Last updated: 21/Oct/18

Dear user! Crow Electronic Alarm Systems (hereinafter: “Crow” or the “Company”) safeguards and respects your privacy.

The provisions set forth below are intended to inform you as to the way Crow, the manufacturer of Shepperd and Serenity systems and their ancillary products, keeps and processes the personal information pertaining to you, as the control holder in the information in conjunction and jointly with the authorized dealer. In addition, its purpose is to inform you as to the manner in which the Company manages the information collected and kept by the application and by your home system (hereinafter collectively: the “Platform”).

The use of out Platform and our services entails the delivery of details, without which we will not be able to provide the requested services to you. By entering into the engagement with us, your consent to our use of these details in order to provide the services and to operate the products in your possession is implied. All the uses of the information are set forth in this privacy policy and some of them you will be requested to approve. If a need arises to collect additional personally identifiable information about you, or to use such information for other purposes, we will seek your additional consent for that purpose.

In general - the information that you deliver, the information collected and the information used, is information that by nature will be connected to the client account, but in fact it is information as to what is happening at the location in which the system is installed. Thus, for example, in detection of ingress and egress at the location where a threshold detector is installed, we cannot tell who of the household or guests is the one that actuated the detector. Therefore, if you wish to obtain information as to one of your household members, we will be unable to provide it.

As the control holder of the information, Crow is obligated in any event to honor the following two principles:

· You are the sole owner of the personally identifiable information about you, which we process.

· Your personally identifiable information is being processed with transparency while safeguarding its security and confidentiality.

Definitions

“Personal Account”: The Crow Platform interface, in which the personally identifiable information of the client is located. The client may access this interface using his user name and password.

"Products": All the items, products and/or elements included in the Crow Platform.

“Smart Products”: The Shepperd and Serenity systems.

“Services”: All the services offered on the Platform.

“Crow Platform”: The system that you purchased added by the corresponding application.

1. Information that we collect from you and how we use it

A. The process being carried out and the nature of the information collected

We may collect personally identifiable information about you, in a number of ways:

1) When you contact or are in contact with the Company, the information collected is kept and processed, mainly in the cases set forth below:

· When you visit and/or use the application, the installed system and/or one of its components;

· When visiting the website of the Company at the address -https://www.thecrowgroup.com

· When you purchase a product of the Company or register to various services on its behalf;

· When you contact the Company, or the relevant distributor in connection with the product that you purchased;

· When you contact us by telephone, via the application, the website of the Company or by email message for technical assistance or any other service and post-sales contact;

· When you request a price proposal or information (for example, documents or demonstrations) relating to one of the services or products that we offer, directly from us or from one of our business partners.

2) In order to ensure the streamlining and improvement of the Platform, the products and the services provided by Crow, we collect, keep and process technical information relating to your system and your application, their settings and their use, in particular in relation to products that are suitable for use in conjunction with remote control devices and the other smart products.

Crow or any of its partners may use this technical information for marketing and commercial purposes as well, provided that your consent is obtained to propose services to you. The maintenance and assistance services form an integral part of the offered services and the functionality of the systems, and therefore we need to use such technical information for such purposes.

Location Data

Part of the services of the smart products are integrated in the application installed on your mobile device (mobile phone, tablet and so forth), inter alia in order to enable location services - this pursuant to your consent on the mobile phone to allow access to your location data. The information as to the location of the device may be affiliated to the Platform to enable remote control of the smart products that you have. In addition, using statistical processing, we use information that is not personally identifiable to you, to learn more about use patterns of the users, to enable us to make better products and services more accessible to them in the future.

Cookies

3) In using the Platform, we may collect information about you using cookies, sdk's, tags, pixels, beacons and similar tools (hereinafter collectively “Cookies”). The use of Cookies is made for the purpose of the ongoing good working order of the Platform, to secure the data on it and the information that you deliver, including to collect statistical data on your use of the Platform (and in particular of the application). In addition, we use cookies to verify details, to enhance your user experience, to characterize the Products that are suitable for you, and also to designate ads that are relevant to you. As mentioned above, the use is mainly for statistical, research and commercial purposes and obviously for information security purposes.

4) Cookies, in general, are text files created by order of the computers of the Company. Part of the Cookies will expire when you shut down the application, and others are retained on the hard drive of your mobile device. The Cookies contain various information such as the operation of the application, the duration of use of it, the uses made, the type of device from which you connected to it and more. The information contained in the Cookies is encrypted, and the Company takes customary security measures to safeguard your information.

5) As mentioned above - there are various kinds and purposes to Cookies -

1) “Strictly Necessary” Cookies

This type of cookies is necessary to the functionality of our platforms in order to enable you to use their main features. Without these cookies, you cannot properly use our website. These cookies are deposited by Crow only for the purposes of the functionality of the systems of the Company and its platforms.

2) Analytics cookies

These cookies provide us information on the use and performance of our website and help us improve them (for example, the functions in the application that you use, the frequency of use and so forth.) Most of those cookies are Company cookies.

3) Advertising cookies

The use of those cookies are for the purpose of advertising that is personally customized to you and sending information that is appropriate for you during the use of the application and the various websites. The use of such cookies is made mainly for the purpose of limiting the number of times that you are exposed to the same ad and in order to measure the effectiveness of ad campaigns.

Blocking these advertising cookies does not affect the use of the application. Nevertheless, blocking them will not prevent showing advertisements on our Platforms in particular or in general.

Blocking advertising cookies will only lead to ads presented to you not being customized to your fields of interest or to your preferences. In principle, these cookies are third party cookies and depend mainly upon the advertising companies - for example cookies by Google, such as those assimilated when using Google Analyticsor Firebase, for additional information on these cookies please go to Google’s website at the addresshttps://policies.google.com/technologies/cookies?hl=en

B. Transparency

1) The personally identifiable information of the user is kept in registered databases duly registered pursuant to the laws of the State of Israel, and is being used solely for the purposes declared pursuant to applicable law. Crow and anyone on its behalf are under obligation to maintain the confidentiality of the information kept by it and to comply with the guidelines and ruled on the framework of applicable law. Crow will use in the information only pursuant to its privacy policy and/or pursuant to the provisions of applicable law.

2) When we collect personal information we will notify you whether such information is necessary or whether it is not necessary from the user’s side.

3) Any refusal to provide essential information that is necessary for the purpose of the operation of the Platform or any service derived from it will prevent the completion of your requests and it may be that you will not be able to enjoy certain parts of the Platform and certain parts of its offered services.

Why do we use the information?

We use the information in order to ensure:

· The good working order of the system performance and regular improvements of Crow’s platforms, its products and services;

· Collecting and binding statistical data in order to improve the performance of Crow’s platforms, products and services;

· Carrying out deductions based upon the functionality of the products and the systems, technical data, definitions of users, and use patterns of the users of the various systems and products;

· Information security of the systems of the Company;

· Creating an account in the users communities of Crow’s products;

· Binding and collecting marketing research data and surveys;

· Sending out mailing or marketing initiatives based upon the consent of the user;

In addition, any anonymous information collected such as pages that you visited and requests, provide us a better understanding of your habits and preferences and help us improve our platform to adapt it to your needs.

4) Keeping the information - we may deposit keeping our platforms or certain services connected to the information about you with service providers such as external cloud services providers in which the information will be kept and maintained.

5) Transfer of information - we may transfer the information that we collect, in whole or in part, for the purpose of:

· Sharing the information with our business partners for the purpose of direct mailing if you provided your express consent for that purpose;

· Compliance with the provisions of applicable law and in view of requests or instructions from regulators or relevant competent authorities;

· Defense against legal proceedings or pursuant to a judicial order or regulatory duty;

· In order to safeguard your essential needs - for example in a state of emergency;

· To prevent or investigate fraud or any other illegal activity.

6) Transfer to external websites - when using the application, you may be able to click on a number of tabs of social media networks and/or widgets linked to external websites or to various social media networks, such as Facebook, Twitter, Google+, Whatsapp, Telegram, Instagram and so forth. By clicking on those, you will be transferred directly to such external website and you will be subject to the terms and conditions of use and the privacy policy of such website.

In certain cases, you will be requested to approve access of Crow’s systems to the information contained in your user profile in such social networks or external websites. If you wish to prevent Crow from obtaining access to this information contained in the public or private profile on those social networks, please use the means available to you on those networks to limit the access to your personal information. In any event, Crow will not be request for information that you elect to share on social networks or from them externally.

C. Respecting you preferences

1) Dear user! You are entitled to inspect, access, modify, amend or delete parts of your personal information and even all of it, in the appropriate circumstances. If you wish to exercise such right, you can provide us with a certificate that attests to your identity and then contact us using the email address support@crow.co.il.

Contact other than using this email address will not be deemed contact received by the Company.

If you provide to the Company an identification certificate for the purpose of verifying your identity and deleting the information about you, we will retain a copy of such certificate only to be able to prove your request. If you provide such identification certificate for the purpose of objection to processing your personal information that was kept about you, in such event we keep the certificate for a period of up to three years or up to on year after the termination of your engagement with the Company and the discontinuation of your use of its products - the later between the two.

2) Operational messages - the system will send to you from time to time messages using SMS to a defined telephone number, for example - when an alarm is actuated, a panic button and so forth. You may adjust the alerts system as you wish in the Platform.

3) You may agree to accept marketing initiatives and information from the Company by ticking the appropriate box in the privacy page of the application, at any time, commencing from the registration process and even while using the platform. The allows you to control and restrict the level of communication that we have with you.

4) We may provide your personal information to our business partners in order for them to send to you marketing initiatives and information regarding other products and services that may interest you. In such event you will be asked to tick your consent in the appropriate box, separately and expressly, if you are willing to accept these offers.

2. Collecting information and types of information - smart products

The smart products include a collection of various products (for example - detectors and cameras and control panel)through which you may define and control the platform.

What types of information are collected?

1. Zones - upon system installation several detectors were installed at your house, according to your selection upon purchase. These detectors are charged with certain areas in the house and control, for example the identification of movement, ingress and egress from such zones. These movements will be recorded as indications in the databases of the Company. When installing the system and even thereafter, you may name those area (for example - ‘entrance door’). Thus, for example, in addition to the regular indications from the system - (ingress and egress), the system settings, and the names of the system that you will select, will also be recorded in the databases of the Company.

2. Temperature detectors - if this product is installed, the indications received from it (pertaining to extraordinary temperatures for example), will be kept on the databases of the Company.

3. Deductions and behavioral habits - based upon the various data collected (and mainly information about movement from detectors), we may study your habits and behavior (for example - the frequency of ingress and egress from zones).

4. Photographs - the security cameras include a stills photography capability, these photographs will be recorded on the databases of the Company. These photographs are not linked to facial recognition technology, but in general a capability to identify ‘objects’ in space exists.

5. System settings - in addition to the zones names, the entire system settings will be recorded on the databases - thus for example the personal details that you provide during installation and activation - name, email address and so forth, will be recorded on the databases of the Company. The other definitions of the system, for example - if you define the number of your family members, this information will be recorded on the databases of the Company. In addition, the other operations of the system (arming, changes in settings and so forth) will also be recorded on the databases of the Company.

6. Use of the application -your actions on the application, the settings and the details that you feed it with - will all be recorded on the databases of the Company, concurrently with collecting information using cookies, as set forth in the first part of this privacy policy.

System modes:

The system has several possible modes, each of which collects different types of information:

- Disarm/Off: In this mode indications are sent from the various detectors as to the zones (ingress and egress), temperature and so forth.

- Stay: In this mode the types of information collected correspond with the system settings (according to the zones that were defined as armed).

- Armed: In this mode the system is armed and all the types of information are being collected.

3. General rules as to management and control of personal information

A. Duration of keeping the personal information

We keep your personal information as it being used during our business engagement, only for the period necessary to the management of such engagement.

The information related to your personal account (use name, password) will be kept for a period not exceeding three years of the date that you:

· Closed or deleted your personal account;

· That we obtained your details - unless you updated them yourself;

· We recently contacted you - unless there is a continued service or subscription that is still valid.

Information that is required to be kept for a longer period of time (for example, business / accounting information and so forth that is required for tax purposes / legal purposes / or other regulatory purposes) - will be kept for the duration of time required pursuant to applicable law or the relevant regulator.

Banking information (if applicable) is being managed by our service providers and being kept only for the duration that is necessary to our engagements only or for the purpose of transaction management, all pursuant to applicable law. It is noted - we do not keep credit details under any circumstances.

The technical information and information about the use of our products will be kept for a period of three years from the date of collection, unless the information was converted to being anonymous.

B. Security of personal information collected

We have deployed technical resources in order to prevent destruction, loss, deterioration in quality, unauthorized disclosure, modification or access, intentional or otherwise, of your personal information.

All the employees that have access to your account and to the information about you undertake to respect the confidentiality of your details and not to use such information for any other purpose except those set forth.

4. Contact us

If you have any questions pertaining to our privacy policy, you can contact us through our Platform or be sending an email message to the address support@crow.co.il or by telephone: +972-3-9726000.