• 1. PRIVACY POLICY

  TrickleStar Inc. ("TrickleStar", "We", "Us" or "Our") values your privacy and is committed to protecting your personal information. This Privacy Policy ("Policy") describes how and when TrickleStar collects, uses, discloses, transfers, and stores your information. This Policy explains our information practices and applies to TrickleStar products and devices (collectively “Products”), applications, services, marketing, promotions, warranty registration, after sales support, repair support, websites, online applications and other services that refer to or link to the Policy (collectively our “Services”).

  Please note that the Policy applies regardless of whether you use a computer, mobile phone, tablet, TV, or other device to access our Services. It is important that you read the Policy carefully because anytime you use our Services, you consent to the practices we describe in the Policy. If you do not agree to the practices described in this Policy, you should immediately refrain and cease to use any of our Services.

• 2. INFORMATION COLLECTION AND USE

  1. The information we collect from you enables us to fulfill your request for our products to send you information or content in which you may be interested and keep you abreast of any updates related to our website. We also use this information to personalize and continually improve our Site, your experience, and to ultimately serve you better.

  2. If you would like to place an order, you will need to provide some personal information, such as your name, email address and address. When making a purchase of our products, you may be requested to provide your credit card, debit card, or acceptable payment option and your billing address and shipping address. You are welcome to not provide this information, but if you do not wish to provide this information then there is no way for us to provide you with our products.

  3. Information We Collect Automatically: In addition, when you visit the Site and/or register for Membership, we may collect certain information by automated means, such as cookies, web beacons, and other automated devices. We also use third-party website analytics tools (such as Google Analytics, and Facebook Insights), that collect information about visitor traffic on the Site. The information we may collect by automated means which may include the following:

  • Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser, domain name and operating system type)

  • URLs that refer visitors to our sites

  • Dates and times of visits to our sites

  • Information on actions taken on our sites (such as page views and site navigation patterns)

  • A general geographic location (such as country and city) from which a visitor accesses our websites

  • Search terms that visitors use to reach our sites and the webpage that led you to the Sites

  • Connected device usage data

  • Power consumption and connected appliance data; for example; temperature, humidity, status.

• 3. COOKIES AND OTHER TRACKING TECHNOLOGY:

  1. Site Analytics: As noted, we may use automated devices and applications, such as Google Analytics, to evaluate usage of our Site. We also may use other analytic means to evaluate our Site. We use these tools to help us improve our Site, performance and user experiences.

  2. Links: TrickleStar may keep track of how you interact with links across our Services, including our email notifications, third-party services, and client applications, by redirecting clicks or through other means. We do this to help improve our Services, to provide more relevant advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.

• 4. INFORMATION SHARING AND DISCLOSURE

  We do not disclose your private personal information except in the circumstances described here.

  • Providing Our Services: We may share or disclose your information with third parties who are necessary to provide you with our Services. This may include Demand Response Aggregators, Gas Utilities or Electric Utilities that operate Demand Response and Time Of Use programs.

  • Your Consent: We may share or disclose your information at your direction, such as when you authorize a third-party web client or application as log-in credentials when you order.

  • Law and Harm: Notwithstanding anything to the contrary in this Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect TrickleStar's rights or property. However, nothing in this Policy is intended to limit any legal defenses or objections that you may have to a third party's, including a government's, request to disclose your information.

  • Business Transfers: In the event that TrickleStar is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.

• 5. HOW WE PROTECT YOUR INFORMATION

  1. We are committed to protecting the information we receive from you. We follow reasonable technical and management practices to help protect the confidentiality, security and integrity of data stored on our system. While no computer system is completely secure, we believe the measures we have implemented reduce the likelihood of security problems to a level appropriate to the type of data involved. We have implemented commercially reasonable precautions, including, where appropriate, password protection, encryption, firewalls, and internal restrictions on who may access data to protect our Site and the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. The Site encrypts your credit card number, debit card number, or other payment option and other personal information using secure technology to provide for the secure transmission of the information from your personal computer to our servers. In addition, only those employees and third parties who need access to your information in order to perform their duties are allowed such access.

     You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a password that nobody else knows or can easily guess, and keeping your password private. Also, you should never share your log-in information with others. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

• 6. CONSENT TO INTERNATIONAL TRANSFER OF DATA

  1. By using or participating in any Service and/or providing us with your information, you consent to the collection, transfer, storage and processing of your information outside of the USA, consistent with this Policy. Please note that the data protection and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country.

• 7. ACCESSING YOUR INFORMATION

  1. You have the right to request details about the information we collect and to correct inaccuracies in that information. Any further statutory user rights remain unaffected. If permitted by law, we may charge you a small fee for providing you with this ability. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. If you would like to make a request to access your information, please contact our customer service department at customer.service@tricklestar.com

• 8. DATA RETENTION

  1. We take reasonable steps to ensure that information about you is available only for so long as is necessary for the purpose for which it was collected, or as required under any contract, or by applicable law.

• 9. THIRD-PARTY LINKS AND PRODUCTS ON OUR SERVICES

  1. Our Services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution and review the privacy statements applicable to the third party websites and services you use.

  2. Third Parties that Provide Content, Advertising or Functionality on Our Services -

  • We enable you to watch video content provided by content providers;

  • Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them; and

  • We enable you to share certain materials on the Services with others through social networking services such as Facebook, Twitter, Google +, and LinkedIn.

  • These third parties may collect or receive certain information about your use of the Services, including through the use of cookies, beacons, and similar technologies, and this information may be collected over time and combined with information collected across different websites and online services. We do not control the data collection and use practices of these companies. Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising.

  • If you connect with a social networking service, we may receive and store authentication information from that service to enable you to log in, as well as other information that you allow us to receive when you connect with these services.

• 10. CALIFORNIA RESIDENTS

  California law allows California residents to ask companies with whom they have an established business relationship to provide certain information about the companies’ sharing of Personally Identifiable Information with third-parties for direct marketing purposes. We do not share any California consumer Personally Identifiable Information with third-parties for marketing purposes without consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices may contact us using the contact information set forth below.

  If you are a California resident, please see our California Resident Privacy Notice, below.

• 11. CHANGES TO THIS POLICY

  We may revise this Policy from time to time. The most current version of the policy will govern our use of your information and will always be on the TrickleStar website. If we make a change to this policy that, in our sole discretion, is material, we will notify you via an email to the email address associated with your account. By continuing to access or use the Site after those changes become effective, you agree to be bound by the revised Policy.

• 12. HOW TO CONTACT US IF YOU WISH TO DISCUSS THIS POLICY

  If you wish to discuss any aspect of this policy, please contact us by email customer.service@tricklestar.com

APPENDIX A

Category	Examples	Collected and How	How Disclosed
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.	Yes. User’s Identifiers data will be collected during user sign up to TrickleStar Portal such as Name, Email, Phone number, Postal address & Utility info. User’s IP address will be stored for device tracking and troubleshooting purposes. User’s Network SSID will be stored for connecting our connected products. User’s usage data will be stored for our internal analytics purposes.	Disclosed to service providers solely for the purpose of completing the transaction initiated by the user.
B. Personally Identifiable Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number. Some Personally Identifiable Information included in this category may overlap with other categories.	Yes, name and address, collected during user sign up to TrickleStar Portal.	Disclosed to service providers solely for the purpose of completing the transaction initiated by the user.
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, citizenship, physical or mental disability, sex (including gender, gender identity, gender expression).	No.	N/A
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Yes, solely related to purchases of products and services from TrickleStar. Transaction records will be stored for user’s purchased Products via TrickleStar Website such as personal info, payment info and shipment info.	Disclosed to service providers solely for the purpose of completing the transaction initiated by the user.
E. Biometric information.	Activity patterns used to extract a template or other identifier or identifying information, such as keystroke. *We do not utilize facial recognition software.	No	N/A
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes, solely related to the TrickleStar website. We log the user’s activities & events for TrickleStar IoT connected devices for up to 6 months. This is for troubleshooting purposes.	Not disclosed to third parties, internal use only.
G. Geolocation data.	Physical location or movements.	Yes. We collect user location data (longitude and latitude) for geofencing feature from our connected devices but only for users that opt-in to using this feature.	Not disclosed to third parties, internal use only.
H. Sensory data.	Audio, electronic and visual.	Yes. We collect occupancy data via a motion detector, temperature and humidity.	Not disclosed to third parties, internal use only.
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No	N/A
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as class lists, student identification codes.	No	N/A
K. Inferences drawn from other Personally Identifiable Information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No	N/A