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PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

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Effective Date: January 1st, 2020

Last Reviewed on: December 30th, 2019

Lorex Technology Inc. (the "Company," "Lorex," "we" or "us") respects your privacy and is committed to protecting it through our adherence to our Privacy Policy posted on our website (the "Site") at https://www.lorextechnology.com/policies/privacy-policy/R-sc2500030 (the "Privacy Policy") and this Privacy Notice for California Residents.

This Privacy Notice for California Residents supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this notice.

This Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Lorex currently does not have any California-based employees or contractors. California-based job applicants or other individuals who are entitled to the right to notice under CCPA will be provided with methods to exercise their rights.

This Notice does not apply to the personal information reflecting a written or verbal business-to-business communication ("B2B personal information") to the extent that complying with certain requirements of CCPA is temporarily exempted for such information.

All capitalized terms used herein and not otherwise defined in this privacy notice will have the meanings set forth in the Privacy Policy being supplemented.

Information We Collect

Lorex collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, Lorex has collected the following categories of personal information from its consumers within the last twelve (12) months:

  1. Identifiers.
  2. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
  3. Commercial information.
  4. Internet or other similar network activity.
  5. Geolocation data.
  6. Sensory data.
  7. Inferences drawn from other personal information.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Lorex obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you when you provide it to us. For example, information that you provide at the time of registering for use of or access to certain features of the Site, registering for the use of our mobile applications ("Apps"), subscribing to certain services, posting material, or requesting further services.
  • Indirectly from you. For example, when you navigate through the Site or use the Apps, we may collect usage details, device-related information, and IP addresses, by means of cookies, web beacons and other tracking technologies.

Use of Personal Information

We may use, sell, or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, when you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our websites and apps, products, and services.
  • To create, maintain, customize, and secure your account with us. For example, to provide you with notices about your account, your product and service purchases, and/or updates to our terms and policies.
  • To process your requests, purchases, transactions, and payments, and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your experience on our Site or Apps and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Site and Apps, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Site and Apps, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Lorex's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Lorex about our Sites users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose or sell your personal information, subject to your right to opt-out of those sales (see Personal Information Sales Opt-Out and Opt-In). We may disclose personal information that we collect or you provide as described in the Privacy Policy with the following categories of third parties:

  • Our subsidiaries and affiliates to deliver you the Products and Services you order.
  • Our group companies, and other companies to facilitate the provision of Services to you (for more information about our group companies, please visit https://www.lorextechnology.com and click on "About Us")
  • Contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use only for the purposes for which we disclose it to them.
  • A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all the Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about users is among the assets transferred.
  • Courts or law enforcement agencies to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, the Company has disclosed the following categories of personal information for a business purpose:

  1. Identifiers.
  2. California Customer Records personal information categories.
  3. Commercial information.
  4. Internet or other similar network activity.
  5. Geolocation data.
  6. Sensory data.
  7. Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Contractors, service providers, and other third parties we use to support our business and who are bound by the contractual obligations to keep personal information confidential and use if only for the purposes for which we disclose it to them. For example, marketing firm to personalize or improve your experience with our websites and apps, and fraud detection agency to prevent digital payments fraud, new account fraud, and account takeovers, etc.

Sales of Personal Information

Lorex allows certain companies to place tracking technologies like cookies on our sites, which allow those companies to receive information about your activity on our sites that is associated with your browser or device. The companies may use that data to serve you more relevant ads on our sites or others. Under the CCPA, sharing data for online advertising like this may be considered as a "sale" of personal information.

Lorex also discloses your information for a business purpose to contractors, service providers, and other third parties ("Partners") we use to support our business and who are bound by the contractual obligations to keep personal information confidential and use if only for the purposes for which we disclose it to them. (See Disclosures of Personal Information for a Business Purpose). Under the CCPA, sharing information to such Partners may also be considered as a "sale" of personal information.

Lorex does not sell your personal data to, or share it with, such Partners or others for purposes of their own direct marketing or advertising, except with your consent.

Except for the kind of sharing as illustrated above, Lorex doesn't sell any of your information.

You always have full control over whether these technologies work on your devices. You can disable them entirely using our cookie consent preference tools , or by clicking the Do Not Sell My Personal Information link on our website.

In the preceding twelve (12) months, the Company has sold the following categories of personal information:

  1. Identifiers.
  2. California Customer Records personal information categories.
  3. Commercial information.
  4. Internet or other similar network activity.
  5. Geolocation data.
  6. Inferences drawn from other personal information.

We sell your personal information to the following categories of third parties:

  • Data aggregators or companies who place tracking technologies like cookies and pixels on our sites.
  • Contractors, service providers, and other third parties ("Partners") we use to support our business and who are bound by the contractual obligations to keep your personal information confidential and use if only for the purposes for which we disclose it to them.

Video and Audio Data

Our Products and Services allow you to stream, view, or record video (and in some cases audio) data. To provide you with these features, we receive content and related information that are captured and recorded when using our Products and Services. This information includes video (and in some cases audio) recordings, live video (and in some cases audio) streams, images, comments, and data our products collect from their surrounding environment to function effectively (such as motion, events, temperature, window/door sensors, passive infrared sensors, water sensors, CO2 sensors, and ambient light) ("Video and Audio Data"). Lorex stores your Video and Audio Data on AWS S3 (Simple Storage Service), the Video and Audio Data is encrypted with AES256 while being transmitted to the cloud. Lorex does not access the content of your Video and Audio Data nor disclose or sell any of your Video and Audio Data.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Lorex disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting [or selling] that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that Lorex delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion), we will delete and/or direct our service providers to delete your personal information from our records, unless an exception applies. .

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please issue a power of attorney granting the agent the power to submit a consumer request to Lorex on behalf of you, and send a copy of such power of attorney to Lorex via email to privacy@lorextechnology.com.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

In case you are not able to submit a request through your password protected account, Lorex may take the following measures to verify your identity:

  • Requesting you to provide a photo ID.
  • Conducting a telephone interview with you.
  • Requesting you to sign an acknowledgement letter saying that you are the data subject.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the "right to opt-out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link: Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by: Opt-In Instructions

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. We currently provide the following financial incentives:

  • We provide coupon codes and/or discounted products and services to existing or potential customers who sign up our mailing list, you can opt-in the incentive by registering a Lorex account and selecting the checkmark against the "Email me about product updates, sales, special pricing and more" option. Alternatively, you may add your email address using a web form: Subscribe To Lorex Technology
  • We provide price match to all Lorex customers who have placed an order on our website at https://www.lorextechnology.com and lower prices for the items in that order are offered on our website afterwards. Within fifteen (15) days of your purchase, you can opt-in the incentive by calling us at 1-866-467-8688 (enter service code 739 to leave us a message) and requesting a price match.
  • We provide extended warranty for Lorex products to existing or potential customers who purchase directly from our website at https://www.lorextechnology.com and write reviews for our products, you can opt-in the incentive by logging into your Lorex account and creating a product review for an item that you have purchased.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Sites and Apps that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@lorextechnology.com or write us at:

250 Royal Crest Court Markham,
Ontario, L3R 3S1
Canada.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Site or send a reminder through the Apps and update the notice's effective date. Your continued use of the Site or Apps following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Notice, the ways in which we collect and use your information described above and in the Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-866-467-8688 (enter service code 739 to leave us a message)

Email: privacy@lorextechnology.com

Postal Address:
Lorex Technology Inc.
Attn: General Counsel
250 Royal Crest Court
Markham, Ontario, L3R 3S1, Canada