Privacy Policy

Privacy Notice
Last updated: March 25, 2019

Sutro Connect ("us", "we", or "our") operates the https://www.mysutro.com website and the MySutro mobile app that use proprietary artificial intelligence algorithms to analyze information about your swimming pool and preferences for treating it to make recommendations of products to use to treat your pool to attain better results (the "Service(s)").

This privacy notice informs you of how we collect, use and disclose personal information when you use our Services and of your rights and choices in connection with this. [Please see our Terms of Use [link] for other terms governing the use of our Services.]

[Recommend to put a summary and hyperlinked TOC here / layer the presentation]

Information we collect

Information you provide to us: Through your use of the Service, we collect personal information, which is information that identifies you as an individual or relates to you as an identifiable individual.

We collect information from you when you:

Open an account:
In order to use the Service as our customer, you would need to provide account information when signing up either on the website or on the mobile app. That includes contact information, such as your first and last name, e-mail address, telephone number, and payment information, such as your credit or debit card information. We use Stripe, a third party provider to process the credit card information and only retain the last four digits of the card as well as the card brand.  

We need this information in order to provide you with the Service. If you do not provide us with contact information we would not be able to send you the informational messages that are part of our Services. If you do not provide us with payment information, you would not be able to order products through our Service.

Use our Service: To use our Service you would need to provide us with details about the products you use to service your pool and other information about your pool such as: the size of the pool, whether your pool is saltwater, type of chemicals currently used, pH and chlorine levels, pool chemistry test readings, etc. You can provide this information to us yourself through the app. If you use our Sutro device, we will collect this information directly from your device.  If you do not provide us with this information, we would not be able to provide you with recommendations regarding the chemicals to use in your pool.

You can choose to provide us with additional information such as your preferences regarding which chemicals to use (brand, generic), what is the primary or secondary sanitizer you use and other information. If choose not to provide us with this information, we would not be able to provide you with tailored recommendations and our recommendations to you would be generic recommendations based on an average pool.

Interact with our Website or make recommendations: When you engage with us on our various social media platforms, or send us any feedback, questions, comments, suggestions, ideas, or interact with us in any way, you provide us with personal information such as your name and email address or social media handle.

Please note that information you provide to us through feedback, surveys, suggestions etc., without the parts that identify you, will be treated as non-confidential and non-proprietary and we may use it and share it with third parties.

Information collected automatically: We automatically collect the following types of information when you browse our website and use our Services:

Usage Information: Which of the pages on our website you access, the frequency of access, how much time you spend on each page, what you click on while on our website, when you accessed the website.

Referral status: Whether you were referred to our Service by one of our business partners.
Location Information: information about your estimated location as may be determined from the IP Address.

Device Information: Information about the mobile device you are using, such as hardware model, operating system, application version number, browser, and IP addresses.

Firebase token:

Pool Stats: If you use the Sutro device, data regarding pool chemistry are collected three times per day [how are these collected if the person doesn’t have the device?]

Cookies and other technologies. Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser. Cookies can be "persistent" or "session" cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser. We use first party cookies, which are cookies that we place on your device ourselves, and third party cookies, which are cookies that we allow third parties to place on your device.

How we use cookies. When you use and access the Services, we may place a number of cookie files in your web browser.

We use both session and persistent cookies on the Service and we use the following types of cookies. To learn how you can control information collected about you using cookies and other technologies see here.
Essential cookies. We use essential cookies to authenticate users (both our customers and our customers' end-users) and prevent fraudulent use of user accounts.

Preferences cookies. We use preferences cookies to remember information that changes the way the Service behaves or looks, such as the "remember me" functionality of a registered user or a user's language preference.

Analytics cookies. We use analytics cookies to track information how the Service is used so that we can make improvements. We also use analytics cookies to test pages, features or new functionality of the Service to see how our users react to them.

Referral cookie: we allow our business providers to place a cookie on your device that allows us to see whether they had referred you to us and share this information with Stripe, our third party payment processor.

Cookies placed by third parties:

Analytics:
We use “Google Analytics” and Autopilot to collect some information we listed above about your use of the Services. We use the information we get from these providers to improve the Services. In order to collect this information, Google Analytics  and Autopilot set cookies on your browser or mobile device, or read cookies that are already there. They may also receive information about you from apps you have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Click “Your Choices With respect to Your Information” to learn about how to control information used by Google analytics or Autopilot.
The third party analytics products we use collect only anonymized IP addresses for IP's located in the European Union ("EU").

How we Use Your Information
We use the information we collect about you to provide the Service, to communicate with you, to provide technical support, and to improve our Services and customer relations.  

We process your information for the following purposes as necessary to provide the Services to you and perform our contract with you:

Provide Services: We use your personal information to provide the Services. This includes analyzing your usage preferences, the products you use and the information you provide about your pool to send you recommendations regarding products to purchase on the website or through the app.
Communicate and provide technical support: We use personal information to communicate with you about the Services, to send you account updates or other communications regarding your account, report bugs, or to inform you of any changes to our website or Services, and to provide you support or other Services you request.  For example, we may need your information to provide technical support or answer questions about the Service.

Communicate about new features: We send you notifications about new features or information available on our Services or that we feel might be of interest to you. Email hello@mysutro.com to learn how you can opt out of receiving these communications at any time.

Maintenance and Improvement of our Services: We use personal information collected automatically through cookies, as described above to: (i) identify your interests and needs in order to provide you with more personalized and relevant content; (ii) diagnose any problems with our website and to improve the user experience; (iii) train and improve our proprietary algorithms. Any information retained for (iii) is retained in a de-identified manner.

Benchmarking: We aggregate personal information for the purpose of research and benchmarking. For example, to calculate the percentage of users in a particular ZIP code. This information is retained in a de-identified manner.

Defend our rights and those of others, to efficiently maintain our business and to comply with the law.

In our processing of your information, we also share your personal information to defend our rights and those of others, to efficiently maintain our business and to comply with the law as described in [how we share your information – click to next paragraph].

How we share your information

We share your information with certain third parties, including our service providers that facilitate our Service, and as necessary to comply with our legal obligations.

Service Providers: We share information with service providers that help us maintain and operate our Website and mobile app and to provide the Services, including data storage, email services, and content management.
Payment processing: We use Stripe to process payment card information. A link to Stripe’s privacy notice is here https://stripe.com/us/privacy

Analytics: We use Google Analytics and Autopilot to conduct data analytics on usage of our Services. A link to the Google privacy notice is https://policies.google.com/privacy and a link to the Autopilot privacy notice is https://www.autopilothq.com/legal/privacy-policy We use Twilio to facilitate sending text messages for the provision of the Services. A link to the Twilio privacy notice is https://www.twilio.com/legal/privacy
We use DialogFlow to conduct natural language processing on information received from users in order to provide the services. A link to the Google privacy notice is https://policies.google.com/privacy
Sale fulfillment: If you choose to buy products we recommend through our Services, you will be directed to a page where your purchase will be facilitated by Amazon. The sale will be governed by Amazon’s terms and privacy notice which can be found here https://www.amazon.com/gp/help/customer/display.html?nodeId=468496.

Corporate Structure: In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.To Prevent Harm: We will share information if we believe it is necessary to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person.

Legal Purposes: We will share information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights or contractual obligations; to defend against legal claims or demands; or to comply with the requirements of any applicable law.With Your Consent: Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose.  You may revoke your consent at any time.

Security
We implement and maintain reasonable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure. We have implemented various policies including, encryption, firewall management, access limitation, and authentication to guard against unauthorized access to personal data in our systems. We transmit all personal information in SSL.

Please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.

Users outside the US
We currently only serve customers in the United States or in Canada.

Your choices with respect to your information

Access, correct or delete your information: You may access your account (on the website or through the mobile app) to access, correct or delete the information you provided to us and which is associated with your account by logging into your account or by emailing us at hello@mysutro.com . Your request should contain a detailed, accurate description of the data you want access to. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file.

In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.
We will retain your information after your account is deleted under the circumstances described in "How Long We Keep Your Information?"

Delete your account: You may request that we delete your account by contacting us at hello@mysutro.com . If you choose to delete your account, we will begin the process of deleting your account from our systems. We will retain your information after your account is deleted under the circumstances described in "How Long We Keep Your Information?"

Emails: You can opt out of receiving promotional e-mails from us by clicking the “unsubscribe” link provided in each e-mail or by contacting us at hello@mysutro.com .  We will continue to send you notifications necessary for the Services related to this e-mail address.  

All cookies: You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help feature on most browsers provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

- For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
- For the Internet Explorer web browser, please visit this page from Microsoft: https://support.microsoft.com/kb/278835
- For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
- For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
For any other web browser, please visit your web browser's official web pages.

Google Analytics:  See https://policies.google.com/technologies/partner-sites for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here https://tools.google.com/dlpage/gaoptout.


How Long We Keep Your Information

You can delete your account or request that we delete your account by writing us at hello@mysutro.com. We will retain your information until you delete your account as stated above. We retain your information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirementsTo read more about specific reasons we would retain some data for longer periods of time click here:Security, fraud & abuse prevention – i.e. to protect you, other people, and us from fraud, abuse, and unauthorized access.

Financial record-keeping - when you make a payment to us we are often required to retain this information for a longer period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations

Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations

Direct communications with us - if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications. Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. For any privacy or data-protection-related questions, please write to hello@mysutro.com.

Do Not Track Disclosure
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. For further details, visit https://www.eff.org/issues/do-not-track.

Links To Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third party sites or Services.

Children's Privacy
This website and our Services are not intended for individuals under the age of eighteen (18) years. Accordingly, we do not knowingly collect or share information from children without parental or guardian consent. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us using the information below, and we will delete that information from our databases.

Changes To This Privacy Notice
We may change this Privacy Notice from time to time. We will post the changes to this page, and will indicate the date they go into effect. We encourage you to review our Privacy Notice to stay informed.  If we make changes that materially affect your privacy rights we will notify you of the changes by posting a prominent notice on our website or using other methods that we select, such as sending you an email.

Contact Us
If you have any questions or concerns about this Privacy Notice or how we treat your information, please contact us: hello@mysutro.com.
Phone: 415.299.8082.
Address: 181 2nd Street. San Francisco, California 94105

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