Seam Privacy Notice

Seam Labs, Inc. (“Seam”, “we” or “us”) provides a business-to-business platform comprised of the Seam API, Connect Webviews, Console, and other device access and management services (collectively, the “Seam Platform”), as well as Seam software applications (“Seam Bridge”) and mobile SDKs to enhance the functionality of the Seam Platform. Seam provides information about itself and its products and services on its website at seam.co (“Seam Website”). This Privacy Notice describes how we collect, use, share and store personal information (i.e., information that personally identifies you, such as your name, email address or billing information).

The Seam Platform generally collects information about the following groups:

• “Platform Users” are people or businesses that have a Seam Platform account or are authorized to access a Seam Platform account. Platform Users are often software developers.
• “End Device Owners” are people or businesses that own or control a device or system that is configured to transmit data to the Seam Platform (such device or system, an “End Device”) or the premises utilizing the End Device. End Device Owners are often residential and multi-family property management companies, hotel operators, and commercial property operators.
• “Individuals” are people who interact with an End Device or are set up as users of the End Device. Individuals often are personnel of the End Device Owner or residents or visitors of the premises utilizing the End Devices.

Collection of Information

End Device Authorization. End Device Owners may choose to authorize Seam (and the Seam Platform) to control their End Devices through an authorization mechanism provided by the End Device maker, where available, or otherwise, by sharing their End Device credentials to Seam through the Seam Platform.

Account Information. Platform Users may provide personal information for themselves or for other Platform Users to create accounts on the Seam Platform and to set up and maintain their use of the Seam Platform. The Seam Platform will automatically collect Seam Platform usage information relating to Platform Users (for example, login timestamps and IP addresses).

Communications with Seam. Seam typically communicates only with Platform Users and potential Platform Users. However, any person may initiate communications with Seam (for example, via email or by submitting a web form).

Individuals’ Information. Each Platform User may provide personal information of its End Device Owners or Individuals to the Seam Platform in order to help the End Device Owners manage their premises that utilize the End Devices. For example, the Seam Platform may collect and store information from the Platform User related to who may access certain premises, including the eligible Individual’s name, role, contact information and access hours. The Platform User may also elect to provide additional information about the Individuals to help the Platform User’s operations, including each Individual’s ID photo, ID number, additional contact information, device identifiers, IP address, and physical location.

End Device Interactions. In connection with providing the Seam Platform, the Seam Platform automatically collects activity about Individuals’ interactions with End Devices (e.g. attempted and successful interactions, types of interactions, and timing of interactions with End Devices). End Device usage activity may become personal information if associated with the relevant Individuals’ personal information within the Seam Platform.

Website and Seam Bridge Usage. Each time you access the Seam Website or website for the Seam Platform (collectively, “Websites”) or use the Seam Bridge, information is sent to our server by your browser or device and stored in our log files. We collect information about your use of the Websites, including your search activity, the pages you view, the date and time of your visit and how you navigate and interact with a page or screen. We also collect information that your device provides to us in connection with your use of the Websites and the Seam Bridge, such as your browser type, type of device, browser language, IP address, mobile carrier, unique device identifier, and requested and referring URLs.
We also use cookies and similar technologies (collectively, “Cookies”) in connection with your use of the Websites to collect information related to what you see, interact with, access and use on the Websites and other Website access and use. For more information about our use of Cookies, please review our Cookie Policy.

Third-Party Sites and Features. The Seam Website may include third-party social media features and other third-party plug-ins and widgets. Your interactions with these features are governed by the privacy policy of the third party providing the feature, not by this Privacy Notice.

Minors. Only persons aged 16 and older are allowed as Platform Users, End Device Owners, and Individuals. Seam does not knowingly collect or store any personal information about children under the age of 16.

Use of Information

Seam Platform. Seam generally is a processor (for example, under GDPR in the European Economic Area) or a service provider (for example, under CCPA in California) for each Platform User with respect to the personal information collected by the Seam Platform from that Platform User and its connected End Devices (“Platform Data”) to operate the Seam Platform. Seam may also use such information as a controller for the following purposes:

• to understand how our products and services are used and to update them;
• in an aggregate or in a de-identified manner to develop new products and services;
• to protect against harm to the rights, property and safety of Seam, Platform Users, End Device Owners, Individuals, third parties, and the public, including to comply with our legal obligations;
• to detect, prevent, or otherwise address fraud, abuse, security, or technical issues with our products and services.

Communications. Seam uses the contact information of Platform Users, potential Platform Users, End Device makers, and people who have provided their contact information to learn more about Seam (including through the Seam Website) to send them communications from Seam, including information about feature changes and updates, as well as marketing messages and calls. If you do not want Seam to contact you for marketing purposes, please use the opt-out method indicated in the communication or email legal@getseam.com.

Websites and Seam Bridge. Seam uses the personal information collected from the Websites and Seam Bridge for the following purposes:

• to understand how visitors navigate the Websites and to improve it, as well as to develop and improve our products and services;
• to protect against harm to the rights, property and safety of Seam, Platform Users, End Device Owners, Individuals, third parties, and the public;
• to detect, prevent or otherwise address fraud, abuse, security or technical issues with our products and services.

Service Providers and Third Parties. Seam may use service providers and third parties to perform services on its behalf, with such service providers and third parties subject to restrictions consistent with this Privacy Notice.

Sharing of Information

Seam does not sell or provide personal information in Platform Data to third parties for their marketing purposes.

Seam discloses personal information to each Platform User (and their authorized Platform Users) regarding Individuals’ interactions with the End Devices connected to the Seam Platform through that Platform User. The Platform User’s use of personal information is governed independently by the Platform User’s privacy policy, and not by this Privacy Notice.

Seam does not disclose personal information with third parties except under the following circumstances:

• to service providers, and third parties to perform services on Seam’s behalf as further described in the section CCPA Right to Know Disclosures, and subject to restrictions consistent with this Privacy Notice;
• to third parties (including governmental entities) if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process or enforceable government request (including for purposes of law enforcement and national security); (ii) enforce Seam policies or contracts, including investigation of potential violations; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) protect against harm to the rights, property or safety of Seam, Platform Users, third parties, or the public as required or permitted by law;
• to Seam’s corporate affiliates, subject to this Privacy Notice;
• upon the sale or transfer of the company or all or part of its assets to a third party or affiliate, personal information may be included, and Seam would request the acquirer to treat the personal information under the Privacy Notice in place at the time of its collection.

Choices and Rights

As the processor or service provider for the information collected by the Seam Platform, Seam will permanently delete information upon request or consent of the controller or Platform User of the information. Seam will provide a copy of personal information available in the Seam Platform to the person to which the information pertains. Seam will take commercially reasonable steps, however, to verify the identity of the requestor before fulfilling any information-related requests in order to protect the information. Seam generally permanently deletes or anonymizes information collected by the Seam Platform within a reasonable period after its agreement with the applicable Platform User ends except to resolve potential disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Seam generally stores personal information from the Seam Website until you request deletion or when there is no longer a legitimate purpose to store the information.

Data Security

We take security and privacy seriously. Our team includes security experts who focus on strengthening our infrastructure and services. To learn more about our security practices, please refer to our Security Page at https://www.seam.co/security-and-privacy.

International Data Transfers

Seam is headquartered in the United States, with service providers in the United States, European Economic Area, United Kingdom, Switzerland, Brazil and other countries. In order to provide you with the Seam Website and the Seam Platform, your personal information will be transferred to and processed in the United States (or any other country where we or our service providers operate). Data protection laws differ among jurisdictions, and the United States and these other jurisdictions may not provide the same level of protection for personal information as your jurisdiction of residence. For example, your information may be required to be disclosed to law enforcement or government authorities under the laws of those jurisdictions. You can learn more here about how many of these disclosures we have made in the last calendar year: https://www.seam.co/security-and-privacy. If you reside in the European Economic Area ("EEA"), Switzerland or the United Kingdom (“UK”), and we transfer your personal information to countries outside of where you reside, we will take appropriate steps to ensure your personal information is afforded the same level of protection as described in this Privacy Notice and use a variety of legal mechanisms to help ensure your data is appropriately protected.

Additional Information for Individuals from the European Economic Area (EEA)

If you are from the EEA, our legal basis for collecting and using the personal information described in this Privacy Notice will depend on the personal information concerned and the specific context in which we collect it. We collect and use your information for business purposes that are in our legitimate interests, in order to enter into or perform a contract with you, with your consent, or to comply with our legal obligations.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you wish to learn more about specific legal grounds we rely on to process your information for any particular purpose (including any legitimate interests we have to process this information), please contact us as provided under the Contact Us section. For example, we rely on our legitimate interests to process information for direct marketing purposes and for fraud prevention and detection, provided these interests are not overridden by your data protection interests or fundamental rights and freedoms.

Seam takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. In addition to the rights described in the Choices and Rights section, you have additional rights in relation to your personal information, including the right to access your personal information, correct your personal information, object to the processing of your personal information and delete your personal information where we are the controller of the personal information or requested by the controller of the personal information. You can exercise these rights by contacting us as provided in the Contact Us section.

You can complain to a data protection authority about our collection and use of your personal information in relation to the General Data Protection Regulation (GDPR) and other applicable law. For more information, and to submit a GDPR complaint, please contact your local data protection authority. Contact details for data protection authorities in the EEA, UK and Switzerland are available here: https://ec.europa.eu/newsroom/article29/items/612080

Additional Information for Individuals from California

This section provides notice and specific information for California consumers to address the California Consumer Privacy Act ("CCPA"). Seam does not sell your personal information. We share your information as described in the Sharing of Information section of this Privacy Notice. We collect the following categories of personal information from you:

• contact information (e.g., full name, email address and phone number) and other personal identifiers (e.g., employee ID number)
• device identifiers (e.g., IP address)
• your purchase history with us
• Website and Seam Bridge usage data, as well as your views and clicks of our ads
• your physical location based on your address or location provided to Seam or the Seam Platform, as well as from your interactions with End Devices
• audiovisual information provided to Seam or the Seam Platform, as well as from your interactions with End Devices (e.g. photos or footage from security cameras)
• job role and status, as well as access hours, provided to Seam or the Seam Platform
• End Device and Seam account credentials

In addition to the rights described above and in the Choices and Rights section, California consumers may also, up to twice every 12 months and subject to certain exceptions, request us to provide information about how we have used and shared your personal information in the prior 12 months. Please submit these requests for information, as well as requests to access or delete your information by emailing us at legal@getseam.com.

Your authorized agent may submit a request to know, delete, or opt out on your behalf via this online support form or by emailing us at legal@getseam.com. We may still require you to directly verify your identity and confirm that you have provided the authorized agent permission to submit the request. The Collection of Information section of this Privacy Notice describes the sources from which we collect your personal information. The Use of Information section of this Privacy Notice describes the purposes for which we collect your personal information. The Sharing Your Information section of this Privacy Notice describes the types of third parties with which we share your personal information. Consistent with the CCPA, except to the extent reasonably related to the value of your personal information, we will not treat California consumers differently for exercising their rights under the CCPA.

Changes to this Privacy Notice

Please note that this Privacy Notice may change from time to time. We will provide notice of any material changes on the Seam Platform or by contacting you.

Contact Us

Seam Labs, Inc., 2948 20th St, #302, San Francisco, CA 94110

If you have any questions, you may submit an inquiry to legal@getseam.com.