Privacy Policy

Website Use Information: Like many websites, we and our third-party partners analyze log file information and other data collected through cookies, web beacons, and other tracking technology, to collect information about your browsing behavior when you visit our Site, including for example, your browser type, domains, page views, IP address, referring/exit pages, information about how you interact with our Site's webpages and with third-party links, traffic and usage trends on the service, etc. We use session cookies to keep you logged in while you use features of our Site; these disappear after you close your browser. We also use persistent cookies, which stay in your browser and allow us to recognize you when you return to the Site. We use this to remember your information so you will not have to re-enter it, to better understand how you use our website and products and services, to diagnose and fix technology problems, and otherwise enhance our Site, products, and services. In some of our email messages, we use a "click-through URL" linked to content on the Site. We track this click-through data to help us measure the effectiveness of our customer communications. We also use third-party analytics tools (including Google Analytics) to assist us with analyzing and improving our service. Most Internet browsers automatically accept cookies, but you may be able to change the settings of your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you set your browser to reject cookies, parts of our Site may not work for you. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device.

• Your selection of the "Do Not Track" option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes . The only way to completely "opt out" of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device to delete and disable cookies and other tracking/recording tools.
• We permit third-party advertising partners to use cookies and other technology to collect information about your browsing activities over time and across different websites when you use our Site. For example, we use advertising services provided by third-party ad partners, such as AdRoll, to market our services to you on other websites and online services. Through a process called "retargeting," each service places a cookie on your browser when you visit our Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third party ad parties honor the Do Not Track browser signal.

Third-Party Sites and Features: Our Site may contain links to other websites operated by third parties and may include social media features such as Facebook and Twitter buttons (such as "Like," "Tweet" or "Pin"). These third-party sites may collect information about you if you click on a link and the social media sites may automatically record information about your browsing behavior every time you visit a site that has a social media button. Your interactions with these features are governed by the privacy policy of the company providing the feature, not by our privacy policy. We do not control what information these third parties collect. Please review your privacy settings on your social media sites and think carefully before clicking on links which may take you to a third-party website.

Minors: Our Site does not knowingly collect or store any personal information about children under the age of 13.

DATA SHARING: Under no circumstance do we share personal information for any commercial or marketing purpose unrelated to the delivery of pushd Products and services without asking you first. We do not rent or sell our customer lists.

The following are the limited situations where we may share personal information:

• With your explicit consent: We may share personal information when we have your consent.
• For external processing: We have vendors, service providers, and technicians who help with some of our processing and storage, including helping to answer your questions. They may also assist with monitoring our servers for technical problems. These technicians (as well as pushd employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-pushd purposes. We also have strict policies and technical barriers in place to prevent unauthorized employee access to data.
• As part of business transitions: Upon the sale or transfer of the company and/or all or part of its assets, your personal information may be among the items sold or transferred. We will request a purchaser to treat our data under the privacy statement in place at the time of its collection.
• For legal reasons: We may provide information to a third party if we believe in good faith that we are required to do so for legal reasons. For example, to respond to legal process, or comply with state and federal laws (or the applicable laws of foreign countries other than the United States).

We may share non-personal information (for example, aggregated or anonymized customer data) publicly and with our partners. This information may also be used to help us generally improve our system. We take steps to keep this non-personal information from being associated with you and we require our partners to do the same.

Your personal information may be collected, processed and stored by pushd or its service providers in the United States and other countries where our servers reside. As a result, your personal information may be subject to legal requirements, including lawful requirements to disclose personal information to government authorities, in those jurisdictions.

SECURITY: pushd takes security seriously and cares about the integrity of your personal information. We use commercially reasonable physical, administrative, and technological methods to transmit your data securely including HTTPS, TLS/SSL protocol, AES and RSA data encryption. The data is stored using Amazon's S3 cloud service. However, pushd cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

INTERNATIONAL VISITORS AND DATA TRANSFERS

International Visitors: The pushd website is hosted in the United States and is intended for United States and Canadian visitors as well as visitors from the United Kingdom, Ireland, France, Belgium and the Netherlands. If you are accessing the site from the European Union or other regions with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer.

International data transfers: When we transfer personal data from the European Economic Area to other countries, including to the United States, we use a variety of legal mechanisms to help ensure your data is appropriately protected.

We may share, as described in this Privacy Policy, information with our affiliates and subsidiaries, and third parties. We may disclose information in response to legal process and lawful requests by public authorities in the United States and other countries, for the purposes of law enforcement and national security.

Privacy Statement for Pushd, Inc. Products & Services

This Privacy Statement for Pushd, Inc. Products and Services ("Privacy Statement") describes information that Pushd, Inc. and its subsidiaries and affiliates (collectively, "pushd") collect, use, share, and store, including personal information (i.e., information that personally identifies you, such as your name, email address or billing information, or other data that can be reasonably used to infer this information).

This document focuses on information related to the operation of pushd products and services, including the Aura Frame and the Aura App (collectively, "pushd Products"). In this Privacy Statement, the expression "pushd Products" also includes our Web Apps and Mobile Apps.

pushd Privacy Policy follows the below terms

• We will be transparent about the different types of information we collect and how we use them.
• We will ask your permission before sharing your personal information with third parties for purposes other than at your request or to provide pushd Products, and to do so only when we think they will provide you with a welcome additional service.
• We will use best-in-class data security tools to keep your data safe and protect the pushd Products from unauthorized access.

Your Consent: Consent to data collection and processing. By using pushd Products, you agree to allow us to collect and process information as described in this Privacy Statement.

What information do the Aura Frame and the Aura App collect?

The Aura Frame and the Aura App collect:

• Information you provide to us
• Information collected from you about others
• Environmental data from the device sensors
• Technical information from the device
• Information collected by our servers
• Log files
• Mobile services

Information you provide to us: We may collect Personal Data from you, such as your first and last name, email, and password when you create an account to log in to our network ("Account"). If you use our Services on your mobile device, including through our Application, we may collect your phone number and the unique device ID number. If you have enabled location services on your mobile device, we collect your location information to determine where you are when you take a picture. When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality. Certain Services may require our collection of your phone number. We may associate that phone number to your mobile device identification information. If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We also collect other types of Personal Data that you provide to us voluntarily, including any requested information you may provide if you contact us via email regarding support for the Services or participate in one of our surveys. We may also collect Personal Data at other points in our Site that state that Personal Data is being collected.

Information collected from you about others: If you decide to invite a third party to create an Account, we will collect your and the third party's names and email addresses in order to send an email and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party's names and email addresses as required above. You or the third party may contact us at help@auraframes.com to request the removal of this information from our database. As part of your use of the Services, we provide you the opportunity to add family or friends as a contributor to your fame. We employ various techniques in order to facilitate adding friends and family as a contributor on our service, including but not limited to, possibly offering contact importer tools so that you can more readily ask your contacts to join and share with you through the Services. With your permission, we will access your address book to facilitate the connection with your friends and family. We do this only for contact matching to help you more easily connect with your friends and family. The email that is sent to your friends will come from pushd. We do not store any passwords you provide as part of the contact import process. We also collect some settings that help us to interpret your data, such as the language and keyboard settings that you have established, and the phone's carrier, mobile network code, and mobile country code.

Environmental data from the device sensors: We collect data from several sensors built into the Aura Frame. These sensors collect data such as the lux value of ambient light in the room, or whether something in the room is moving. This helps your Aura Frame display photos when you are at home and save energy when you are away. For example, if the Aura Frame senses that you've entered the room after an extended period of time, it can turn on the frame's display and show a new photo, based on an assumption that you've just entered the room or returned home. Similarly, if a light goes off or no one is moving in the room, the Aura Frame may turn the display brightness down or off to adjust to the brightness in the room and help save energy.

Technical information from the device: In order to improve your experience over time and help troubleshoot any problem you may encounter with the Aura Frame, we record your product model and serial number, software version, and information collected via technology, via our servers or log files. This also includes mobile services and analytics services we may use to collect information to help us analyze how users interact with the Application and Site.

Information collected by our servers: To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol ("IP") address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

Log files: We gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users' movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users' needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests.

Mobile services: We may also collect information from your mobile device if you have downloaded our Application. This information is generally used to help us provide the Services to you. Examples of information that may be collected and used include your geographic location, the time you arrived at that location, how long you have been there, how you use the Application, and information about the type of device you use. In addition, in the event our Application crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of our Application.

Analytics services: We use Google Analytics and Mixpanel or similar services to help analyze how users interact with the Site. We use this information only to improve our Site, Application, and Services. The information (including your IP address) generated by the Cookies or other technologies about your use of the Services (the "Analytics Services Information") is transmitted to Google Analytics and Mixpanel. Google Analytics and Mixpanel will use the Analytics Services Information to compile reports on user activity, such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. Google and Mixpanel may also transfer the Analytics Services Information to third parties where required to do so by law, or where such third parties process the Analytics Services Information on their behalf. Google's ability to use and share the Analytics Services Information is governed by the Google Analytics Terms of Use and the Google Privacy Policy. Mixpanel's ability to use and share the Analytics Services Information is governed by the Mixpanel Terms of Use and Mixpanel Privacy Policy. You may refuse the use of Cookies by selecting the appropriate settings in your browser. Mixpanel also offers an opt-out cookie at https://mixpanel.com/optout/ However, please note that if you do opt-out of the use of Cookies, you may not be able to all portions of the Services or all functionality of the Services. By using the Services, you consent to the processing of data about you by Google, Mixpanel and/or similar services in the manner and for the purposes set out above.

Use of Your Personal Data

• General use
• User comments
• Creation of anonymous data
• Disclosure of your personal data
• Your choices regarding information

General use: In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

• Facilitate the creation of and secure your Account on our network.
• Identify you as a user in our system.
• Provide improved administration of our Site, Application, and Services.
• Provide the Services you request.
• Improve the quality of experience when you interact with our Site, Application, and Services.
• Send you a welcome email to verify ownership of the email address provided when your Account was created.
• Send you administrative email notifications, such as security, or support and maintenance advisories.
• Respond to your inquiries related to employment opportunities or other requests.
• Contact you as a part of secondary fraud protection or to solicit your feedback.
• Send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of pushd.

User comments: We often receive comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last names and may also indicate their home city. We obtain the user's consent prior to posting his or her name along with the comment.

Creation of anonymous data: We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

Disclosure of your personal data: We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

• Third Parties Designated by You. When you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information, including other websites, your friends, relatives, and business associates. For example, users whom you have added as a contributor to your frame will see your name and frame photos.
• Third Party Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to pushd. These third party service providers are required not to use your Personal Data other than to provide the services requested by pushd.
• Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy.
• Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
• Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), pushd may disclose Personal Data if it believes in good faith that such disclosure is necessary in connection with any legal investigation; to comply with relevant laws or to respond to subpoenas or warrants served on pushd; to protect or defend the rights or property of pushd or users of the Site, Application, or Services; and/or to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

Your choices regarding information: You have several choices regarding the use of information on our Services:

• Email Communications. We will periodically send you free emails that directly promote the use of our Site or Services. When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the email you receive or by contacting us directly (please see contact information above). Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.
• Cookies. If you decide at any time that you no longer wish to accept Cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser's technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided above.
• Changing or Deleting Your Personal Data. You may change any of your Personal Data in your Account by editing your Personal Data within your Account or by sending an email to us at help@auraframes.com. You may request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request, but please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud or similar purposes.
• Applications. You can stop all collection of information by the Application(s) by uninstalling the Application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Changes to Privacy Policy: Please note that this privacy policy may change from time to time. We will provide notice of any changes on the website or by contacting you.

If you have any questions, please contact us at help@auraframes.com

Last Updated: October 4, 2016