Last updated: May 16, 2018

At Netbeast, S.L., the company behind Yeti, a Spanish corporation (“Netbeast”, “Yeti”, “Company”, “us”, or “we”), we respect and protect the privacy of visitors to our website, www.getyeti.co, and the other websites under the getyeti.co domain (collectively, the “Sites”), and our customers who use our SaaS product, smart home control software, tools, and related services (together with the Sites, the “Service”).

This Privacy Policy (“Policy”) explains how we collect, use, disclose, and protect visitors’ and users’ information as part of the Service. Any discussion of your use of the Service in this Policy is meant to include your visits and other interactions with the Sites and Services, whether or not you are a user of Yeti’s SaaS product.

Capitalized terms that are not defined in this Policy have the meaning given them in our Terms of Service.

By using the Service, you do hereby warrant and represent that:

1. You have read, understand, and agree to all terms and conditions stated herein, including our Terms of Service, available at www.getyeti.co/terms, incorporated herein by reference, which govern the use of the Service, and
2. That you are giving Yeti permission to use and store such information consistent with this Privacy Policy and our Terms of Service.

1. What do we mean by Personal Information?

In this Policy, “Personal Information” means information or an information set that identifies or could be used to identify an individual. Except as described in this Policy, Yeti will not give, sell, rent or loan any Personal Information to any third party.

Personal Information does not include “Usage Data” which we define as encoded or anonymized information or aggregated data we collect about a group or category of services, features or users which does not contain personally identifying information. Usage Data helps us understand trends in usage of the Service so that we can better consider new features or otherwise tailor the Service. In addition to collecting and using Usage Data ourselves, we may share Usage Data with third parties, including our customers, partners and service providers, for various purposes, including to help us better understand our customers’ needs and improve the Service as well as for advertising and marketing purposes. We do not share Usage Data with third parties in a way that would enable them to identify you personally.

1.1 EU Personal Data

If you are located in the EU, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) related to your Personal Data, as further described below. Yeti will be the controller of your Personal Data processed in connection with the Service, unless you access the Service through an enterprise account, or other Yeti account that is controlled by a third party (e.g. your employer).

2. How do we collect, use, and share your Personal Information and other information?

a. Information you provide to us

When you register for the Service, we may ask for Personal Information such as your name, email address, or credit card or other billing information. Additionally, as users employ the Services to control smart home peripherals, the software continuously saves changes made by users with the server and will document items such as when users are creating automation rules and saving changes, when a user last opened the app, when changes to a smart home peripheral’s state are made, or when a user performs certain tasks.

We may also retain the contents of any messages you send to us or through the Service, and we may collect information you provide in user content that you post or upload to the Service (“User Content”).

Yeti may use Personal Information provided to operate, improve upon, and personalize the Service, for billing identification and authentication, to contact and communicate with you about the Service and your use of the Service, to support use of the Service, to send marketing materials (subject to your opt-in option), for research purposes, and to generally improve the content and functionality of the Service. We may also combine your Personal Information with third-party analytics information to build a broader profile of our individual users so that we can serve you better and provide custom, personalized content and information. Additionally, we may use the Personal Information we collect for identification and authentication and fraud prevention, to analyze Site and Service usage and improve the Service, for internal market research, troubleshooting problems, to enforce our Terms of Service, and as otherwise set forth in this Policy. Note that we will never email you to ask for your account information; if you receive such an email, please forward it to hello@netbeast.co.

If you would like more information about our policy, please review our Terms of Service.

We use financial information solely as authorized by you in accordance with the Service. While Yeti does not store your credit card information and will use commercially reasonable efforts to ensure the security of all credit card and all other Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all personal and/or financial information stored therein, and you agree to hold Yeti harmless for any damages that may result therefrom.

b. Information we may receive from and share with third parties

We may now or in the future receive Personal Information about you from third parties. For example, if you access our Site or Service through a third-party connection or log-in or connect an application to Yeti, that third party you connected with may pass certain information about your use of its service to Yeti. This information could include, but is not limited to, the user ID associated with your account, an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that third-party service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service.

Yeti may also share Personal Information with its third party service providers (such as its credit card processors and hosting partners) to provide the necessary hardware, software, networking, storage, and other service we use to operate the Service and maintain a high-quality user experience. We do not permit our service providers to use the Personal Information we share for their marketing purposes.

c. Analytics information

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser and our mobile service as part of a web page request, including information that assists us in improving the Service. We may collect and use this analytics information together with your Personal Information to build a broader profile of our individual users so that we can serve you better.

The Site primarily uses the following analytical tools, for which we include relevant privacy information and opt-out options:

Google Analytics and Google Adwords

Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. You may also learn more about how Google collects and processes data specifically in connection with Google Analytics. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on.

Hotjar

Hotjar’s use of information collected through Hotjar is set forth in its Privacy Policy, which includes instructions for opt-out.

Facebook Remarketing Service

Facebook’s use of information collected is set forth in its Privacy Policy. You may opt out from Facebook’s interest-based ads.

d. Log files

Yeti gathers certain information automatically and stores it in log files. This information includes internet protocol addresses as well as browser, internet service provider, referring/exit pages, search terms, operating system, date/time stamp, and click stream data. Occasionally, we may connect Personal Information to information gathered in our log files, as necessary to improve the Service for individual customers. Otherwise, we generally use this information as we would any Usage Data, to analyze trends, administer and maintain the Service, or track usage of various features within the Service.

e. Cookies

A cookie is a small software file stored temporarily or placed on your computer’s hard drive. The main purpose of cookie is to allow a web server to identify a user’s computer and web browser, and tailor web pages and/or login information to user’s preferences. Cookies help us promptly display the information needed to use the capabilities on the Service and other information which we consider to be of interest to visitors to the Sites and users of the Service. By gathering and remembering information about website preferences through cookies, we can provide a better web and marketing experience. Cookies don’t give us access to users’ computers, and the information we collect through cookies doesn’t include Personal Information.

We utilize session cookies, which allow us to uniquely identify your browser while you are logged in and to process your online transactions. Session cookies disappear from your computer when the web browser is closed or computer is turned off. We also utilize persistent cookies to make it easier to log into and use the Service. Persistent cookies remain on computers after the web browser is closed or the computer is turned off.

Many jurisdictions require or recommend that website operators inform users as to the nature of cookies they utilize and, in certain circumstances, obtain the consent of their users to the placement of certain cookies. If you require more specific information as to the nature of the cookies utilized in the Service for purposes of fulfilling these obligations, please contact us by email at hello@netbeast.co.

f. Clear GIFs/web beacons information

When you use the Service, we may employ clear GIFs (also known as web beacons) which are used to anonymously track the online usage patterns of our users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information is allows for more accurate reporting and improvement of the Service.

g. Device identifiers

When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor, and/or remotely store one or more “device identifiers,” such as a unique device identifier (“UDID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Yeti. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

h. Application integration

In order to facilitate the exchange of data between third-party SaaS applications, we may need to store certain information (“App Credentials”) that helps us access these third-party SaaS application accounts on your behalf. We store your App Credentials in an encrypted form.

When we access these third-party applications on your behalf, the third-party application provides us with access to certain data. We will use, store, and disclose this data in accordance with this Policy.

You should note that Yeti shall have no liability or responsibility for the privacy practices or other actions of any third-party applications for which you provide us with App Credentials.

i. Other information sharing

In addition to the purposes described above, we disclose Personal Information to respond to subpoenas, court orders and law enforcement or governmental requests or investigations, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations or our Terms of Service, or as otherwise required by law.

We use or may use information such as cookies, log files, device identifiers, and clear GIFs information to:

(a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site

(b) provide custom, personalized content and information

(c) to provide and monitor the effectiveness of our Service

(d) monitor aggregate metrics such as total number of visitors, traffic, and demographic patterns

(e) diagnose or fix technology problems

(f) help you efficiently access your information after you sign in, and

(h) automatically update the Yeti application on your mobile devices.

We may share information, including Personal Information, with any member of the Yeti team, which includes any entity that controls, is controlled by, or under common control with Yeti.

2.1 Processing grounds

We will only use your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below.

• Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our User Agreement with you, which enables us to provide you with the Service. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Service that require such data:

• Contact Information
• User Account Information
• Financial Account Information
• Transaction Information
• User Content

• Legitimate Interest: We process the following categories of Personal Data when we believe doing so furthers the legitimate interest of us or third parties:

• Contact Information
• Financial Account Information
• User Account Information
• Transaction Information
• User Content
• Partner Information
• Log Data

Examples of these legitimate interests include:

• Operation and improvement of our business, products, and services
• Marketing of our products and services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions

• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

3. Links to other websites

The Service contains links to websites and applications other than the Service, including websites and applications operated by affiliates and other third parties. Please be aware that we do not determine and we are not responsible for the privacy practices or content of websites and applications operated by third parties. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. We encourage you to be aware when you leave the Service, and read the privacy statements of third-party websites and applications linked to the Service. Yeti does not endorse and is not responsible for the practices of third parties or their websites or applications. In addition, you agree that we are not responsible for and we do not control any third parties that you authorize to access your User Content. If you are using a third-party website or service and you allow such a third party access to you User Content, you do so at your own risk. This Policy applies only to information collected by the Service.

4. Public forums

The Service offers publicly accessible blogs. We use disqus as a platform to enable comments from the general public and our users. You should be aware that any information provided in these areas may be read, collected, and used by others who access them. If you elect to post something in a public area of our Service, any Personal Information or content that you voluntarily disclose for posting to the Service, becomes available to the public, and is controlled by the applicable privacy policy of disqus. Please note that, as to create content tied to a specific user account you must sign in through the disqus service, the information provided in said channel is managed by them, you may change your privacy settings through your account in their service. To request removal of your Personal Information from our blog, contact us at hello@netbeast.co. We’ll try to forward your wishes to disqus. In some cases, you may have to contact disqus to have your Personal Information removed.

5. Customer testimonials / comments / reviews

From time to time, we post customer testimonials on the Sites which may contain Personal Information. We obtain the customers’ consent to post their names along with their testimonials.

6. Protection of information

Yeti is committed to ensuring the security of your Personal Information. We use commercially reasonable technological, physical, and administrative security safeguards, such as firewalls and carefully developed security features, to protect the confidentiality and security of your Personal Information within the Service and the Sites. For example, when you enter confidential information (such as login credentials or information submitted from within the Service) we encrypt the transmission of that information using secure socket layer technology (SSL). These technologies, procedures, and other measures are used in an effort to ensure that your data is safe, secure, and only available to you and to those you authorized to access your data. However, no internet, email, or other electronic transmission is ever fully secure or error-free, so you should take care in deciding what information you send to us in this way. Yeti is not responsible for the functionality or security measures of any third party.

7. Hosting and data transfer

We are based in Spain, but, unless we expressly agree otherwise (including through our Terms), we may host, transfer, and process data, including Personal Information, in Spain and in other countries through Yeti and third parties that we use to operate and manage the Service. When you access or use the Service, or otherwise provide information to us, you are consenting, on behalf of you and your authorized agents, (and representing that you have the authority to provide such consent) to the processing and transfer of information in and to Spain and other countries which may have different privacy laws from your or their country of residence. We will always make sure to transfer information only to countries that are covered by the European GDPR law requirements for data transfer.

8. Data retention

Yeti will retain Personal Information we process on behalf of our customers or collect directly from our customers for as long as needed to provide Service to our customers, subject to our compliance with this Policy. We may further retain and use this Personal Information as necessary to comply with our legal obligations, maintain accurate accounting, financial and other operational records, resolve disputes, and enforce our agreements. We have established internal policies for the deletion of data from customer accounts following termination of a customer’s subscription to the Service.

9. Children’s Personal Information

Yeti does not knowingly collect any Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through our Service. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce our Policy by instructing their children never to provide Personal Information on our Service without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to Yeti through our Service, please contact us, and we will use commercially reasonable efforts to delete that information from our databases. If you’re under the age of 16 you need written authorisation from your parents or legal guardian before using our Service.

10. What rights and choices do you have regarding your personal data?

Accessing, Correcting, and Deleting Your Personal Data and Other Data Subject Rights

You have certain rights with respect to your Personal Data, and we want to help you review and update your information to ensure it is accurate and up-to-date.We may limit or reject your request in certain cases, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, if it is not required by law, or if the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question. In some cases, we may also need you to provide us with additional information, which may include Personal Data, to verify your identity and the nature of your request. We will take reasonable steps to respond to all requests within 30 days (or less!).

If you are an Yeti Account holder, you can accomplish most of the following by logging into your User Account or, for those using enterprise accounts, by contacting your account administrator. You can also contact us directly at hello@netbeast.co if you have any additional requests or questions:

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems. Please note that if you request the deletion of information required to provide the Service to you, your User Account will be deactivated and you will lose access to the Service.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

For the following, please email us at hello@netbeast.co:

• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Service.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for marketing purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.

You also have the right to lodge a complaint about Yeti’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Closing Your Account

You may close an account, and upon termination of your User Account, we will take reasonable steps to provide, modify, or delete your Personal Data as soon as is practicable. However, Yeti may nevertheless retain your Personal Data to protect the business interests of Yeti, Yeti Affiliates, vendors, and other users, and some information may remain in archived/backup copies for our records or as otherwise required by law. Those interests include without limitation the completion of transactions, maintaining records for financial reporting purposes, complying with our legal obligations, resolving disputes, and enforcing agreements.

11. Changes to the Privacy Policy

We may, in our sole discretion, modify or update this Policy from time to time. If we make any material changes to this Policy, we will endeavor to notify you by email or by posting a prominent notice on the Sites or Service prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of the Service constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of the Service.

12. Business transactions

Yeti may assign or transfer this Policy, and your user account and related information and data, including any Personal Information, to any person or entity that acquires all or substantially all of the business, stock or assets of, or is merged with Yeti. We may also transfer or assign such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, or similar transactions or proceedings, provided that the recipient of such information will continue to be bound by the terms of this Privacy Policy.

13. Contact us

If you have questions regarding this Policy or about the privacy practices of Yeti, please contact us by email at hello@netbeast.co, or at:

Netbeast, S.L.

Avenida Santa Lucía, 55-14,

41500 Alcalá de Guadaíra, Spain

You may contact our Data Protection Officer by email at hello@netbeast.co, or at:

Jesús Darío Rivera Rubio

Netbeast, S.L.

Avenida Santa Lucía, 55-14,

41500 Alcalá de Guadaíra, Spain