This Privacy Policy explains how Sauron Industries, Inc. (“Sauron,” “we,” “us,” or “our”) collects, uses, discloses and protects personal information when you visit our website at www.sauron.systems (the “Site”), use our mobile application, purchase or use our home security monitoring and surveillance products and services (collectively, the “Services”) or otherwise interact with us. This Policy is designed to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (Cal. Civ. Code §§ 1798.100–1798.199.100) (“CCPA/CPRA”), the California Online Privacy Protection Act (Cal. Bus. & Prof. Code §§ 22575–22579) (“CalOPPA”), the federal Children’s Online Privacy Protection Act (15 U.S.C. §§ 6501–6506) (“COPPA”), and the federal Trade Commission Act’s prohibition on unfair and deceptive practices (15 U.S.C. § 45).

If you are a California resident, see Section 8 (“Your California Privacy Rights”) for rights specific to you. If you reside outside California, additional state-specific rights may apply to you as described in Section 9.

1. Personal Information We Collect

We collect the categories of personal information described below. The specific information we collect depends on how you interact with us — for example, whether you simply browse the Site, create an account, purchase a Service or contact customer support.

1.1 Information You Provide Directly

• Identifiers: name, email address, mailing address, telephone number, account username and password, and government-issued identification information if provided for installer background-check purposes.
• Payment Information: billing address and payment card or bank account information, processed by our third-party payment processor. We do not store full payment card numbers on our own systems.
• Account and Service Information: information you provide when creating an account, configuring your system, setting sharing permissions or contacting customer support, including service preferences and household configuration details.
• Communications: records of your communications with us, including support tickets, emails, and chat transcripts.

1.2 Information Collected Automatically

• Device and Usage Data: IP address, browser type, operating system, device identifiers, pages viewed, and general usage patterns on the Site and mobile application, collected via cookies, SDKs and similar tracking technologies (see Section 4).
• Approximate Location Data: derived from IP address or, if you enable location services on the mobile application, more precise device location.

1.3 Information Collected Through the Services

Because our Services involve home security monitoring, we collect certain categories of information directly from your premises and connected devices. This includes:

• Video and Image Data: video footage and still images captured by cameras and sensors installed at your premises.
• Audio Data: audio recordings, where enabled and where consented to in accordance with applicable two-party consent laws, including the California Invasion of Privacy Act (Cal. Penal Code § 632).
• Sensor and Event Data: motion-detection events, door/window sensor activity, alarm activations and system diagnostic data.
• Biometric Information: if you enable optional facial-recognition or person-recognition features, we collect biometric identifiers derived from video footage of individuals at your premises, including household members, guests and visitors. Biometric Information is Sensitive Personal Information under Cal. Civ. Code § 1798.140(ae)(2). We collect and use Biometric Information only as described in Section 3.3 below.

1.4 Sensitive Personal Information

Some of the information described above constitutes “Sensitive Personal Information” under the CCPA/CPRA, including: precise geolocation, account log-in credentials and biometric information collected for the purpose of uniquely identifying an individual. We collect and use Sensitive Personal Information only for purposes permitted under Cal. Civ. Code § 1798.121, including providing the Services you request, and we do not use or disclose Sensitive Personal Information to infer characteristics about you beyond what is reasonably necessary to provide the Services.

2. Sources of Personal Information

We collect personal information from the following sources:

• Directly from you, when you create an account, purchase Services, configure your system or contact us.
• Automatically from your devices and use of the Services, including cameras, sensors and the mobile application.
• From service providers who assist us in operating the Services, such as payment processors, cloud-storage providers and customer-support platforms.
• From professional installers and alarm agents who solicit, negotiate or perform installation services on our behalf.

3. How We Use Personal Information

We use personal information for the following business and commercial purposes:

• To provide, maintain and improve the Services, including monitoring, alerting and emergency dispatch coordination.
• To process payments, manage your account and provide customer support.
• To communicate with you about your account, the Services and service-related notices.
• To maintain the security and integrity of the Services, including detecting and preventing fraud, unauthorized access and other malicious activity.
• To comply with legal obligations, respond to lawful requests from public authorities and enforce our agreements.

3.1 Marketing Communications

With your consent where required by law, we may use your contact information to send you promotional communications about new features or offers. You may opt out of marketing communications at any time using the unsubscribe link in any marketing email or by contacting us as described in Section 11.

3.2 De-Identified and Aggregated Data

We may create and use de-identified and aggregated data derived from Service data to develop, train, and improve our detection and analytics models, conduct security research and develop new products. De-identified data is not re-identified and does not constitute personal information once de-identified consistent with Cal. Civ. Code § 1798.145(a)(6).

3.3 Biometric Information and Model Training

Where you enable optional facial- or person-recognition features, we use Biometric Information to provide those features within your household’s account. We do not use identifiable Biometric Information to train, fine-tune, or improve any recognition model intended to operate across other customers’ premises unless we have obtained your separate, opt-in, written consent for that specific use, which you may withdraw at any time as described in that consent disclosure. We do not condition provision of the Services on your consent to such cross-account model training use.

4. Cookies and Tracking Technologies

The Site uses cookies, web beacons and similar tracking technologies to operate the Site, remember your preferences and understand how visitors use the Site, consistent with CalOPPA. You can control cookies through your browser settings; disabling cookies may affect the functionality of the Site.

Do Not Track: The Site does not currently respond to “Do Not Track” browser signals. Where the Site uses cookies or similar technologies subject to the CCPA/CPRA’s definition of “sale” or “share,” we honor opt-out preference signals, including the Global Privacy Control, as described in Section 8.4.

5. How We Disclose Personal Information

We disclose personal information to the following categories of recipients, for the business purposes described above:

• Service Providers: third parties that perform services on our behalf, such as cloud hosting and storage, payment processing, customer support platforms and monitoring-station operators, under written contracts that satisfy the service-provider requirements of Cal. Civ. Code § 1798.100(d), including prohibitions on retaining, using or disclosing personal information outside the direct business relationship with us.
• Emergency Responders and Law Enforcement: in connection with an active alarm event, or in response to valid legal process or where we believe disclosure is necessary to protect the safety of any person.
• Professional Advisors: auditors, attorneys and other professional advisors, where necessary for their services to us.
• Business Transfers: in connection with a merger, acquisition, financing or sale of business assets, subject to standard confidentiality protections.

5.1 No Sale or Sharing of Personal Information

We do not sell personal information for monetary consideration.  

6. Data Retention

We retain personal information for as long as reasonably necessary to provide the Services and fulfill the purposes described in this Policy, consistent with the proportionality standard in Cal. Civ. Code § 1798.100(c). Specific retention periods for video, event and account data are set forth in your Service Agreement and applicable Schedules. Upon termination of your Services, we delete your Service data within the period specified in your Service Agreement, except where longer retention is required by law or a pending legal hold.

7. Data Security

We maintain a written information security program with administrative, physical and technical safeguards appropriate to the sensitivity of the personal information we process, consistent with industry standards. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

8. Your California Privacy Rights

If you are a California resident, you have the following rights under the CCPA/CPRA with respect to your personal information, subject to certain exceptions:

8.1 Right to Know

You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purpose for collecting it and the categories of third parties with whom we have disclosed it, covering the 12-month period preceding your request.

8.2 Right to Delete

You may request that we delete personal information we have collected from you, subject to certain exceptions, such as where retention is necessary to complete a transaction, detect security incidents, comply with a legal obligation or for other purposes permitted under Cal. Civ. Code § 1798.105(d).

8.3 Right to Correct

You may request that we correct inaccurate personal information that we maintain about you.

8.4 Right to Opt Out of Sale or Sharing

Although we do not currently sell or share personal information as described in Section 5.1, you have the right to opt out of any future sale or sharing of your personal information. Where applicable, you may exercise this right by clicking “Your Privacy Choices” in the Site footer, or by using a recognized opt-out preference signal, such as the Global Privacy Control.

8.5 Right to Limit Use of Sensitive Personal Information

You have the right to direct us to limit our use of your Sensitive Personal Information to that which is necessary to provide the Services. You may exercise this right by contacting us as described in Section 11, or, where applicable, through a “Limit the Use of My Sensitive Personal Information” link on the Site.

8.6 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights, including by denying Services, charging different prices, or providing a different level of quality, except as permitted by law in connection with a voluntary financial incentive program. 

8.7 Right to Appeal

If we deny your request to exercise any of the above rights, you may appeal that decision by contacting us as described in Section 11. We will respond to your appeal within 45 days, consistent with Cal. Code Regs. tit. 11, § 7026.

8.8 How to Exercise Your Rights

You may submit a request to know, delete, correct, or limit use of Sensitive Personal Information by: (a) calling us at 1 888 282 5598 or (b) emailing us at privacy@sauron.systems. We will verify your identity before processing your request, consistent with Cal. Code Regs. tit. 11, § 7060–7062. You may designate an authorized agent to submit a request on your behalf, subject to our ability to verify the agent’s authority. We will respond to verifiable requests within 45 days, with one 45-day extension where reasonably necessary.

9. Other State Privacy Rights

If you reside in a state other than California that has enacted a comprehensive consumer privacy law — for example, Virginia, Colorado, Connecticut, Utah, Oregon, or Texas — you may have similar rights to know, access, delete, correct and opt out of certain processing of your personal information under that state’s law. You may exercise those rights by contacting us as described in Section 11. 

10. Children’s Privacy

The Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13 in violation of COPPA. If we learn that we have collected personal information from a child under 13 without parent or guardian consent, we will take steps to delete that information. If you believe we have collected information from a child under 13, please contact us as described in Section 11.

Note: Because the Services may incidentally capture images or video of minors present at a monitored premises (such as a Client’s children), this incidental collection is part of the Client’s use of the Services under the Service Agreement, rather than collection directly from a child online, and is addressed in the Service Agreement rather than this Section.

11. Contact Us

If you have questions about this Policy or wish to exercise your privacy rights, please contact us at:

Sauron Industries, Inc.
205 Second Street
San Francisco, CA 94105
Email: privacy@sauron.systems
Phone: 415-481-3545

12. Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy on the Site with a revised “Last Updated” date, and where required by law, provide additional notice of material changes.

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