BELKIN PRIVACY POLICY

We at Belkin are committed to protecting your privacy. Our goal is to provide you with a positive experience on our websites and when using our apps, products and services, while at the same time keeping your Personal Information, as defined below, secure. Our privacy practices are described below, as well as in separate notices given when an app, product or service is purchased or downloaded (our "Privacy Policy"). This Privacy Policy covers all Belkin products and Belkin websites. By visiting Belkin websites, using Belkin products or providing us with your Personal Information (as defined below), you are accepting and consenting to the practices, terms and conditions described in this Privacy Policy. This Privacy Policy may be accessed through audio readers.

You will not need to consent to this Privacy Policy, but do acknowledge you have read and understood its terms.

For ease of reference, we will use the following terms in this Privacy Policy:

"Belkin", "our", "us" or "we" means Belkin International, Inc., including its global subsidiaries and affiliated companies (including Linksys and Wemo); "Belkin products" includes all Belkin, Linksys and Wemo branded apps, products and services; and "Belkin websites" include all global Belkin, Linksys and Wemo websites.

If you are in the European Economic Area ("EEA"), for the purposes of the EU General Data Protection Regulation 2016/679 ("GDPR"), the data controller is Belkin Limited of Shipton Way, Express Park, Rushden, Northants, NN10 6GL, UK.

Types of Information Covered by This Privacy Policy

Personal Information. This means any information that (either in isolation or in combination with other information) can be used to identify you directly or indirectly. Some examples of Personal Information include your name, address, email address, phone number, any ID number or location data.

Aggregated Information. Information may be aggregated and/or anonymized. When information is aggregated, it is combined with information about other customers and users. Aggregated information that includes Personal Information is considered Personal Information until it has been anonymized.

Anonymized Information. When information is anonymized, Personal Information is removed from collected data and the remaining portion of the data is repurposed for internal or external use, such as, for example, to determine how many users of a particular router include an Internet-enabled television in a home network environment, or how many users viewed a particular website video or advertisement. Such information cannot be used to identify you. Some examples include usage data relating to Belkin websites and Belkin products, language preferences and Belkin website page views.

In most cases, usage data collected when you visit Belkin websites or use Belkin products is both aggregated and anonymized so it does not identify you personally and therefore is not Personal Information. Certain Belkin products have privacy notices that indicate when usage data contains Personal Information.

Children’s Personal Information. The Belkin websites and Belkin products are not directed to, nor does Belkin knowingly collect Personal Information from children under the age of 16. If we are informed that we have collected the Personal Information of a child under the age of 16, we will delete that Personal Information from our systems. If you believe we might have inadvertently collected Personal Information from or about a child under the age of 16, please contact us here. We also do not sell the information of minors under the age of 16 years of age.

How We Collect Information

We collect and process the following data about you:

Information you give us. If you fill in forms on Belkin websites or correspond with us by phone, email or otherwise, you may be providing us with information about you, which may include Personal Information. This includes information you provide when you register on Belkin websites, register or return a Belkin Product, subscribe to any of our services, search for a product, place an order on Belkin websites, participate in discussion forums or other social media functions on Belkin websites, enter a competition, promotion or survey, participate in a training session or other event, download firmware, software and apps, or when you report a problem with Belkin websites or Belkin products or otherwise request support. Personal Information you give us may include your name, address, email address, phone number and other contact information, financial and credit card information and any other information that can be used to personally identify you.

Information we collect about you. We automatically collect information when you use Belkin websites or Belkin products, including:

• technical information, including the Internet protocol ("IP") address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plugin types and versions, operating system and platform and language preferences. This information is all normally provided by your web browser, and we do not specifically request it;
• information about your visit to Belkin websites, including the full Uniform Resource Locators ("URL") clickstream to, through and from Belkin websites (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; videos watched; page interaction information (such as scrolling, clicks, and mouseovers); and methods used to browse away from the page;
• any phone number or email address used to contact customer support;
• usage data about how and when you use Belkin products, other devices that are connected to Belkin products and what features of Belkin products you use;
• technical information and data gathered when your Belkin products are connected to the Internet, such as how many and which devices are connected to your home network, when you use the devices and the amount of network traffic generated. We also collect environmental data when you use certain Belkin products, such as utility settings, temperature and light readings in the home, motion detection and alarm events; and
• if you consent, certain apps collect information about your location. If you do not want this information collected, do not consent, or consult your device manual for instructions on how to change location settings.

Information we receive from other sources We work closely with third parties who provide services to us (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and we may receive information about you from them.

How We Use Information

We use the information we collect for a number of purposes. These purposes will be consistent with the reason you provided the information to us or for a directly related purpose. The uses we make of such information are to:

• set up an account for you on Belkin websites or Belkin products;
• facilitate your purchase and/or download of Belkin products;
• authenticate use of your account or purchases and/or use of a Belkin Product;
• register your Belkin Product in our product database;
• carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• assist you with customer support;
• communicate about and administer participation in customer promotions and surveys;
• provide the Belkin products you request;
• provide you with information about the Belkin products you use, such as new features, bug fixes, service downtimes or upgrades;
• help us develop new Belkin products and improve current Belkin products;
• provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We (or selected third parties) will contact you by electronic means only if you have optedin to receive marketing information. "Opt-in" means that you have taken an affirmative action to receive information, such as by checking a box or clicking a button;
• notify you about changes to Belkin websites and Belkin products and changes to our terms, conditions and policies;
• administer Belkin websites and Belkin products for internal operational purposes, including troubleshooting, data and statistical analysis, testing, research and survey purposes;
• improve Belkin websites and Belkin products and to ensure that content is presented in the most effective manner for you and for your computer or device;
• ensure the security of Belkin websites and Belkin products;
• monitor and regulate interactive features of Belkin websites and Belkin products that you choose to participate in, including online forums and chat rooms relating to Belkin products;
• help you navigate Belkin websites;
• help you access and use certain features of Belkin products remotely and to help you monitor and safeguard your home and home network;
• provide you with information and recommendations about Internet and utility usage in your home;
• measure or understand the effectiveness of advertising we serve to you and others who visit Belkin websites and to deliver relevant personalized advertising to you and others; and
• determine which aspects of Belkin websites and Belkin products are most useful to you and other users of Belkin websites and Belkin products.

Why We Use Information

Where we process your Personal Information to provide a product or service, we do so because it is necessary to perform contractual obligations that we owe to you and for our legitimate interests to provide products and services, to maintain our relationship with you and to protect our business. If you choose not to provide us with the Personal Information we need to provide you with a product or service, we will not be able to provide it. When you purchase and/or download new Belkin products, we will only use your Personal Information for the purposes set out in this Privacy Policy, and any notification provided to you at the time of purchase or download.

We also use your Personal Information to protect our business (for example, against fraud), or to comply with legal requirements to which we are subject (for example, tax or financial reporting requirements).

We will always seek your consent before we send you any direct marketing communications.

Sharing Information

Under no circumstances do we rent or sell your Personal Information. We will only share your Personal Information with third parties for marketing purposes if you have granted us permission to do so, and in accordance with the Marketing section below. We share Personal Information in the following ways:

• within Belkin for purposes of data processing or storage;
• within Belkin's corporate group, including with our subsidiaries, affiliated companies and divisions, all of whom may use your information for the purposes disclosed in this Privacy Policy;
• with business partners, service vendors, authorized thirdparty agents or contractors to provide a requested service or transaction, including processing orders, hosting websites, storing your information, providing email communications on our behalf and providing customer support. For example, when making purchases on the Belkin website stores, Belkin uses a payment processor to verify your payment card information. Your payment card information is passed through to the payment processor and is not collected or stored by Belkin. The payment processor is authorized to use this information only to authenticate your purchase and for no other purpose. We only provide these third parties with the minimum amount of Personal Information necessary to complete or provide the requested service or transaction, and we do not allow third parties to use your Personal Information for a different purpose than what was disclosed to you;
• with service providers, advisors or other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of our assets. If Belkin merges with or acquires or is acquired by another entity, Personal Information would be transferred as a whole to the successor entity;
• to comply with the law or legal process (such as responding to subpoenas or court orders), to comply with government reporting obligations and to exercise our legal rights or defend against legal claims; and
• to protect our legal rights or those of others, such as protecting the Belkin brand or investigating violations of Belkin terms of use, violations of law, intellectual property infringement, misuse of Belkin websites, fraud or potential threats to personal safety.

In addition, we share aggregated anonymized information, including usage data about Belkin products, with third parties for a variety of purposes, including to analyze trends about home networking and utility use, to show third parties how their products could work with Belkin products and to generally improve home networking. We've taken steps to ensure that this information cannot be linked back to you and we require third parties to keep all shared information in its anonymized form.

For certain Wemo and Linksys products, Belkin may provide the opportunity for you to connect and interface Belkin products with one or more third party products and services, which will involve the exchange of information from your Belkin Product with the third party product or service. Your explicit consent and authorization will be required at the time of connection to the third party product or service, and will be revocable by you at any time by sending us a request here. In some cases, if you purchase, use or download a third party product or service that connects to a Belkin product, you will also be subject to such third party's privacy policy. Belkin is not responsible for the privacy practices of such third party partners. If you access a Belkin product through a third party product in this manner, you agree to the privacy policy of such third party. We encourage you to carefully read the privacy policies and terms of use of any third party products that connect to Belkin products.

Any third parties with whom we share your Personal Information are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. We will take all reasonable steps to make sure these third parties comply with the same privacy principles that govern our collection of your Personal Information.

We will ask for your consent, such as by email response, opt-in box or click through agreement acceptance, before we use or share your Personal Information for any other purpose

Marketing

You have the right to ask us not to process your Personal Information for marketing purposes. We will inform you (before collecting your Personal Information) if we intend to use your Personal Information for marketing purposes, or if we intend to disclose your Personal Information to any third party for marketing purposes.

We will give you choices about your Personal Information. Some choices are presented up front in the form of opt-in notices or acceptance boxes for marketing to you or sharing your Personal Information with third parties. You always have the choice to opt-out if you later change your mind. One form of opt-out is clicking the Unsubscribe link in a marketing email. This will take you off our marketing email list. Please note that these opt-in/opt-out choices do not apply to the receipt of mandatory website, service or software communications, such as update or downtime information, or receipt of order or shipping confirmations on Belkin website stores, which you may receive periodically as part of Belkin performing its contract with you, unless you cancel your service or order or terminate use of software in accordance with the applicable terms of use or license agreement.

If you do not wish to receive direct marketing material from us or a third party, in addition to following the "Unsubscribe" instructions in a marketing email, you can send us a request here.

Where We Store Your Information

The data that we collect from you may be transferred to, and stored at, various locations globally, including the United States. It may also be processed by Belkin staff or contractors operating outside your country of residence (including, if you are in Europe, outside of the EEA, or, if you are in Australia or New Zealand (“ANZ”), outside of ANZ) who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We also use cloud-based applications and services to store and process your Personal Information, which may result in your Personal Information being stored outside your country of residence (or the EEA or ANZ).

We will take such steps as are reasonable to make sure we and our service providers do not breach the privacy principles that govern our collection of your Personal Information and that your Personal Information is treated securely and in accordance with this privacy policy as well as applicable data protection laws. By providing your Personal Information to us, you fully understand that Belkin will transfer, process and store your Personal Information outside of your country of residence where data protection standards may be different, and disclose your Personal Information to overseas service providers who may not fully comply with the particular laws of your country.

Our Privacy Policy and our practices are designed to provide a globally consistent level of protection for Personal Information all over the world. This means that even in countries whose laws provide for less protection for your information, Belkin will still handle your information in the manner described in this Privacy Policy and in conformity with all applicable laws. This includes, where relevant, entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA (available here).

Accessing and Updating Your Personal Information

We need your help in keeping your Personal Information accurate and up to date, so please notify us of any changes to your Personal Information. You can access and update your Personal Information and communication preferences at any time in the following ways:

• by clicking the "Unsubscribe" link in any email you receive from us;
• by sending a request to us here. Please be sure to include your name, email address and specific relevant information about the information you would like to change or the material that you no longer wish to receive; or
• for many Belkin websites and Belkin products, by signing into your online account located at the URL provided when you signed up for the Belkin website or service.

You have a number of rights in relation to your personal data. These can differ by country and jurisdiction. You may have the following rights:

• correct your data if it is inaccurate or incomplete;
• transfer Personal Information you have provided to us to a third party if we are processing that data on either on the basis of your consent or to perform a contract with you;
• delete your Personal Information, unless we are required to retain it by law, or to establish, exercise or defend legal claims, or for another one of our business purposes; and/or
• provide you with a copy of your Personal Information held on our current records. If you are outside the EEA or California, we may make a reasonable charge if records must be accessed from backed up or archived records. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.

If you are resident in the EEA, you also have the right to:

• withdraw your consent to our processing of your Personal Information at any time after you have consented, including optingout of receiving marketing materials. The easiest way to do this is by clicking the "Unsubscribe" link in any email you receive from us;
• restrict our processing of your Personal Information where you believe such data to be inaccurate, our processing is unlawful, or that we no longer need to process such data for a particular purpose (unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it); and/or
• object to such processing on grounds relating to your particular situation, where the legal justification for our processing of your Personal Information is our legitimate interest. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise or defend legal claims.

You can make a request to exercise any of these rights in relation to your Personal Information by sending the request to us here or calling us at 877-460-2323.

We will respond to your request promptly upon receipt. If you are in the EEA, this will be within one month of receipt, or, if further time is required, we will inform you of this and the reason for the delay. We may ask you to verify your identity before we can act on your request. We may conduct an identity verification by phone call or email. Depending on your request, we may ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity.

If your Personal Information has been disclosed to a third party in accordance with this Privacy Policy, we will take reasonable steps to notify the third party of any updated information you provide to us.

If you are in the EEA, you also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws. Please click here for a list of contact details for the EEA data protection authorities.

Authorized Agent

You may use an authorized agent to submit a request to access your information, delete your information, or opt out of the sale of your information. To designate an agent for these purposes:

• You must provide us with a copy of a written and signed permission given to your authorized agent; and
• You must verify your own identity directly with us.

Information for California Residents.

California Civil Code Sections 1798.115(c), 1798.130(a)(5)(c), 1798.130(c), and 1798.140 indicate that organizations should disclose whether certain categories of information are collected, “sold” or transferred for an organization’s “business purpose” (as those terms are defined under California law). You can find a list of the categories of information that we collect and share here. Please note that because this list is comprehensive it may refer to types of information that we share about people other than yourself. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing please submit a written request to us using the information in the "Contact Information" section below. We do not discriminate against California residents who exercise any of their rights described in this Privacy Policy.

Retention of Personal Information

We will only retain your Personal Information to fulfill the purposes for which it was collected, as required for legitimate business purposes as described in this Privacy Policy, or otherwise permitted by law. When we no longer need to use Personal Information, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

Cookies, Web Beacons and Other Web Tools

To learn more about how we use cookies, web beacons and other web tools, and how to control which cookies, web beacons and other web tools are used, please see our Cookie Policy.

Security

We strive to maintain appropriate administrative, technical and physical safeguards designed to protect the information collected by Belkin websites and Belkin products. Unfortunately, the transmission of information via the Internet is not 100% secure. In the event that we are required by law to inform you of a breach to your personal information, we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

It is important to note that if you use a computer or device that can be accessed by others, other people may be able to access unencrypted Personal Information. If you do not want your information to be available to others, exercise caution when using public computers or devices or when using any computer or device to which users unauthorized by you may have access.

We recommend that you take every precaution in protecting your Personal Information when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. You should also be aware that names that you give your Wi-Fi-enabled devices, home networks and services (also known as "friendly names") may be detectable by others outside your home, so you should not use Personal Information as part of your friendly names.

Updates and Upgrades

Belkin products may be updated or upgraded from time to time to provide additional features, address technical issues, and generally make your user experience better. Some Belkin products include an auto-update feature, which gives us the ability to make updates automatically. You can change auto-update options by changing your settings within the Belkin Product account information. In very limited cases, updates may still be automatically applied, regardless of the auto-update setting. For example, we may provide an automatic update that prevents or fixes a security vulnerability or breach to your network.

Third Party and Social Media Linked Sites

Belkin websites and online services may contain links to websites or online services operated by third parties. Belkin products may also use or offer products and services from third parties, such as a third party app that works with a Belkin Product. Once you leave Belkin websites and Belkin products, your activities are governed by the terms of use and privacy policies of the third party websites and online services. Belkin is not responsible for the privacy practices or the content of these websites and online services, and we encourage you to carefully read the terms of use and privacy policies of any website and online service you visit.

Belkin websites and Belkin products may contain social media features, such as Facebook "Like" buttons. These features may collect information about your device's IP address, set cookies to facilitate interaction with social media features or link you to a social media website where you may post Personal Information. All interactions with social media features are governed by the privacy policy of the social media company providing the feature.

Forums/Chat Rooms

If you participate in or post information to a discussion forum or chat room on any Belkin website or Belkin Product, you should be aware that the information you provide there will be made broadly available to others, and can be read, collected, forwarded or used by other users of these forums, potentially inside or outside Belkin, who have access to that forum. This information could also be used to send you unsolicited messages. Please recognize that individual forums may have additional rules and conditions. Each participant's opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Belkin. We are not responsible for Personal Information or any other information you may choose to submit in these forums, or the consequences of any submission. If at any time you would like to remove a posting, please contact us here. Keep in mind that removal of a posting from a forum or chat room does not mean that the posting will be deleted from our systems, or that it has been completely removed from the Internet.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time, so please review it frequently. If we change our Privacy Policy, we will post the revised version here, with an updated revision date. If we make material changes to our Privacy Policy, we will notify you by email or prominently post a notice on this website.

How to Contact Us

Should you have any privacy-related questions or comments related to this Privacy Policy, please contact us here or, if you are in California, by phone at 877-460-2323.

If you have complaints or concerns about this Privacy Policy, please contact us at the above email. We treat all complaints about a breach of the privacy laws seriously. Someone from Belkin will investigate your complaint and respond to you within a reasonable time.

Updated Effective January 1, 2020