Privacy Policy

Policy objectives

This Privacy Policy Statement (the “Privacy Policy”) contains the policies, procedures and practices followed by Eddy Solutions, subsidiaries, and affiliates (collectively “Eddy”) pertaining to the collection, use and disclosure of personal information (the “Personal Information”) of an identifiable person (the “Individual”) that is apresent, future or former customer of Eddy.

Why we collect personal information

Eddy collects data from you, through our interactions with you and through our products for a variety of purposes described below, including to operate effectively and provide you with the best experiences with our products. You provide some of this data directly, such as when you apply for a service agreement with Eddy, administer your Eddy Solutions account (myeddyhome.com), or contact us for support. We get some of it by collecting data about your interactions, use and experience with our products and communications.

We rely on a variety of legal reasons and permissions (“legal bases”) to process data, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts and compliance with legal obligations, for a variety of purposes described below.
We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time and include:

• Data brokers from which we purchase demographic data to supplement the data we collect.
• Communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks.
• Partners with which we offer co-branded services or engage in joint marketing activities.
• Developers who create experiences for Eddy products, such as MyEddyHome for Android and iOS devices.
• Publicly available sources, such as open government databases.
• Credit Reporting Agencies when you give us permission to carry out credit background check.

If you represent an organisation, such as a business, condominium corporation, educational institution, property developer, or utility companies, that utilises business services from Eddy, please see the Business Products sectionof this privacy statement to learn how we process your data.
You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data, you can decline. Many of our products require some personal data to operate and provide you with a service. If you choose not to provide data necessary to operate and provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you’re using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalisation that use the data will not work for you.

What personal information do we collect

The data we collect depends on the context of your interactions with Eddy and the choices you make (including your privacy settings), the products and features you use, your location and applicable law.

The data we collect can include the following:

Name and contact data. Your first and surname, email address, postal address, phone number and other similar contact data.

Credentials. Passwords, password hints and similar security information used for authentication and account access.

Demographic data. Data about you such as number of people under and above 18 years of age living at your home, whether you are a senior citizen, country and preferred language.

Payment data. Data to process payments, such as your payment instrument number (such as a credit card number, utility account number, or bank account information) and the security code associated with your payment instrument.

Subscription and licensing data. Information about your subscriptions, licences and other entitlements.

Interactions. Data about your use of Eddy products. In some cases, such as water billing period, this is data you provide in order to make use of the products. In other cases, such as alert reports, this is data we generate. Other examples of interactions data include:

• Device and usage data. Data about your device and the product and features you use, including information about your hardware and software, how our products perform, as well as your settings. For example:
  • Payment and account history. Data about the items you purchase and activities associated with your account.
  • Browse history. Data about the webpages you visit.
  • Device, connectivity and configuration data. Data about your device, your device configuration and nearby networks. In addition, IP address, device identifiers (such as the IMEI number for phones), regional and language settings and information about WLAN access points near your device.
  • Error reports and performance data. Data about the performance of the products and any problems you experience, including error reports. Error reports (sometimes called “crash dumps”) can include details of the software or hardware related to an error, contents of files opened when an error occurred and data about other software on your device.
  • Troubleshooting and help data. Data you provide when you contact Eddy for help, such as the products you use, and other details that help us provide support. For example, contact or authentication data, the content of your chats and other communications with Eddy, data about the condition of your device and the products you use related to your help enquiry. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.
• Preferences and Patterns of Water Usage, Water Pressure, Temperature, and Humidity. Data about your preference and patterns of water usage, water pressure, temperature, and humidity, such as time of day when high or low usage. In addition to those you explicitly provide, your preferences and patterns can also be inferred or derived from other data we collect.
• Images. Images and related information, such as picture metadata when submitted to Eddy.
• Social data. Information about your relationships and interactions between you, other people and organisations, such as types of engagement (e.g. likes, dislikes, events, etc.) related to people and organisations.
• Location data. Data about your device’s location, which can be either precise or imprecise. For example, Location can be inferred from a device’s IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postcode level.

Other input. Other inputs provided when you use our products. For example, data such as the snoozing of a water usage related alert when using MyEddyHome app, temperature, and humidity tracking data when you use devices that have applicable sensors. we also collect financial transaction data from your credit card issuer if applicable to provide the service.

Video or recordings. Recordings of events and activities at Eddy buildings, retail spaces and other locations. If you enter Eddy locations or other facilities, or attend an Eddy event that is recorded, we may process your image and voice data.

Feedback and ratings. Information you provide to us and the content of messages you send to us, such as feedback, survey data and product reviews you write.

How we use personal data

Eddy uses the data we collect to provide you rich, interactive experiences. In particular, we use data to:

• Provide our products, which includes updating, securing and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the service or carry out the transactions you request.
• Improve and develop our products.
• Personalise our products and make recommendations.

Advertise and market to you within the guidelines of Canada’s Anti-Spam Legislation, which includes sending promotional communications, targeting advertising and presenting you relevant offers.

We also use the data to operate our business, which includes analysing our performance, meeting our legal obligations, developing our workforce and doing research.

For these purposes, we combine data we collect from different contexts (for example, from your use of Eddy products). For example, Eddy uses the telemetry from Eddy H20 sensors to control automated shutoff of your water supply at the Eddy IQ Meter provided you have requested such configuration. However, we have built in technological and procedural safeguards designed to prevent certain data combinations where required by law. For example, where required by law, we store data we collect from you when you are unauthenticated (not signed in) separately from any account information that directly identifies you, such as your name, email address or phone number.

When we process personal data about you, we do so with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests of Eddy as described in this section and in the Reasons we share personal data section of this privacy statement. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in the Where we store and process personal data section of this privacy statement.

More on the purposes of processing:

• Provide our products. We use data to operate our products and provide you with rich, interactive experiences. For example, if Eddy products detect unusual water usage events they generate automated notificationswith the location of the device that triggered it. Additionally, as communications are a feature of various products, programmes and activities, we use data to contact you. For example, we may contact you by phone or email or other means to inform you when a subscription is ending or discuss your licensing account. We also communicate with you to secure our products, for example by letting you know when product updates are available.
• Product improvement. We use data to continually improve our products, including adding new features or capabilities. For example, we use error reports to improve security features, and usage data to determine what new features to prioritise.
• Personalisation. Many products include personalised features, such as customized water usage profiles that enhance accuracy of water related events. These features use automated processes to tailor your product experiences based on the data we have about you, such as inferences we make about you and your use of the product, activities, and location. For example, depending on your settings, our products may be configured to use more strict usage patterns when triggering water related events if you are on vacation. Many of our products provide controls to disable personalised features.
• Product activation. We use data – such as device and application type, location and unique device, application, network and subscription identifiers – to activate products that require activation.
• Product development. We use data to develop new products. For example, we use data, often de-identified, to better understand our customers’ water usage patterns which can shape the development of new products.
• Customer support. We use data to troubleshoot and diagnose product problems, repair customers’ devices and provide other customer care and support services.
• Help secure and troubleshoot. We use data to help secure and troubleshoot our products. This includes using data to protect the security and safety of our products and customers, troubleshooting performance and compatibility issues to help customers get the most out of their experiences, and notifying customers of updates to our products. This may include using automated systems to detect security and safety issues.
• Safety. We use data to protect the safety of our products and our customers.
• Updates. We use data we collect to develop product updates and security patches. For example, we may use information about your device’s capabilities, such as available memory, to provide you a software update or security patch. Updates and patches are intended to maximise your experience with our products, help you protect the privacy and security of your data, provide new features and ensure that your device is ready to process such updates.
• Promotional communications. We use data we collect to deliver promotional communications. From your MyEddyHome App you can choose whether you wish to receive promotional communications from Eddy by email, SMS, physical mail and telephone. For information about managing your contact data, email subscriptions, and promotional communications, see the How to access and control your personal data section of this privacy statement.
• Relevant offers. Eddy uses data to provide you with relevant and valuable information regarding our products. We analyse data from a variety of sources to predict the information that will be most interesting and relevant to you and deliver such information to you in a variety of ways. For example, we may predict your interest in conservation of water and communicate with you about conservation options you may like.
• Advertising. Eddy does not use what you say in email, chat, video calls or voicemail, or your documents, photos or other personal files to target ads to you. We use data we collect through our interactions with you, through some of our products, and on third-party web properties, for advertising in our products and on third-party properties. We may use automated processes to help make advertising more relevant to you. For more information about how your data is used for advertising, see the Advertising section of this privacy statement.
• Transacting commerce. We use data to carry out your transactions with us. For example, we process payment information to provide customers with product subscriptions and use contact information to deliver goods purchased from the Eddy.
• Reporting and business operations. We use data to analyse our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
• Protecting rights and property. We use data to detect and prevent fraud, resolve disputes, enforce agreements and protect our property. For example, we use data to confirm the validity of software licences. We may use automated processes to detect and prevent activities that violate our rights and the rights of others, such as fraud.
• Legal compliance. We process data to comply with law. For example, we use the age of our customers to ensure we meet our obligations to protect children’s privacy. We also process contact information and credentials to help customers exercise their data protection rights.
• Research. With appropriate technical and organisational measures to safeguard individuals’ rights and freedoms, we use data to conduct research, including for public interest and scientific purposes.

Reasons we share personal data

We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorised. For example, we share your content with third parties when you tell us to do so, such as when you authorize your insurance company to access water usage telemetry to participate in discount programs. If you use anEddy product provided by an organisation you are affiliated with, such as an employer or school, we share certain data, such as interaction data and diagnostic data to enable your organisation to manage the products. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

In addition, we share personal data among Eddy-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this statement. For example, companies we’ve hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets.

Finally, we will retain, access, transfer, disclose and preserve personal data, including product telemetry (such as water usage, pressure, temperature, and humidity readings), when we have a good faith belief that doing so is necessary to do any of the following:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
• Protect our customers, or to help prevent the loss of life or serious injury of anyone.
• Operate and maintain the security of our products, including to prevent or stop an attack on our computer systems or networks.
• Protect the rights or property of Eddy, including enforcing the terms governing the use of the services – however, if we receive information indicating that someone is using our services to traffic in stolen intellectual or physical property of Eddy, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.

Please note that some of our products include links to products of third parties whose privacy practices differ from those of Eddy. If you provide personal data to any of those products, your data is governed by their privacy policies.

Access or corrections to personal information

You can access and control your personal data that Eddy has obtained with tools Eddy provides to you, which are described below, or by contacting Eddy. For instance:

• If Eddy obtained your consent to use your personal data, you can withdraw that consent at any time.
• You can request access to, erasure of and updates to your personal data.

You can also object to or restrict the use of your personal data by Eddy. For example, you can object at any time to our use of your personal data:

• For direct marketing purposes.
• Where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.

You may have these rights under applicable laws, including the EU General Data Protection Regulation (GDPR), but we offer them regardless of your location. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.

If your organisation, such as your employer, educational institution or service provider, provides you with access to and is administering your use of Eddy products, contact your organisation to learn more about how to access and control your personal data.

You can access and control your personal data that Eddy has obtained, and exercise your data protection rights, using various tools we provide. The tools most useful to you will depend on our interactions with you and your use of our products. Here is a general list of tools we provide to help you control your personal data; specific products may provide additional controls.

• MyEddyHome.com. If you wish to access and edit the profile information in your Eddy account, change your password, add security information, you can do so by visiting the Eddy account profile page.

Customer Service Department. You can also reach our representatives at 1.877.388.3339 to submit your request or updates

Not all personal data processed by Eddy can be accessed or controlled via the tools above. If you want to access or control personal data processed by Eddy that is not available via the tools above or directly through the Eddy products you use, you can always contact Eddy at the address in the How to contact us section or by using our web form. We will respond to requests to control your personal data within 30 days.

Your communications preferences

You can choose whether you wish to receive promotional communications from Eddy by email, SMS, postal mail and telephone. If you receive promotional email or SMS messages from us and would like to opt out, you can do so by following the directions in those messages. You can also make choices about the receipt of promotional email, telephone calls and post/mail by signing in with your personal Eddyaccount, and viewing your communication permissions where you can update contact information, manage Eddy-wide contact preferences, opt out of email subscriptions and choose whether to share your contact information with Eddy partners. These choices do not apply to mandatory service communications that are part of certain Eddy products, programs, activities or to surveys or other informational communications that have their own unsubscribe method.

Browser-based controls

When you use a browser, you can control your personal data using certain features. For example:

• Cookie Controls. You can control the data stored by cookies and withdraw consent to cookies by using the browser-based cookie controls.
• Tracking protection. You can control the data third-party sites can collect about you using Tracking Protection in Internet Explorer (versions 9 and up). This feature will block third-party content, including cookies, from any site that is listed in a Tracking Protection List you add.
• Browser controls for “Do Not Track”. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites that you visit indicating that you do not wish to be tracked.

Cookies and similar technologies

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie. This data often consists of a string of numbers and letters that uniquely identifies your computer, but it can contain other information as well. Some cookies are placed by third parties acting on our behalf. We use cookies and similar technologies to store and honour your preferences and settings, enable you to sign-in, provide interest-based advertising, combat fraud, analyse how our products perform and fulfil other legitimate purposes described below.

Our use of cookies and similar technologies

Eddy uses cookies and similar technologies for several purposes, depending on the context or product, including:

• Storing your preferences and settings. We use cookies to store your preferences and settings on your device, and to enhance your experiences. For example, if you opt out of interest-based advertising, we store your opt-out preference in a cookie on your device.
• Sign-in and authentication. We use cookies to authenticate you. When you sign in to a website using your personal Eddy account, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information so you do not have to sign in each time you return to the site.
• Security. We use cookies to process information that helps us secure our products, as well as detect fraud and abuse.
• Storing information you provide to a website. We use cookies to remember information you shared. When you provide information to Eddy, such as when you add products to a shopping basket on Eddy websites, we store the data in a cookie for the purpose of remembering the information.
• Social media. Some of our websites include social media cookies, including those that enable users who are signed in to the social media service to share content via that service.
• Feedback. Eddy uses cookies to enable you to provide feedback on a website.
• Showing advertising. Eddy uses cookies to record how many visitors have clicked on an advertisement and to record which advertisements you have seen, for example, so you don’t see the same one repeatedly.
• Analytics. We use first- and third-party cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our products.

Performance. Eddy uses cookies to understand and improve how our products perform. For example, we use cookies to gather data that helps with load balancing; this helps ensure that our websites remain up and running.

In addition to the cookies Eddy sets when you visit our websites, third parties can also set cookies when you visit Eddy sites. For example:

• Companies we hire to provide services on our behalf, such as site analytics, place cookies when you visit our sites.
• Companies that deliver content, such as videos or news, or ads on Eddy sites, place cookies on their own. These companies use the data they process in accordance with their privacy policies, which may enable these companies to collect and combine information about your activities across websites, apps or online services.

How to control cookies

Most web browsers automatically accept cookies but provide controls that allow you to block or delete them. Please refer to your browser’s privacy or help documentation to find Instructions for blocking or deleting cookies in other browsers.

Certain features of Eddy products depend on cookies. If you choose to block cookies, you cannot sign in or use some of those features, and preferences that are dependent on cookies will be lost. If you choose to delete cookies, any settings and preferences controlled by those cookies, including advertising preferences, are deleted and will need to be recreated.

Our use of web beacons and analytics services

Some Eddy webpages contain electronic tags known as web beacons that we use to help deliver cookies on our websites, count users who have visited those websites and deliver co-branded products. We also include web beacons or similar technologies in our electronic communications to determine whether you open and act on them.

In addition to placing web beacons on our own websites, we sometimes work with other companies to place our web beacons on their websites or in their advertisements. This helps us develop statistics on how often clicking on an advertisement on aEddy website results in a purchase or other action on the advertiser’s website.

Finally, Eddy products often contain web beacons or similar technologies from third-party analytics providers, which help us compile aggregated statistics about the effectiveness of our promotional campaigns or other operations. These technologies enable the analytics providers to set or read their own cookies or other identifiers on your device, through which they can collect information about your online activities across applications, websites, or other products. However, we prohibit these analytics providers from using web beacons on our sites to collect or access information that directly identifies you (such as your name or email address). You can opt out of data collection or use by some of these analytics providers by clicking any of the following links: Adjust, AppsFlyer, Clicktale, Flurry Analytics, Google Analytics (requires you to install a browser add-on), Kissmetrics, Mixpanel, Nielsen, Visible Measures, or WebTrends.

Other similar technologies

In addition to standard cookies and web beacons, our products can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally. But, like standard cookies, these technologies can also store a unique identifier for your computer, which can then track behaviour. These technologies include Local Shared Objects (or “Flash cookies”) and Silverlight App Storage.

Local Shared Objects or “Flash cookies”. Websites that use Adobe Flash technologies can use Local Shared Objects or “Flash cookies” to store data on your computer. To learn how to manage or block Flash cookies, go to the Flash Player help page.

Silverlight Application Storage. Websites or applications that use Microsoft Silverlight technology also have the ability to store data by using Silverlight Application Storage.

Security of personal data

Eddy is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as a credit card number or password) over the Internet, we protect it through the use of encryption. Eddy complies with applicable data protection laws, including applicable security breach notification laws.

Where we store and process personal data

Personal data collected by Eddy may be stored and processed in your region, in Canada and the United States. Eddy uses Microsoft Azure Hosting services in Virginia and California. The storage location(s) are chosen in order to operate efficiently, to improve performance and to create redundancies in order to protect the data in the event of an outage or other problem. We take steps to ensure that the data we collect under this privacy statement is processed according to the provisions of this statement and the requirements of applicable law.

Our retention of personal data

Eddy retains personal data for as long as necessary to provide the products and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes and enforcing our agreements. Because these needs can vary for different data types, the context of our interactions with you or your use of products, actual retention periods can vary significantly.

Other criteria used to determine the retention periods include:

• Do customers provide, create or maintain the data with the expectation we will retain it until they affirmatively remove it? Examples include customers adding secondary users to their accounts.
• Is there an automated control, such as in the MyEddyHome App, that enables the customer to access and delete the personal data at any time? If there is not, a shortened data retention time will generally be adopted.
• Is the personal data of a sensitive type? If so, a shortened retention time would generally be adopted.
• Has Eddy adopted and announced a specific retention period for a certain data type?For example, informationof the instrument for payments to keep your account in good standing is retained for the duration of the term of service.
• Has the user provided consent for a longer retention period? If so, we will retain data in accordance with your consent.
• Is Eddy subject to a legal, contractual or similar obligation to retain or delete the data? Examples can include mandatory data retention laws in the applicable jurisdiction, government orders to preserve data relevant to an investigation or data retained for the purposes of litigation. Conversely, if we are required by law to remove unlawful content, we will do so.

Advertising

Advertising allows us to provide, support and improve some of our products. Eddy does not use what you say in email, chat, video calls or voicemail, or your documents, photos or other personal files to target ads to you. We use other data, detailed below, for advertising in our products and on third-party properties. For example:

• Eddy may use data we collect to select and deliver some of the ads you see on Eddy web properties, such as www.EddySolutions.com, and www.MyEddyHome.com.
• We may share data we collect with third parties, such as Oath, AppNexus or Facebook (see below), so that the ads you see in our products, their products or other sites and apps serviced by these partners are more relevant and valuable to you.
• Advertisers may choose to place our web beacons on their sites, or use similar technologies, in order to allow Eddy to collect information on their sites such as activities, purchases and visits; we use this data on behalf of our advertising customers to provide ads.

The ads that you see may be selected based on data we process about you, such as your location, your transactions, how you use our products, or the content you view. For example, if you view content on EddySolution.com about water damage protection, we may show advertisements about insurance providers.

The ads that you see may also be selected based on other information learned about you over time using demographic data, location data, usage data from our products and sites, as well as the sites and apps of our advertisers and partners. We refer to these ads as “interest-based advertising” in this statement. For example, if you view smart home content on EddySolution.com, you may see offers for smart water meters on MyEddyHome.com. To provide interest-based advertising, we combine cookies placed on your device using information that we collect (such as IP address) when your browser interacts with our websites. If you opt out of receiving interest-based advertising, data associated with these cookies will not be used.

Further details regarding our advertising-related uses of data include:

• Children and advertising. We do not deliver interest-based advertising to children who are added to the Eddy Solutions Account by their parents.
• Data retention. For interest-based advertising, we retain data for no more than 13 months, unless we obtain your consent to retain the data longer.
• Data sharing. In some cases, we share with advertisers reports about the data that we have collected on their sites or ads.

Data collected by other advertising companies. Advertisers sometimes include their own web beacons (or those of their other advertising partners) within their advertisements that we display, enabling them to set and read their own cookie. Additionally, Eddy partners with third-party ad companies to help provide some of our advertising services, and we also allow other third-party ad companies to display advertisements on our sites. These third parties may place cookies on your computer and collect data about your online activities across websites or online services. These companies currently include, but are not limited to: A9, AppNexus, Criteo, Facebook, MediaMath, nugg.adAG, Oath, Rocket Fuel, and Yahoo!. Select any of the preceding links to find more information on each company’s practices, including the choices it offers. Many of these companies are also members of the NAI or DAA, which each provide a simple way to opt out of ad targeting from participating companies.

Collection of data from children

Eddy does not knowingly collect or store any personal information about children under the age of majority in their jurisdictions.

Once parental consent or authorisation has been granted by adding the child to the notification profile in the account then it will be treated much like any other account. The child can access the account, receive water related alerts, and control the relevant Eddy products or devices.

Parents can change or revoke the consent choices previously made, and review, edit or request the deletion of the personal data of children for whom they provided consent or authorisation. For example, parents can access their Eddy Account through the MyEddyHome App and remove the notification profile of a minor that they have previously added.

Preview or free-of-charge releases

Eddy offers preview trials, insider, beta or other free-of-charge products and features (“previews”) to enable you to evaluate them while providing Eddy with data about your use of the product, including feedback and device and usage data. As a result, previews can automatically collect additional data, provide fewer controls, and otherwise employ different privacy and security measures than those typically present in our products. If you participate in previews, we may contact you about your feedback or your interest in continuing to use the product after general release.

Changes to this privacy statement

We update this privacy statement when necessary to provide greater transparency or in response to:

• Feedback from customer, regulators, industry or other stakeholders.
• Changes in our products.
• Changes in our data processing activities or policies.

When we post changes to this statement if there are material changes to the statement, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this privacy statement to learn how Eddy is protecting your information.

How to contact us

If you have a privacy concern, complaint or question for Eddy Chief Privacy Officer, please contact us by using our web form at the privacy web page. Alternatively, our Customer Service Department will be happy to answer any questions you may have about your personal information1.877.388.3339 orcontactEddy Chief Privacy Officer.

Name: Travis Allan

Title: Chief Privacy Officer
Address: 5255 Yonge Street, Suite 900 Toronto, ON Canada M2N 6P4
Email: privacy@eddysolutions.com

We will respond to questions or concerns within 30 days.

You can also contact the Privacy Commissioner of Canada for assistance between the hours of 8:30 a.m. to 4:30 p.m. EST, at:

Toll-free: 1-800-282-1376
Phone: (819)994-5444
Fax: (819)994-5424
TTY:(819)994-6591

or by mail at:

30 Victoria Street
Gatineau, Quebec
K1A 1H3

or on the web at:

http://www.priv.gc.ca

You can also contact your Provincial or Territorial Privacy Commissioner’s office for more information:

Provincial and territorial privacy laws and oversight

Alberta
Office of the Information and Privacy Commissioner of Alberta

British Columbia
Office of the Information and Privacy Commissioner for British Columbia

Manitoba
Manitoba Ombudsman

New Brunswick
Office of the Integrity Commissioner for New Brunswick

Newfoundland and Labrador
Office of the Information and Privacy Commissioner for Newfoundland and Labrador

Northwest Territories
Information and Privacy Commissioner of the Northwest Territories

Nova Scotia
Office of the Information and Privacy Commissioner Nova Scotia

Nunavut
Information and Privacy Commissioner of Nunavut

Ontario
Office of the Information and Privacy Commissioner of Ontario

Prince Edward Island
Office of the Information and Privacy Commissioner (Prince Edward Island)

Quebec
Commission d’accès à l’information du Québec

Saskatchewan
Saskatchewan Information and Privacy Commissioner

Yukon
Yukon Information and Privacy Commissioner

Eddy Business ServicesProducts

Business Products are Eddy products and related software offered to, and designed primarily for use by, businesses, condominium corporations, educational institutions, property developers, or utility companies. They include:

• Riser Protection – Stop catastrophic flooding stemming from leaks and issues within the riser stacks
• Closed Loop Line / Boiler Protection – Stop pressurized leaks within the closed loop system directly from the boiler.
• Main Feed / Zone Protection Protect your building from the main to key distribution zones
• Food Court Protection Sensors and shutoffs located in food courts/restaurants
• Eddy Link, IQ Meters, H2O Sensors, Actuators and associated hardware.
• Property Management Dashboard (Software).

In the event of a conflict between this Eddy privacy statement and the terms of any agreement(s) between a customer and EddyBusiness Services Products, the terms of those agreement(s) will control.

You can also learn more about our Business Products’ features and settings, including choices that impact your privacy or your end users’ privacy, in product documentation.

If any of the terms below are not defined in this Privacy Statement, they have the definitions below.

General. When a customer tries, purchases, uses or subscribes to Eddy Business Products, or obtains support for or professional services with such products, Eddy collects data to provide the service (including uses compatible with providing the service), provide the best experiences with our products, operate our business and communicate with the customer. For example:

• When a customer interacts with anEddy support professional, we collect device and usage data or error reports to diagnose and resolve problems.
• When a customer pays for products, we collect contact and payment data to process the payment.
• When Eddy sends communications to a customer, we use data to personalise the content of the communication.
• When a customer engages with Eddy for professional services, we collect the name and contact data of the customer’s designated point of contact and use information provided by the customer to perform the services that the customer has requested.

The Eddy Business Services Products enable you to purchase, subscribe to or use other products and online services from Eddy or third parties with different privacy practices, and those other products and online services are governed by their respective privacy statements and policies.

Business Services

To provide the Business Services, Eddy collects Customer Data, Administrator Data, Payment Data and Support Data.

We use Customer Data, Support Data and Personal Data as described in the clauses of Service Agreement. Customer is the controller of Personal Data and Eddy is the processor of such data, except when (a) Customer acts as a processor of Personal Data, in which case Eddy is a subprocessor or (b) stated otherwise in the Service Agreement.

Administrator Data is the information provided to Eddy during sign-up, purchase or administration of Business Services and Products. We use Administrator Data to provide the Business Services, complete transactions, service the account, detect and prevent fraud and comply with our legal obligations. Administrator Data includes the name, address, phone number and email address you provide, as well as aggregated usage data related to your account, such as the controls you select. Administrator Data also includes contact information of your colleagues and friends if you agree to provide it to Eddy for the limited purpose of sending them an invitation to use Eddy Business Services; we contact those individuals with communications that include information about you, such as your.

As needed, we use Administrator Data to contact you to provide information about your account, subscriptions, billing and updates to the Business Services, including information about new features, security or other technical issues. We also contact you regarding third-party inquiries we receive regarding use of the Business Services, as described in your agreement. You cannot unsubscribe from these non-promotional communications. We may also contact you regarding information and offers about other products and services, or share your contact information with Eddy’s partners. When such a partner has specific services or solutions to meet your needs, or to optimise your use of the Business Services, we may share limited, aggregated information about your organisation’s account with the partner. Eddy will not share your confidential information or contact information with the authorised partner unless we have sufficient rights to do so. You can manage your contact preferences or update your information notifying your Eddy account manager.

We use payment data to complete transactions, as well as to detect and prevent fraud.

Some Eddy Business Services require, or are enhanced by, the installation of local software (e.g. agents, device management applications) on a device. At your direction, the local software may transmit (i) data, which can include Customer Data, from a device or appliance to or from the Business Services; or (ii) logs or error reports to Eddy for troubleshooting purposes. The Eddy Business Services, including local software, collect device and usage data that is transmitted to Eddy and analysed to improve the quality, security and integrity of our products.

Property Management Dashboard

Eddy Property Management Dashboard uses data to operate effectively and provide you the best experiences. The data we collect depends on the features you use, as well as your configuration and settings, but it is generally limited to device and usage data. Here are examples of the data we collect:

• During installation or when you upgrade the software, we may collect device and usage data to learn whether you experience any difficulties.
• When you use Eddy software or appliances, we may collect device and usage data to learn about your operating environment to improve security features.
• When you experience a crash using Eddy software or appliances, you may choose to send Eddy an error report to help us diagnose the problem and deliver customer support.

Eddy uses the data we collect from Eddy software and appliances to provide and improve our products, to deliver customer support, to activate the product, to communicate with you, and to operate our business.

Revision Date: October 12, 2021