Seam Privacy Notice

This Privacy Notice describes how Seam Labs, Inc. (“Seam” or “us”) collect, use, share and store personal information (i.e., information that personally identifies you, such as your name, email address or billing information) from the operation of the Seam API and related websites, mobile applications or other services provided by Seam (the “Seam Platform”), as well as from our public informational websites (“Seam Website”).

The Seam Platform generally collects information about the following groups:

• People or businesses who are referred to as “Platform Users” because they access or use data or other services made available through the Seam Platform. Platform Users who do not have an account on the Seam Platform but receive a virtual key through the Seam Platform are referred to as “Virtual Key Users.”
• People or businesses who are referred to as “End Device Users” because they own or control, or are directly or indirectly authorized by the device owner to control, a non-Seam device. The non-Seam devices are referred to as “End Devices”;
• People who are neither Platform Users nor End Device Users but whose data may be collected by Seam-provided hardware (“Seam Device”) or by the Seam Platform are referred to as “Individuals.”

End Device Users and Platform Users are collectively referred to as “Users.”

Collection of Information

End Device Authorization. End Device Users may choose to authorize Seam (and Seam Devices and the Seam Platform) to control their End Devices through a third-party authorization mechanism or by sharing their End Device credentials to Seam through the Seam Platform.

Account Information. Users may provide setup and account information for themselves as Platform Users or for other Platform Users through the Seam Platform or directly to Seam (for example, via email). The Seam Platform also will automatically collect Seam Platform usage information relating to Platform Users (for example, login timestamps and IP addresses)(“Usage Data”).

Communications with Seam. Users, potential Users, Individuals and other people may communicate directly with Seam (for example, via email for general support purposes or by submitting a web form) or their contact information may be provided by Users for Seam to reach out directly to (for example, to provide specific troubleshooting).

Virtual Key Recipient Information. Users may provide personal information of Individuals who are their employees, contractors or customers but who do not have a Seam Platform account. For example, in order for a delivery or maintenance service provider to receive a virtual key from an User, we may collect and store information related to the service provider’s identity, eligibility to provide those services, expected timing for the services, the service recipient’s identity and the service provider’s actual precise geolocation when using the virtual key. This information helps the User to validate and secure entry into the building.

Individuals’ Information. Personal information relating to Individuals generally is collected by the Seam Platform only if that information is provided by Users. For example, an User may provide information about the identity and building unit number of an Individual receiving a package from that User (or its contractor or service provider).

Other Device Information. In connection with providing the Seam Platform, the Seam Platform automatically collects activity related to End Device and Seam Device usage (e.g. attempted and successful building entries). This information may also become personal information if an User associates the End Device or Seam Device usage activity with personal information within the Seam Platform.

Information Automatically Collected by the Website. Each time you access the Seam Website or website for the Seam Platform (collectively, “Website”), information is sent to our server by your browser or app and stored in our log files. We collect information about your use of the Website, 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 Website, 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 in connection with your use of the Website to collect information related to what you see, interact with, access and use on the Website and other Website access and use.

• We use session cookies to keep you logged in while you use features of the Website.
• We use persistent cookies, which stay in your browser and allow us to recognize you when you return to the Website. We use this to remember your information so you will not have to re-enter it, to better understand how you use the Website and our products and services, to diagnose and fix technology problems, and otherwise enhance the Website and our products and services.
• In some of our email messages, we use a pixel or “click-through URL” linked to content on the Website. We track this click-through data to help us measure the effectiveness of our customer communications.

Most Internet browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you set your browser to reject cookies, parts of the Website may not work for you. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device. Please note that unless required by law, we do not change system behavior of the Website in response to browser requests not to be tracked.

Third-Party Sites and Features. The Seam Website may include third-party social media features and other third-party plug-ins and widgets. When these features are displayed on the Seam Website, they are operated or hosted by third parties and are subject to their own privacy policies instead of this Privacy Policy. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our Privacy Policy.

Minors. The Seam Website does not knowingly collect or store any personal information about children under the age of 16.

Use of Information

Seam Platform and Seam Devices. Seam uses the contact information of Users**_ _**to send them communications from Seam. Otherwise, in general, Seam is a processor (for example, under GDPR in the European Economic Area) or a service provider (for example, under CCPA in California) for each User with respect to the personal information collected by the Seam Platform and Seam Devices from that User to operate the Seam Platform and Seam Devices. Seam may aggregate and anonymize Usage Data, in accordance with applicable law, and use such resulting de-identified data set for its purposes. Seam also may use such information for the following purposes:

• to understand how our products and services are used and to improve them;
• to protect against harm to the rights, property and safety of Seam, Users, Individuals, third parties and the public;
• to detect, prevent or otherwise address fraud, abuse, security or technical issues with our products and services.

Seam Website. Seam uses the personal Information collected from the Seam Website to communicate with you and for Seam’s own marketing purposes, including to send Seam email newsletters relevant to your interests. Seam also uses the personal information collected from the Seam Website for the following purposes:

• to understand how visitors navigate the Seam Website 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, Users, 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. Seam may use service providers to perform services on its behalf, with such service providers subject to restrictions consistent with this Privacy Notice. Depending on the location of you or the Seam Device or End Devices, Seam may process personal information on servers that are not in the same country as you or the Seam Device or End Devices.

Sharing of Information

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

Through the Seam Platform account for each User, Seam shares personal information to that User (and their authorized Users) regarding Individuals who use their End Device (e.g. who enter the property secured by the End Device) or who receive services from or through that User (e.g. Individuals receiving delivery or maintenance services through the User).

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

• to service providers to perform services on its behalf, with such service providers subject to restrictions consistent with this Privacy Notice;
• to third parties 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, customers, 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 generally for the information collected by the Seam Devices or the Seam Platform, Seam will provide a copy of or permanently delete information upon request or consent of the controller or customer to which the information belongs in accordance with law. To protect the information, Seam will take commercially reasonable steps to verify the identity of the requestor before fulfilling any information-related requests. In addition, Seam will permanently delete information collected by the Seam Devices or the Seam Platform within a reasonable period after its agreement with the applicable customer ends except to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws. Seam stores personal information from the Seam Website until you request Seam to permanently delete it. Seam will process such deletion requests in accordance with law.

Minors

Only persons aged 16 and older are allowed as Platform Users. The Seam Website, Seam Devices and the Seam Platform do not knowingly collect or store any personal information from anyone under the age of 16.

Data Security

We take security and privacy very seriously. Our team includes security experts who focus on strengthening our infrastructure and firmware devices. To learn more about our security practices, please refer to our security page seam.co/security.

International Data Transfers

Seam is headquartered in the United States, with service providers in several countries. In order to provide you with the services you sign up for by creating an account or visiting the Seam Website or using 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 here [URL to a blog article] about how many of these disclosures we have made in the last calendar year. If you are from the European Economic Area ("EEA") and we transfer your personal information to countries outside of the EEA, we will take appropriate steps to ensure your personal information is afforded the same level of protection as described in this Privacy Notice. If you are located in the EEA or Switzerland, we use a variety of legal mechanisms to help ensure your data is appropriately protected when transferred to countries outside of the EEA or Switzerland.

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 object to, or to ask us to restrict, the processing of your 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 and Switzerland are available here.

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 and other identifiers
• User ID or device identifiers (for example, IP address or other similar identifiers);
• Customer records (for example, customer records containing personal information, such as name, address, and telephone number);
• Purchase history
• Usage data

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 privacy@seam.co.

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 privacy@seam.co. 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 privacy@seam.co.