrorism, or other issues related to public security;
• Other parties in connection with corporate transactions: We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of bankruptcy; and
• Other parties with your consent or at your direction: In addition to the disclosures described in this Privacy Notice, we may share information about you with third parties when you separately consent to or request such sharing.

HOW LONG DO WE RETAIN YOUR INFORMATION AND WHERE DOES IT GO?

How long your data will be retained depends on the legal basis relied upon to process your data. For example, data we process to perform our contract with you requires us to keep the data throughout the time you use SmartThings. As long as you are an active user of SmartThings, we will retain and process this data. Data such as your account information, device information and identifiers fall into this category.

Data we process to promote our business interests, such as your use of SmartThings, is only kept for as long as needed for the purposes for which they were collected. For example, this data may be collected to perform analytics so we can develop improvements to SmartThings, or we may process data to keep a record of inquiries you made through or about SmartThings to improve your customer service experience.

In addition, we may also process your data based on your consent. If you withdraw your consent, we will stop processing your data that relies on your consent, but it will not impact the processing of data collected prior to your withdrawal until the purposes for which such data were collected have been achieved.

Please note, although we aim to retain your data for the time period described above, your data may be processed longer, pursuant to applicable law. For example, if a specific statute mandates we retain a certain piece of data, we will comply and retain that data until the required retention period expires.

As long as your data is retained by us, your data will always be subject to appropriate safeguards.

Your use of SmartThings will involve the transfer, storage, and processing of your personal information to other countries; such countries include, without limitation, the Republic of Korea, United States, Canada, India, and the Philippines. All international data transfers are subject to legal requirements to ensure that your personal information is processed safely and as you would expect.

UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice may be updated to let you know about changes in how we collect and process your information in SmartThings or changes in related laws. The date when the document was last updated is shown at the top of this Privacy Notice.