BRUNT PRIVACY POLICY

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

  Brunt wants to make Brunt websites easy for you to navigate and Brunt Products easy for you to use. We are constantly improving Brunt websites and Brunt Products to make them more user-friendly.

  For ease of reference, we will use the following terms in this Privacy Policy: "Brunt", "our", "us" or "we" means Brunt. Co. Ltd., including its global subsidiaries and affiliated companies. "Brunt websites" include all global Brunt websites. "Brunt Products" includes all Brunt branded apps, products and services.



Types of Information Covered by This Privacy Policy

  Brunt may collect both Personal Information and Non-Personal Information. "Personal Information" means any information that can be used to identify you. Some examples of Personal Information include your name, address, email address and phone number. "Non-Personal Information" means information that on its own cannot be used to identify you. Some examples of Non-Personal Information include usage data relating to Brunt websites and Brunt Products, language preferences and Brunt website page views.

  Information may be aggregated and/or anonymized. When information is aggregated, it is combined with information about other customers and users. When information is anonymized, Personal Information is removed from collected data and the remaining portion of the data, containing only Non-Personal Information, is repurposed for internal or external use, such as, for example, to determine how many users of a particular router include an Internet-enabled television in a home network environment, or how many users viewed a particular website video or advertisement. Aggregated information that includes Personal Information is considered Personal Information until it has been anonymized. Anonymized information is considered Non-Personal Information. In general, usage data collected when you visit Brunt websites or use Brunt Products is both aggregated and anonymized so it does not identify you personally and is therefore Non-Personal Information.

  The Brunt websites and Brunt Products are not directed to, nor does Brunt knowingly collect Personal Information from children under the age of 13. If we are informed that we have collected the Personal Information of a child under the age of 13, we will delete that Personal Information from our systems. If you believe we might have inadvertently collected Personal Information from or about a child under the age of 13, please contact us at privacy@brunt.co.



How We Collect Information

  We may collect and process the following data about you:

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

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



How We Use Information

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


Sharing Information

  Under no circumstances do we rent or sell your Personal Information to third parties for marketing purposes. We only share your Personal Information with third parties for marketing purposes if you have granted us permission to do so. We will ask for your consent, such as by email response, opt-in box or click through agreement acceptance, before we use or share your Personal Information for any purpose other than the reason you provided it or as otherwise provided by this Privacy Policy. We may share Personal Information in the following ways:
  In addition, we may share aggregated and anonymized Non-Personal Information, including usage data about Brunt Products, with third parties for a variety of purposes, including to analyze trends about home networking and utility use, to show third parties how their products could work with Brunt Products and to generally improve home networking. We've taken steps to ensure that this information cannot be linked back to you and we require third parties to keep all shared information in its anonymized form.

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

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

  When making purchases on the Brunt website stores, Brunt uses a payment processor to verify your payment card information. Your payment card information is passed through to the payment processor and is not collected or stored by Brunt. The payment processor is authorized to use this information only to authenticate your purchase and for no other purpose.



Marketing

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

  We will always give you choices about your Personal Information. Some choices are presented up front in the form of Opt-in notices or acceptance boxes for marketing to you or sharing your Personal Information with third parties. In certain cases where permitted by law, we also may give you the choice to Opt-out. "Opt-out" means you have already chosen to Opt-in, but you later change your mind. One form of Opt-out is clicking the Unsubscribe link in a marketing email. This will take you off of our marketing email list. Brunt's general policy is to have users Opt-in, rather than Opt-out, to receive marketing information and to allow the sharing of information with third parties. Please note that these Opt-in/Opt-out choices do not apply to the receipt of mandatory website, service or software communications, such as update or downtime information, or receipt of order or shipping confirmations on Brunt website stores, which you may receive periodically unless you cancel your service or order or terminate use of software in accordance with the applicable terms of use or license agreement.

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



New Brunt Products

  When you purchase and/or download new Brunt Products, we will only use your Personal Information for the purposes set out (i) in this Privacy Policy and (ii) in any notification provided to you at the time of purchase or download.



Where We Store Your Information

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

  We will take such steps as are reasonable to make sure we and our service providers do not breach the privacy principles that govern our collection of your personal information. By providing your Personal Information to us, you fully understand and consent to the transfer, processing and storage of Personal Information outside of your country of residence where data protection standards may be different, and you consent to disclosure and use of your Personal Information to overseas service providers who may not fully comply with the particular laws of your country. Our Privacy Policy and our practices are designed to provide a globally consistent level of protection for Personal Information all over the world. This means that even in countries whose laws provide for less protection for your information, Brunt will still handle your information in the manner described in this Privacy Policy and in conformity with all applicable laws.



Accessing and Updating Your Personal Information

  We need your help in keeping your Personal Information accurate and up to date, so please notify us of any changes to your Personal Information. You can access and update your Personal Information and communication preferences at any time in the following ways:
  We will honor your reasonable request to:
  We will respond to your request promptly upon receipt. We may ask you to verify your identity before we can act on your request. If your Personal Information has been disclosed to a third party in accordance with this Privacy Policy, we will take reasonable steps to notify the third party of any updated information you provide to us.

  We note again that, if you choose to no longer receive marketing information from us, we may still communicate with you about other matters, such as product and service updates for Brunt Products you have purchased and customer support matters.



Retention of Personal Information

  We will only retain your Personal Information to fulfill the purposes for which it was collected or as required for legitimate business purposes as described in this Privacy Policy or otherwise as permitted by law.



Cookies, Web Beacons and Other Web Tools

  We use automatic data collection tools like cookies, embedded web links and widgets (collectively, "web tools"). These web tools collect certain information that your browser or your mobile device sends to Brunt websites and Brunt Products, such as computer IP address, browser type and service provider. In addition, Brunt uses small pieces of code called web beacons. Web beacons allow a website to transfer or collect information through a graphic image request. This allows Brunt to collect information such as the address of the page you are visiting, the address of the referring page you previously visited, what browser or mobile device you are using, and your display settings. Brunt and its advertising partners use web beacons, for example, to find out if advertising on Brunt websites and other websites that contain Brunt ads is effective, or if certain videos on Brunt websites are being viewed.

  Brunt may use web tools for the following purposes:
  You have the following choices regarding Brunt's use of web tools:
  We do not currently respond to web browser "do not track" signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. Visit the following website, www.allaboutdnt.org, for more information on this developing area.

  In addition to Brunt's use of web beacons on Brunt websites, we allow certain third parties who provide Brunt advertising on their websites to use their own web beacons within Brunt websites. In that case, if you click on or view a Brunt ad on one of our advertising partners' websites and are redirected or go to the Brunt website, the advertising partner places a web beacon on your browser so that we can track advertising conversions (which let us know if an ad was effective). These web beacons will appear on your browser regardless of whether you have refused to accept cookies or indicated that you do not want to be tracked on Brunt websites or on the Internet generally. However, they are only used by Brunt for the limited purpose of tracking advertising conversions and do not identify you personally in any way.

  Third parties may collect information about your online activities over time and across different websites when you use Brunt websites. To avoid tracking by these third parties, you can exercise the choices above to reject cookies, although Brunt has no control over and cannot confirm whether these third parties honor the do not track browser choices you have made.



Security

  We strive to maintain reasonable administrative, technical and physical safeguards designed to protect the information collected by Brunt websites and Brunt Products. Unfortunately, the transmission of information via the Internet is not 100% secure. Although we will do our best to protect your Personal Information, we cannot guarantee its security; any transmission is at your own risk.

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

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



Updates and Upgrades

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



Third Party and Social Media Linked Sites

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

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



Forums/Chat Rooms

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



Updates to this Privacy Policy

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



How to Contact Us

  Should you have any privacy-related questions or comments related to this Privacy Policy, please contact us at privacy@brunt.co. If you have complaints or concerns about this Privacy Policy, please contact us at the above email. We treat all complaints about a breach of the privacy laws seriously. Someone from Brunt will investigate your complaint and respond to you within a reasonable time.



Updated January 11, 2018