Effective Date: April 12, 2023

INTRODUCTION

The Wuxi Force Technology Co., Ltd. (collectively, “FT”, “we”, “our”, or “us”) are committed to protecting your privacy. References in this notice to “FT”, “we”, “us” and “our” are references to the entity responsible for the processing of your personal data.

Please read this Privacy Notice carefully. By using any of our Services, you agree to the collection, use, sale, share, and disclosure of your personal data as described in this Privacy Notice. If any term(s) in this Privacy Notice is unacceptable to you, please do not use the Services or provide any personal data.

INFORMATION COLLECTION

Information You Provide or We Collect About You Directly

When Using Our Services

We collect several types of information from and about users of our Services, which may include information defined as personal data, personal information, or personally identifiable information under applicable law (“personal data”).

For example, the personal data we collect from you may include:

· Personal identifiers, such as name, mailing address and postal code, email address, telephone or mobile phone number, or government-issued ID number;

· Commercial information, such as credit or debit card number or information collected and processed on our behalf by our vendors;

· Dealer ID;

· User account information, such as FT account number, user ID, or password;

· Information regarding the products or equipment or Services purchased;

· Information you provide to us about authorized users (e.g., guests or co-owners) who may have access to or be able to action your connected devices through one of our Sites or Apps. Information you provide about your authorized users includes their names or email addresses;

· Inferences drawn from other personal data to create consumer profile;

· Photographs (if you elect to upload one) or avatars which you choose to upload (if available);

· Internet or other electronic network activity information, including, browsing history, search history, and information regarding your interaction with our Sites or Apps (as explained further below under Information Collected Automatically); and

· Charges you incur and other information relating to your transactions.

Depending on the country in which you use our Services and subject to applicable laws, the personal data we collect from you may, for example, also include, but are not limited to:

· Biometric information, such as facial recognition, image, or fingerprint scans;

· Precise and/or approximate geolocation data;

· Video images and audio recordings of you and those that come within range of your cameras or cameras of others that use our Services; and

· Protected classification information, such as age, gender, nationality, date of birth, or marital status.

We collect such personal data directly from you through our Services, when, for example, you:

· Complete forms on our Sites or in our Apps. This includes information provided when you sign up for our products, services, newsletters, emails and other types of information material; when we process and respond to your inquiries related to products, tech data sheets, technical support and customer service; search for a retailer or dealer; or when you provide feedback on our Services;

· Use our Services. This includes when you use our Sites, Apps, and/or devices such as our camera and security features;

· Register for an account on or otherwise use our Apps. This information may include, for example, registration data such as your name and email address or the connected devices you have installed;

· Provide to us information about authorized users (e.g., guests or co-owners) who may have access to or be able to action your connected devices through one of our Sites or Apps. Information you provide about your authorized users may include their names and email addresses;

· Correspond with us. This includes information and personal data contained in records and copies of your correspondence with us, including your participation in a survey or promotion, request for information, or when you contact us;

· Use or register one of our products or connected devices or Services. We collect details of actions you or your authorized users initiate through our Apps. For example, we will collect logs of when a garage door is opened or closed through the Services. This data may be available to other authorized users, depending on their level of permission, through device history logs within the App; and

· Purchase a product or service. We collect commercial information [via our third-party vendors], such as credit or debit card number or other financial information.

· Privacy and video surveillance laws in your jurisdiction may apply to your use of our products and Services. You are solely responsible for ensuring that you comply with applicable law when you use our products or Services. For example, you may need to display a notice that alerts visitors to your home that you are using our products or services. Capturing, recording or sharing video or audio content that involves other people, or capturing other peoples’ facial feature information, may affect their privacy rights.

Information Collected from Third Parties or Other Sources

Subject to applicable law, we may obtain personal data or other information about you from third parties or other sources and combine this information with the information we collect from and about you through the Services. Such information may include, but is not limited to:

· Information obtained through communications that you make through a third party, such as through our network of independent retailers and/or dealers;

· Information obtained through transactions you complete with us or our retailers, including charges you incur;

· Information about your credit history or other publicly available information about you from consumer reporting agencies;

· Prospective customer information (e.g., business contact information) and analytics information shared with us by third-party partners or vendors;

· Any other information obtained through companies that have business relationships with us, such as our licensees, affiliates, and business partners; and

· Information, including your name and email address, provided by another user in order to invite you to set up an account as an authorized user of a connected device or one of our other products.

Subject to applicable law, we also may obtain information and personal data about you from other online sources, including when you connect with us through our official corporate pages on third party social networks (such as Facebook) or the “apps” on those pages. This information may include, but is not limited to, name, username, demographic information, updated address or contact information, interests, and publicly-observed data, such as from social media and online activity. We may combine this information with the information we collect from and about you through the Services.

Information Automatically Collected

As with many other websites and “Apps,” as you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, patterns, and connected device, including:

· Details of your visits to our Services, including resources that you access and use on our Services, the areas or pages of the Site or App that you visit, the amount of time you spend viewing the Site or App, traffic data, location data, logs, language, date and time of access, frequency of your return to the Site or App, other click-stream or Site/App-usage data, emails that you open, forward or click-through to our Site or App, and other communication data;

· Information about your computer, mobile devices and internet connection, including your IP address, geolocation, operating system, software version, phone model, phone operating system, domain name from which you accessed the Services, and browser type;

· Device information, including the model, serial number, and technical information about the device you have installed and other information you choose to share about the product while using our Services, including but not limited to the device status for entryway products and logging information regarding device usage;

· Details of referring websites (e.g., URL);

· Details of actions you or your authorized users initiate with your connected devices through our Apps. Please note that this data may also be available to other authorized users, depending on their level of permission, through device history logs within the App, as described further in the “Information Sharing” section below; and

· Anonymized historic App data for programming testing purposes.

The information we collect automatically is statistical data that helps us improve our Services and deliver a better and more personalized service, including by enabling us to:

· Determine traffic patterns;

· Count visits;

· Determine traffic sources so we can measure and improve the performance and security of our Services;

· Help us to know which pages and content are the most and least popular;

· Observe search patterns to provide more intuitive navigation cues;

· Determine user frequency and recency; and

· Troubleshoot unexpected issues with your connected devices.

· Cookies Used on the Services

We and certain third parties may use cookies, web beacons, pixel tags, JavaScript, or other technologies to collect certain information about visitors to our Sites or Apps and interactions with our emails and online or mobile advertisements, and may use such information to allow FT to keep track of analytics and certain statistical information that enables us to improve our Sites and Apps and provide you with more relevant content and advertising on our Sites, Apps, or other websites or mobile applications.

For EEA Users: Information on Our Use of Google Analytics

If you have provided your consent at our Cookie Preference Center Our Sites and Apps may use Google Analytics.

During your visit to our Sites and Apps, the following data may be collected:

· The pages you call up, your “click behavior”;

· Achievement of “goals” (conversions, e.g., newsletter registrations, downloads, purchases);

· Your user behavior (e.g., clicks, time spend, bounce rates);

· Your approximate location (region);

· Your IP address (in abbreviated form);

· Technical information about your browser and the end devices you use (e.g., language settings, screen resolution);

· Your internet provider; and

· The referrer URL (the website/advertising medium from which you came to this website).

Combination of Information

Subject to and in accordance with applicable law, we may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Sites and Apps (including personal data), as well as information collected from other online sources or from third-party sources to help us tailor our communications to you and to improve our Services.

INFORMATION USE

Below is information on how we process the information collected about you (including personal data), as well as the corresponding legal basis. We may process your information where the processing is:

· Necessary for entering into, or the performance of, a contract with you. For example:

· To carry out our obligations arising from any contracts entered into between you and us, and to provide you with the information, products and services you request from us, and

validate, confirm, verify, and track your account, products or services (including to process payment card transactions, or to contact you about your account, products or services).

· Necessary for us to comply with a legal obligation.

· The processing of your personal data is a statutory requirement

· Necessary for the purposes of the legitimate interests pursued by a third party or us (to the extent it does not infringe on any individual’s fundamental rights and freedoms). For example:

· To allow you to participate in interactive features of our Services (when you choose to do so);

· To keep our Services safe and secure;

· To provide you with technical support and to improve our content, products and Services;

· To provide you with information that you have requested and respond to your enquiries;

· To notify you of changes to our Services;

· If you are an existing customer, to communicate (including by email and SMS) with you to provide information about goods and services similar to those that were the subject of a previous sale or, where permitted by applicable law, negotiations of a sale to you;

· To protect the security and integrity of the Sites, Apps, and our business, such as by protecting against fraud, unauthorized transactions, claims and other liabilities and managing risk exposure, including by identifying potential hackers and other unauthorized users;

· Subject to applicable law and regulations, in the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, to transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal data that you provide and other information concerning your relationship with us;

· To anonymize historic App data for programming testing purposes;

· To use your data in an aggregated non-specific format for analytical and demographic purposes;

· To troubleshoot unexpected issues with your connected devices and other FT products;

· If you use any of the Sites or Apps to connect with third party services to use information from and about you, on your behalf, to interact with these third-party services based on your requests; and

· Necessary to provide you with the respective service (e.g., use of strictly necessary cookies for the performance of our Sites and Apps). Without such information, we may not be able to deliver the respective service to you.

· Pursuant to valid consent, depending on the country in which you use our Services and subject to applicable laws, provided by you, in order to present the content from our services in the most effective manner for you and for your device, and across different services;

· To provide you with certain services in an App or on a Site or information about goods or services we feel may interest you. For example, to contact you with information, newsletters, promotional materials, and contests from FT or on behalf of our business partners, licensees, and affiliates. We may use a pixel tag or other similar technology to collect information about your visits to Sites and Apps, and we may use that information to target advertisements for our products and Services.

· To certain types of cookies (performance cookies, functional cookies and targeting cookies) on your website for marketing purposes;

· To enable, enhance, and develop the facial recognition features of our products or services where you elect to use then (e.g., collection and processing of face scans, voiceprint, or other biometric information for the operation of our services and for developing our product databases);

· To enhance your online experience if you are a user in the EEA, including as a way to recognize you and welcome you to a Site or App, make the account usage and purchasing process faster and smoother and provide you with customized Site or App content, targeted offers, and advertising on Sites, Apps (including geo-targeted advertising), or via email, telephone, text message, or by mail;

· To recognize your online activities over time and across different Services and improve our content, products, and services; and

· For any other purpose where you have provided valid consent where it is legally required.

INFORMATION SHARING

Subject to applicable law and regulations, FT may disclose the personal data we collect from and about you in the following ways:

· With our affiliated companies, installers, retailers and dealers, including subsidiaries of such companies;

· With our third party service providers that provide business, professional or technical support functions for us and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them;

· With our third-party hosting service/s (e.g., cloud providers), which store personal information on our behalf. For example, your personal data, including video and audio data, will be shared with our third-party cloud hosting providers and stored on such providers’ platforms, and such cloud providers may have access to your personal data stored on their platforms.

· With our agents, licensees, and other companies that assist us in providing a product or service to you, including, but not limited to, making your purchase and installation; providing you with customer assistance; processing and/or confirming your transactions; providing you with the services you requested; assessing creditworthiness; billing and collecting any amounts owed in connection with your account or products or services purchased; or recovering any monies due, such as through debt collection agencies;

· With our select licensees, affiliates, retailers and business partners that we believe may have offers of interest to you, including for their own marketing purposes;

· As necessary if we believe that there has been a violation of our terms of use or of our rights or the rights of any third party;

· To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law;

· With authorized users of a connected device, which, depending on their level of permission, may receive your user profile data and have access to device history logs within the App. If you do not wish to share this data with other authorized users, you may decline the invitation you received to use the App;

· As otherwise described to you at the point of collection or with your consent when required by applicable law and regulations;

· With a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by one or more of our entities about our users is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal data provided through the Services in a manner that is consistent with this Privacy Notice.

FT may also share aggregate or anonymous non-personal data about you and other users with third parties for their marketing or analytics uses, without restriction.

CROSS-BORDER TRANSFERS OF PERSONAL DATA

The personal data that we collect from you may be transferred to, and stored at, a destination outside the country in which it is collected. We will take all steps reasonably necessary to ensure that your personal data is treated securely and subject to appropriate safeguards in accordance with this Privacy Notice and applicable laws.

DATA RETENTION

We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.

The criteria used to determine our retention periods include:

· necessity to fulfill our legitimate business purpose;

· prescription by applicable laws, stated in the contract and other legal obligations; and

legal or regulatory obligation or investigation.

Where we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

Non-affiliated third parties are independent from FT and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.

Disclosures of Your Personal Data for a Business Purpose

In the twelve months preceding the effective date of this Privacy Notice, we may have disclosed the following categories of your personal data for a business purpose to the following categories of third parties:

LINKS TO OTHER WEBSITES

The Sites, Apps, and email messages from us may contain links to third-party websites and “apps”, which may have privacy policies that differ from our own. You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the Privacy Notice of the company providing the website and not by this Privacy Notice. FT therefore encourages you to read the privacy statements and terms and conditions of linked or referenced websites and apps you enter. These third-party websites and apps may send their own cookies and other tracking devices to you, log your IP address, and otherwise collect data or solicit personal data. We are not responsible for the practices of such websites or apps.

PUBLIC FORUMS

Any information you may disclose in blogs, on message boards, in chat rooms, or on other public areas on a Site, App, or other third-party website that the Site or App may link to, becomes public information. Please exercise caution when disclosing personal data in these public areas. We reserve the right to remove any posting or content in a posting at our sole discretion.

CHILDREN’S PRIVACY

Protecting children’s privacy is important to us. We do not direct our Sites or Apps to, nor do we knowingly collect any personal data from, children under the age of 13 (or 16 where applicable by law). If we learn that a child has provided personally identifiable information to a Site or App, we will use reasonable efforts to remove such information from the files of such Site or App.

DATA SECURITY

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site and App visitors. While we make every reasonable effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

CONTACT INFORMATION

We hope this Privacy Notice answers your questions about our collection, use and disclosure of your personal data. If you have additional questions about this Privacy Notice or the practices described herein, you may contact us at:

Wuxi Force Technology Co., Ltd.

Building H, Plainvim Industrial Park (No. 30 Wanquan Road), Wuxi, China

+86 510 88796565

info@f-linx.com

REVISIONS TO THIS PRIVACY NOTICE

FT reserves the right, at its sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Notice at any time. If we do, we will make you aware of the change(s) on the Site or App by including a copy to the previous version of the Privacy Notice. The date this Privacy Notice was last revised is identified at the top of the page. Your continued use of the Site or App following the posting of changes to these terms means you accept these changes. If we change this Privacy Notice in a material way, we will provide appropriate notice to you.