Privacy Policy

Last updated: June 27, 2023

Smith Micro Software, Inc. and its subsidiaries (collectively, “we,” “us,” or “Smith Micro”) are committed to maintaining your trust by respecting and protecting your privacy.

This Privacy Policy (this “Policy”) applies to our websites, products and services (collectively, “Products”) that link to or reference this Policy. This Policy describes how we collect, use, process and protect your personal data. It also explains your available choices about how we use and process your personal data, how we communicate with you, how you can make requests related to your personal data, and other important information. Additional information on our personal data practices may be provided in supplemental privacy statements or notices provided prior to or at the time we collect your personal data.

We reserve the right to update or make changes to this Privacy Policy from time to time in our sole discretion without prior notice, which changes we may provide to you by any reasonable means, including without limitation, by posting the revised version of this Privacy Policy on our website at www.smithmicro.com/privacy. You can determine when this Policy was last revised by referring to the “Last updated” legend at the top of this Privacy Policy. Any changes to our Privacy Policy will become effective upon our posting of the revised version on our website at www.smithmicro.com/privacy. Except where your separate consent is required by law, your use of our Products which link to our reference this Policy following such changes constitutes your acceptance of the revised Policy then in effect. By using our Products which link to or reference this Privacy Policy, you agree to the terms and conditions of this Policy. If you do not agree to the terms and conditions of this Policy, please do not use our Products.

WHAT THIS PRIVACY POLICY COVERS

This Privacy Policy applies to personal data, which we define as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be used to identify an individual person. Personal data includes information such as your name, address, email address, and phone number, as well as other information, such as demographic data, device data, and profile data. It also applies to information that is considered sensitive personal data, which includes things like precise geolocation data. For purposes of this Privacy Policy, personal data includes “personal information” and similar terms as defined under applicable privacy laws.

Except as noted below, this Privacy Policy applies to all personal data we collect when you access or use our website, products and/or services (which we again collectively refer to as our “Products”), or when you communicate or otherwise interact with us.

This Privacy Policy does not apply to information that is not personal data, including anonymous, de-identified, or aggregated data, even when such information has been derived from personal data.

By accessing or using our Products, or otherwise engaging with us, you acknowledge our collection, use, and sharing of personal data as described in this Privacy Policy. Accordingly, we encourage you to read this Privacy Policy carefully.

Special Note Regarding the Use of our Products by Children: We believe it is important to protect the privacy and safety of children. We do not knowingly collect data from, children under the age of 13, except where explicitly described otherwise in the privacy notices for Products that are designed and offered specifically to assist families with features such as parental controls and location related services. In the case of our family safety Products, like our SafePath® applications and services, which include such features, children under the age of 13 may be invited to sign up for the service by a parent or legal guardian. If you authorize a child under 13 to use a Product in which you have an account by providing them a device or other access associated with your account, any personal data associated with their use will be treated as your personal data under this privacy policy. Except as provided in connection with our SafePath Products, if you are under the age of 13, please do not provide personal data in connection with your use of Smith Micro Products. We encourage parents and guardians to go online with their children.W

Types of Data Smith Micro Collects
How We Use Personal Data
Reasons We Share Personal Data
How We Protect Your Personal Data
How to Access and Control Your Personal Data
Other Important Notices Regarding Our Privacy Practices
State Law Privacy Rights and Choices
Product-Specific Details

1. Types of Data Smith Micro Collects

Smith Micro collects data to operate effectively and to furnish or enhance your experience with our Products. You provide some of this data directly when you sign up for an account in connection with our Products or when you submit a request to us for information or support. We also record data in connection with your interaction with our Products, such as through the use of cookies on our website or through your use of one of our software solutions.

Learn More View Summary

You have choices about the data we collect. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a Product or Product feature, you may not be able to use that Product or feature.

The data we collect depends on the context of your interactions with Smith Micro and the choices you make, including your privacy settings, and the Products and features that you use. The data we collect can include the following:

Personal Data You Provide Directly to Us

Account information. If you create an account in a Smith Micro Product, we may collect account information such as your name, username or alias, passwords, telephone number, email address, and the dates on which you sign up for and/or unsubscribe from a Product, and your photograph, if you choose to assign a photograph to your account profile.

Product settings. For Products with features that enable the user to establish settings, such as our products that enable a user to establish parental controls settings or geographic safety zones, we process those settings in order to deliver those Product features to you.

Demographic information. We may collect demographic information that you choose to provide in connection with one of our Products, which may include your selected language, if the Product is offered in multiple languages.

Your Communications. If you contact us directly, we collect personal data about you, including identifiers, such as your name, email address, phone number, the contents of any message or attachments that you may send to us, and any other information you choose to provide. We will also collect identifiers from you, such as your email address and phone number, when you sign up to receive product updates, offers, and other promotional information or messages from us.

Personal Data We Collect Automatically

Contact list. If you use a Smith Micro Product that enables you to invite your selected contacts to participate in features of the Product with you, we collect data from your selected contact list entries, such as first and last name, email address, phone number, and contact photo, to make it easier for you to configure the settings for these features, which for our family safety applications may include family member location-based services and/or family member check-in functionality.

Device and Usage data. We collect data about your device and how you and your device interact with Smith Micro and our Products. For example, we may collect:

Product use data. We collect data about the Smith Micro Products you use, including any Products that you purchase and the Smith Micro web pages you visit.
Device, connectivity and configuration data. We collect data about your device and the network you use to connect to our Products. It includes data about the operating systems and other software installed on your device. It also includes device identifiers (such as the IMEI number for phones), regional and language settings, and your IP address. Your IP (Internet Protocol) address is a number that is automatically assigned to the computer that you are using by your ISP (Internet Service Provider). This number is identified and logged automatically in our server log files whenever you visit our websites, along with the time(s) of your visit(s) and the page(s) that you visited.
Environmental Variables. We may also collect certain environmental variables, such as your MAC address, computer type (Windows or Macintosh), screen resolution, OS version, Internet browser, and Internet browser version. These environmental variables are collected by most websites, and can be used to optimize your experience on our website.
Error reports and performance data. We collect data about the performance of the Products and any problems you experience with them. This data helps us to diagnose problems in our Products that you use, and to improve our Products and provide solutions. Depending on the Product that you are using and your settings, error reports can include data such as the type or severity of the problem, details of the software or hardware related to an error, contents of files you were using when an error occurred, and data about other software on your device.
Troubleshooting and Help Data. When you engage us for troubleshooting and help, we collect data about you and your hardware, software, and other details related to the incident. Such data includes contact or authentication data, the content of your communications with us, data about the condition of the machine and the application when the fault occurred and during diagnostics, and system and registry data about software installations and hardware configurations.

Device geolocation data. For Products with location-enhanced features, we collect data about the location of your device, which can be either precise or imprecise. Precise location data can be Global Navigation Satellite System (GNSS) data (e.g., GPS), as well as data identifying nearby cell towers and Wi-Fi hotspots, we collect when you enable location-based Products or features. Imprecise location data includes, for example, a location derived from your IP address or data that indicates where you are located with less precision, such as at a city or postal code level.

Social Media. When you interact with us through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network.

View Summary

2. How We Use Personal Data

We use the data that we collect to provide our Products, which may include updating and troubleshooting, providing support, and/or providing personalized recommendations and relevant marketing and advertising. We also use data to operate our business, which includes analyzing our performance and meeting our legal obligations.

Learn More View Summary

When we process personal data about you, we do so with your consent and/or as necessary to complete a transaction or to provide a Product that you have requested or authorized, to operate our business, to meet our contractual and legal obligations, to protect the security of our systems and our customers, or to fulfill our other legitimate interests as described this section and in the Reasons We Share Personal Data section below.

In particular, we use your personal data as follows:

To Fulfill a Contract with You or in to Fulfill Your Requests and to Provide Authorized or Purchased Products. We may use your personal data to fulfill the purpose for which you provided it. For example, if you have requested or subscribed to one of our Products, we will use your personal data to process your requests related to the Product, to provide the Product to you and to respond to your request for technical support, and/or to provide you with ongoing service. This may include performing our contractual obligations, keeping the Product up-to-date, safe and free of errors, including implementation of new product features and versions, verifying your identity and entitlement to use the Product, managing your subscriptions and user accounts.

Administrative Communications. We may use your personal data to communicate with you, for example to provide you with updates about your account, security updates, or important changes to our terms, conditions, and policies.

Other Communications. We may use your personal data to inform you of products, programs, services and promotions that we believe may be of interest to you. If you no longer wish to receive promotional emails, you may opt out of receiving promotional emails from us at any time by following the instructions in those messages.

Emails that You Send. We may provide functionality to permit you to send messages regarding Smith Micro website-related content to a recipient that you designate through our website. If you wish to use this feature, you will be required to provide us with, and we will use, your intended recipient’s email address in order to facilitate your sending the message. By providing any email address to facilitate the sending of messages, you confirm that you have permission to do so.

Promotions. We may operate sweepstakes, contests and similar promotions through our websites. We typically ask you for your name and contact information when you enter a promotion and in the event that you win. You should carefully review the rules of each such promotion, as the rules may contain additional important information about our use of your personal data in connection with the promotion. To the extent that the rules of any promotion conflict with this Policy concerning our use of your personal data, the promotion-specific rules will control.

Internal Business Purposes. We also use personal data for our internal business purposes. For example, we use data to develop aggregate analyses and business intelligence that enable us to operate, protect, make informed decisions about, and report on the performance of our Products and our business. We also use personal data in connection with debugging and repairing errors in our Products, and in connection with maintaining and improving the quality of our Products, including measuring and enhancing their performance and accuracy, enhancing existing features and developing new features.

Legal and Policy Compliance. We process data to comply with law and to enforce our policies, terms and conditions and other agreements. We also process contact information and credentials to help customers exercise their data protection rights. If needed, we may also process personal data to cooperate with law enforcement and protect the rights, interests, safety, or property of Smith Micro or our customers, service providers, and other third parties.

To Protect our Business and our Users. We process data to detect and help protect our business against security incidents and threats, and illegal, fraudulent, or unauthorized activities, to investigate suspicious traffic, cybersecurity threats or vulnerabilities, complaints, and claims, to enforce our policies, contracts, terms and conditions, and to defend against or pursue claims, disputes or litigation. We also process data to protect users of our Products, as well as other providers, from fraudulent, malicious, deceptive, abusive, or unlawful activities of others.

View Summary

Top

3. Reasons We Share Personal Data

We share your personal data with your consent and/or as necessary to complete a transaction or to provide a Product that you have requested or authorized, which may include sharing your data with third parties performing services on our behalf. We will also share data if required by law or to respond to legal process, to protect our customers or to protect our rights or property.

Learn More View Summary

Third Party Services. We may use third party contractors and service providers process the personal data that we collect for the purposes described in this Privacy Policy or in a supplemental privacy statement or notice, which may include services provided on our behalf or to enable certain of the features and functionality of our Products. Third party services that we use may include but are not limited to data analysis, cloud storage, mapping services, order fulfillment and other services of an administrative nature. In such cases, these companies provide services to Smith Micro pursuant to a binding agreement which limits their use of your personal data to the services that they provide. They must abide by our data privacy and security requirements and applicable law and are not allowed to use personal data they receive from us for any other purpose.

We Do Not Sell or Rent Information. Smith Micro does not sell, rent, or license personal data of our customers with others outside the Smith Micro family of companies for non-Smith Micro purposes without your consent. In particular, with respect to any of your data that we obtain through our software applications that offer MDM services, we will not for any purpose sell or disclose such data to any third parties and we will not use such data except in the delivery of the application’s services to you.

Communications that You Initiate. If you initiate contact with us, such as through a “Contact Us” or similar form on our website, or with your friends, family members or other third parties in connection with your use of our Products (e.g., by sending messages through our website or by inviting a family member to join your account for one of our Products) your personal data, such as your name and your email address, will be disclosed to your designated recipient.

When You Choose to Share Personal Data with Your Trusted Family Members. Our family safety Products, such as our SafePath application and services, allow individuals to choose to share personal data with participating family members and other individuals whom they trust. At the user’s election and depending on the features enabled by the Product, the personal data that you share may include things like your name and your precise geolocation. If you choose to share your personal data with your family members and/or other individuals whom you trust through an account in one of our Products, our Products will facilitate your sharing of such personal data with the others participating in your account. Please see the additional Product-Specific Details below.

When you Participate in a Product Trial, Demo or Evaluation. When you sign up for an account in one of our Products in connection with a third party’s trial, demonstration or evaluation of the Product and its features or performance, including as a representative or a family member of a representative of a Smith Micro customer or prospective customer, we may disclose to such third party information related to your use of the Product in connection with such trial, demonstration or evaluation, and that information may include personal data.

Promotions. If you sign up for a promotion, we may share the personal data that you provide to us in connection with the promotion with any identified third party sponsors of the promotion or otherwise in accordance with the rules applicable to such promotion. You should carefully review the rules of each promotion you choose to participate in, as they may contain additional important information about the use of your personal data. To the extent that the rules of any promotion conflict with this Policy concerning our use of your personal data, the promotion-specific rules will control.

Corporate Affiliates. We may share the information we collect with our corporate affiliates, subsidiaries, branch offices and other members of our corporate group.

Corporate Transaction. In the event of any corporate transaction involving Smith Micro, such as a merger or sale of assets, we may disclose or transfer personal data as part of such transaction.

Law enforcement; emergencies; compliance. Notwithstanding any other provision of this Policy to the contrary, we may disclose your personal data as required (a) to comply with applicable law or regulations; (b) to comply with or respond to legal process; (c) to respond to governmental or other lawful requests; (d) to enforce our rights under our terms of service; (e) to protect our operations or those of any of our affiliated entities; (f) to protect the rights, interests, privacy, safety or property of Smith Micro, our affiliated entities, you or others; (g) in connection with claims, disputes, or litigation, or to permit us to pursue available remedies or limit the damages that we may sustain; and (h) in an emergency.

Product Reviews. If you post a review or comment with respect to our Products, we may publicly post your reviews and comments online on our website or mobile app, or link your reviews to third party websites.

View Summary

4. How We Protect Your Personal Data

Smith Micro uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, to notify those individuals whose information may have been compromised, and to take such action as may be required by applicable laws and regulations.

Top

5. How to Access and Control Your Personal Data

You can view, edit or delete your personal data online for many of our Products. In connection with the use of certain of our Products, you can also make choices about our collection and use of your data. When you are asked to provide personal data, you may decline. But if you choose not to provide data that is necessary to provide a Product or feature, you may not be able to use that Product or feature. How you can access or control your personal data will depend on which of our Products that you use.

Learn More View Summary

Smith Micro Products That You Obtain from Your Wireless or Cable Service Provider. Smith Micro delivers certain Products, including our CommSuite® visual voicemail platform and our SafePath® connected lifestyle platform to wireless and cable service providers for their distribution to their customers, typically under the service provider’s brand. When you use a Smith Micro Product provided by your wireless or cable service provider, Smith Micro’s processing of your personal data in connection with that Product is governed by a contract between Smith Micro and your service provider, and the terms of your use, including the important terms related to your personal data, are as established by your service provider. To modify your account information, update or amend your personal data, exercise your rights with respect to your personal data, change your password or privacy settings or cancel your account, please log into the account that you have created through your service provider or contact your service provider directly through the means that they have made available to you.

Opt-Out. If you receive a marketing-related email from us and do not wish to receive further marketing-related emails from us, you may opt-out by following the unsubscribe instructions at the bottom of such message. If you have one or more accounts with us in connection with our Products, you may also choose to unsubscribe by logging in and modifying your profile for the applicable Smith Micro Product. If you have more than one account with us, you will need to update your choices for each account. We will endeavor to comply with your request as soon as reasonably practicable and in any event as required by law.

Geolocation Data. If you are using a Smith Micro Product with location-based features on your mobile device, such as our SafePath application, the Product will collect data about the device location if the device is turned on and you are logged in to the application. You can stop sharing your location with us at any time by updating the settings on your mobile device to limit the app's access to your location information. Please note, however, that we may not be able to provide all of the functionalities of the Service to you if you disable access to location data. If you no longer want to continue using our Product, uninstalling or logging out of the application will also stop us from collecting your location.

View Summary

6. Other Important Notices Regarding Our Privacy Practices

Below you will find additional privacy information that you may find important or helpful to your understanding of how we collect and use your personal data.

Learn More View Summary

Cookies. Smith Micro uses "cookies" in conjunction with our web-based Products to obtain information. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of our websites and in connection with web-based Products. If you do not want information collected through the use of cookies, your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some aspects of our Products may not work as intended or may not work at all without cookies.

Pixel Tags. We and our service providers may also use so-called "pixel tags," "web beacons," "clear GIFs," or similar means (collectively, "Pixel Tags") in connection with our website pages and HTML-formatted email messages to, among other things, track the actions of website users and email recipients, to determine the success of marketing campaigns and to compile aggregate statistics about website usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to website visitors and may be associated with cookies on the visitors' hard drives. Pixel Tags allow us to count users who have visited certain pages of our websites, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

Third Party Sites. Our Products may contain links to third party websites. These linked sites are not under Smith Micro's control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and our inclusion of a link does not imply our endorsement of the linked site. If you provide any personal data through any such third party website, your transaction will occur on such third party's (and not Smith Micro’s) website, and the personal data you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

Analytics and Advertising Services. We may use third-parties to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet and to track and report on the performance of those advertisements, and to serve ads when you visit our websites. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you use our Products, as well as when you visit other online sites and services. If you would like more information about this practice and to know your choices about not having this information used by these companies, please visit networkadvertising.org/optout_nonppii.asp.

Transfer, Processing and Storage of Personal Data. Our websites and certain of our other Products are operated in the United States of America. We may process the personal data that we collect in your region, in the United States, and in any other country where we or our affiliates, subsidiaries, or service providers operate. We take steps to ensure that the data we collect under this Policy is processed according to the provisions of this Policy and the requirements of applicable law.

We transfer personal data from the European Economic Area to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms, including contracts incorporating the standard contractual clauses adopted by the European Union, to help ensure your rights and protections with respect to your data.

Security. We seek to have security measures and tools (such as firewalls, digital SSL certificates, intrusion detection systems, and database encryption) in place to help protect against the loss, misuse and alteration of the information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. As a result, although we strive to protect your data, we cannot ensure or warrant the security of any information you transmit to us through or in connection with our websites or that is stored by us. You acknowledge and agree that any information you transmit through our websites or upload for storage in connection with our websites is so transmitted or stored at your own risk. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us at privacy@smithmicro.com or at our physical address at 5800 Corporate Dr., 5th Floor, Pittsburgh, PA 15237, Attention: Privacy (note however that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).

Retention Period. We will retain your data for the period necessary to fulfill the purposes outlined in this policy unless a longer retention period is required by law and/or regulations. When we no longer have an ongoing legitimate business reason to keep your personal data, it will either be securely disposed of, or de-identified through an appropriate anonymization means.

Jurisdictional Issues. We host our websites from the United States, and our websites are not intended to subject us to the laws or jurisdiction of any state, country or territory other than those of the United States. We do not represent or warrant that our websites, or any part thereof, are appropriate or available for use in any particular jurisdiction other than the United States. Those who choose to access our websites do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the availability of our websites, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. By using our websites and submitting any personal data in connection with such use, you consent to the transfer of your submitted personal data to other countries, such as the United States, which may provide a different level of data security than in your country of residence.

Contacting Us. If you have any questions regarding this policy, please contact us by email at: privacy@smithmicro.com or mail us at:

Smith Micro Software, Inc.
Attention: Privacy
5800 Corporate Drive
Pittsburgh, PA 15237

Please note that email communications will not necessarily be secure; accordingly you should not include credit card information or other sensitive information in your email correspondence with us.

View Summary

7. Your Privacy Rights and Choices

There are a variety of data protection laws around the world that provide privacy rights to consumers and end users. Within the United States, these laws may vary and certain states provide their residents with specific rights regarding their personal data. To underscore our commitment to your privacy, we also offer these state law driven choices to consumers in places where they are not required.

Learn More View Summary

Depending on your use of our Products, the following categories of personal information may have been collected in the preceding 12 months (as these processing activities are defined under applicable privacy laws, such as the California Consumer Privacy Act (CCPA):

Categories of personal data collected and disclosed. For business purposes in the preceding 12 months is described in Types of Data Smith Micro Collects and Reasons We Share Personal Data.

Business or commercial purpose for collecting personal data. Our business purposes for collecting your personal data is described in How We Use Personal Data.

Categories of sources of personal data. This includes information you provide us, that we collect and infer when you use our Products and provided from other sources. For more information, see How We Use Personal Data and Reasons We Share Personal Data.

CCPA provides consumers who are California residents with the additional rights described below. You may exercise any of the rights described in this section by contacting us at privacy@smithmicro.com. Please reference “CCPA” in your subject line. These instructions are also available by calling our toll-free CCPA hotline at 833-606-0138. Please note that we may ask you to verify your identity before taking further action on your request. If we are unable to verify your identify, we will unfortunately not be able to fulfill your request. This is for your protection.

• Your Right to Know and Access: You have the right to know and access what data we have collected about you over the past 12 months, including:
- o The categories of personal information we’ve collected about you;
- o The categories of sources from which the personal information is collected;
- o The business or commercial purpose for collecting, selling or sharing your personal information (as the terms “selling” and “sharing” are defined under CCPA);
- o The categories of third parties to whom we disclose personal information; and
- o The specific pieces of personal information we have collected about you.
• Your Right to Delete: You have the right to request that we delete personal information we have collected from you (and direct our service providers to do the same). In some instances, however, we may decline to honor your request where an exception applies.
• Your Right to Correct Inaccurate Personal Information: You have the right to request that we correct any of your personal information that we maintain. When you make such a request, we will ask you to provide documentation supporting the accuracy of the personal information that is the subject of your request, and we will evaluate the totality of the data relating to the personal information that you are contesting. We may deny your request if we determine that the personal information that we maintain is more likely than not accurate based on the data provided. We will notify you to let you know whether or not we have been able to honor your request, and the reasons for our determination.
• Your Right to Ask Us Not to Sell or Share Your Personal Information and Your Right to Ask Us to Limit the Use of Your Sensitive Personal Information: You can tell us not to sell or share your personal information, as the terms “sell” and “share” are defined under CCPA. You can also tell us to limit the use of your sensitive personal information. Please note that providing personal data to service providers or contractors does not constitute the sale or sharing of personal information.
• Your Right to Appeal: You can ask us to reconsider the outcome of a request you’ve submitted to exercise any of these rights. Once we receive your request, we will research your request and provide you with an explanation of our review.
• Other Rights: You also have the right not to be discriminated against for exercising any of the rights listed above.

View Summary

Top

8. Product-Specific Details

In addition to the information provided above, which applies generally to all of our Products, you may find the following additional, information related to specific Smith Micro Products, to be important or useful to you.

a. SafePath® Platform

Our SafePath platform is a connected lifestyle platform, which includes tools for family safety, including powerful family locator functionality, robust parental controls and built-in support for wearable devices such as GPS wristwatches and pet trackers. Our SafePath family of products and services are offered to consumers by wireless and cable service providers, typically under the service provider’s brand, and the collection and use of your personal data in connection with your use of the service will be governed by the privacy policy established by your service provider. For more information, please see the privacy policy offered by your service provider.

In certain cases, we may allow users to access a version of our SafePath platform and related mobile application directly from us for product trial, demonstration, evaluation, market research, or other limited purposes. If you are a user of our SafePath platform in one of these instances, our practices with regard to personal data are as described in our SafePath Privacy Notice, which includes important information specific to SafePath and where it is applicable can be accessed directly from the application. In these instances, this Privacy Policy is in addition to and supplemental to the SafePath Privacy Notice.

b. CommSuite® Platform

Our CommSuite platform delivers visual voicemail and related services to enhance the voicemail experience. Our CommSuite products and services are offered to consumers by wireless and cable service providers, typically under the service provider’s brand, and the collection and use of your personal data in connection with your use of the service will be governed by the privacy policy established by your service provider. For more information, please see the privacy policy offered by your service provider.

c. ViewSpot® Platform

Our ViewSpot platform is intended for use by businesses, not consumers. It enables wireless service providers to display promotional content on display devices in their own or their authorized agents’ retail stores and/or to analyze anonymous data related to the retail store, the devices displayed in the retail store and the promotional content displayed through the service. Our ViewSpot platform does not collect personal data.

Top

Privacy Policy

WHAT THIS PRIVACY POLICY COVERS

Table of Contents

1. Types of Data Smith Micro Collects

2. How We Use Personal Data

3. Reasons We Share Personal Data

4. How We Protect Your Personal Data

5. How to Access and Control Your Personal Data

6. Other Important Notices Regarding Our Privacy Practices

7. Your Privacy Rights and Choices

8. Product-Specific Details

a. SafePath® Platform

b. CommSuite® Platform

c. ViewSpot® Platform

where we are