Privacy Notice for Flock Safety

Last Updated: June 17, 2024

Overview

This privacy notice (“Privacy Notice”) is intended to help you (“you” or “your”) understand how Flock Group, Inc. and its subsidiaries and affiliates (“Flock,” “we,” “us” or “our”) collect, use disclose, and safeguard the information you provide to us via (1) the Flock website located at http://www.flocksafety.com, including, without limitation, all sub-domains thereof on which this Privacy Notice is posted (collectively, the “Site”) and (2) the Flock Services. All terms not defined herein shall have the meaning set forth in our “Terms and Conditions” located here.

By using or accessing the Site and/or the Flock Services, you signify your acknowledgment and assent to the collection, use, and disclosure of your Personal Information, as defined herein, in accordance with this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Site and/or the Flock Services. Flock is free to revise this Privacy Notice at any time by updating this posting. We will keep this Privacy Notice under regular review and will place any updates here. The “Last Updated” section at the top of this notice states when this notice was last updated. We encourage you to periodically review this Privacy Notice to stay informed about how we collect, use, and share Personal Information.

Collection of Personal Information

The intention of this Privacy Notice is to provide you with what personal information Flock collects and how we use it, as well as describe any rights or options you may have in regards to such use. For clarity, personal information, as used in this Privacy Notice, means information that can be used to identify you, directly or indirectly, alone or together with other information (“Personal Information”). This may include things such as your full name, contact information, email address, mailing address, phone number, device IDs, certain cookie and network identifiers, and any content captured by our products that may identify an individual, and other categories described below.

We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with the Flock Services, including to administer, operate, and/or improve the Flock Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you with information relevant to your use of the Flock Services, to fulfill your requests or inquiries for certain products and services, and to analyze how you use the Flock Services. In the event you do not wish to be contacted about advertisements, please select that option here.

If you visit the Site, you may generally do so anonymously without providing any Personal Information. However, there are cases in which we may ask you for personal data. For example, we will occasionally conduct online surveys to better understand the needs and profiles of our Site visitors. In addition, we may request Personal Information when you register to receive additional information regarding our products and services, download software, sign up for a newsletter, demo, or send us a question. Even if you choose not to provide the information we request, you can still visit most of the Site, but you may be unable to access certain options, offers, and services. In case you change your mind, or wish to update or delete your Personal Information, we will endeavor to correct, update, or remove the personal data you give us in compliance with all applicable privacy laws. You can update or delete your Personal Information by contacting us at the contact points specified at the end of this Privacy Notice.

Your Flock Hardware and Other Flock Products

Information Input During Setup: When you set up your account, you may be asked for certain basic information, including, but not limited to, your device name, description, and geolocation. This information is used to personalize your experience (e.g., to tell you which device is triggering a notification). For clarity, “device” refers to any tool used to access the Flock Services and/or products, whether it is a camera, user account, or other piece of hardware or software.

Environmental Data from Sensors: We collect data from sensors built into some of our devices or products installed on your property. These sensors collect data such as device temperature and ambient light. By recording this information, your device can know, for instance, to turn on night vision if it’s dark outside.

Video and Audio Signals and Data: After you begin using your device, we may process information from your device, so that we can send you alerts such as when a suspect vehicle passes the device. When you access the Flock Services, you will have access to images, video, and/or audio recordings from your device, depending on the product. In addition, we will capture, process, and retain images, video, and/or audio data recordings from your device for the duration of your retention period, and you will be able to access those recordings using the Flock Services during your subscription period.

Technical Information from the Device: In order to improve your experience over time and help troubleshoot any problem you may encounter with your device, we may record your device’s serial number, software version, and/or technical information such as cellular signal strength.

Saved and Shared Content: You may save and choose to share certain content like video/audio clips, images, captions, and comments for other people to access using the Flock Services. We will collect and store information that will allow us to save or share your content as directed by you through the Flock Services.

Anonymized Data: We may collect, analyze, and anonymize your data to the extent such anonymization renders the data non-identifiable (“Anonymized Data”). We may use Anonymized Data to perform the Flock Services and improve or develop related systems and technologies, including the training of machine learning algorithms. Our use of Anonymized Data is not subject to this policy.

Data protection and privacy laws in your jurisdiction may impose certain responsibilities on you and your use of our products. You are responsible for ensuring that you comply with all applicable laws when you use the Flock Services or products, including, where so required, to execute a mutually agreed upon data protection agreement with Flock. Note, recording and sharing content that involves other people may affect their privacy and/or data protection rights.

Distinction Between Personal Information Captured Via this Website and Customer Data Captured by Flock Hardware

Flock Hardware captures footage of license plates via Flock cameras. This is referred to in our terms and conditions as Customer Data. Flock cameras do not use facial recognition or capture any personally identifiable information such as name, phone number, or address. Rather, Flock captures such images in public spaces where there is no expectation of privacy. While many privacy laws regulate the use of Personal Information (i.e., access, deletion, etc.), it is important to distinguish those rights from non-personal information. Since Flock cameras do not capture any Personal Information and rather capture the license plate data itself, Flock cannot verify any information captured in order to process any data subject request.

Flock’s Security Practices Regarding Customer Data

Flock’s security posture for Customer Data starts before the cameras are even installed. Flock has a dedicated team, which maps out the best location for installation - all of which require that installations are in accordance with constitutional rights. This means that Flock’s cameras are never placed in a location where there is an expectation of privacy.

Once captured, Customer Data is securely transmitted to the cloud, stored for thirty (30) days, and then permanently deleted. It is encrypted throughout its entire lifecycle and securely stored with AES256 encryption with our cloud provider, Amazon Web Services. On the camera itself, Customer Data is only stored temporarily for a period of seven (7) days until it is uploaded to the cloud, at which point it is removed automatically from the local camera. This means that Customer Data is secure from when it is on the Flock camera to when it is transferred to the cloud, using a secure connection to Flock servers. While stored in the cloud, all data (both footage and metadata) is fully encrypted at rest. Flock defaults to permanently deleting all Customer Data after thirty (30) days on a rolling basis.

Flock’s customers own 100% of their data and determine who is an Authorized End User on the account. Flock does not share the footage/data with any third-party entity, including any repossession companies, towing companies, companies related to traffic enforcement, revenue collection and unpaid fines, or any other third party entity for any commercial use. Any license plate data that may be searched by authorized law enforcement requires justification to verify the legitimacy of the search and create an audit trail. Lastly, Authorized End Users from law enforcement undergo training to properly use our system and communicate with their dispatch teams. Such users must learn how to enter legitimate reasons for search and how to audit searches as necessary.

As a result, Customer Data is captured in a location with no expectation of privacy, Customer Data does not collect Personal Information, Customer Data is securely stored, transmitted, and deleted, and any law enforcement access is contingent on training to ensure proper use. For more information on how Flock prioritizes your privacy, please visit our Trust page.

Use of Personal Information

Other than as required to perform the Flock Services as required by law, as disclosed to you when the information is collected, or as described in this Privacy Notice, Flock does not rent, sell, or otherwise distribute your Personal Information to third parties (without your consent).

Flock collects certain Personal Information about you to operate our business, which may include Personal Information contained in legal agreements (e.g., commercial agreements, NDAs, invoices, etc.), financial information relating to payments, receivables, and fulfillment (e.g., banking information, credit card or other account numbers, addresses, phone numbers, etc.), professional or employment-related information, (e.g., job applications, resumes, education and work history details, background check results, references, etc.), and employee benefit information (e.g., stock or equity ownership information, benefit elections, personal information about dependents, medical histories, contact information, etc.).

Personal Information provided by users may be used for marketing and promotional purposes only by Flock and its subsidiaries and affiliates. You may choose to opt out of such a collection by calling or emailing Flock directly, as detailed at the bottom of this notice. If you do provide us with consent to share your information with other third party companies, we may share your information with third party companies who offer products and services that may be of interest to you, in accordance with your preferences. These companies may then contact you directly with product or sample offers, personalized offers and information, or to ask for your feedback on products and programs that they think may be of interest to you. While we use all reasonable efforts to safeguard the confidentiality of your information, Flock will have no liability for disclosure of any information obtained due to errors in transmission or the unauthorized acts of third parties.

We engage third party service providers to perform certain services on our behalf. For example, we may use outside shipping companies, credit card processing companies, resellers, distributors, content providers, and/or other service providers. In order to perform those services, the service providers may need to know your Personal Information. For this reason, Flock may share your Personal Information with our third party service providers at our discretion. We require that they protect this information and only use it to perform services on our behalf.

Please note that certain third parties, such as companies providing specific features of, or integrations with, the Flock Services, or sites, services, and products provided by third parties, including some that may be linked to or otherwise made available through or on the Site and/or the Flock Services, may use other means of passively collecting information about your use of their services, the third party offerings, or content. Flock does not have access to and/or control over these third party means of data collection. For specific details on such companies’ privacy practices, please visit their privacy policies. However, in the event Flock combines data from third party offerings with other Personal Information you provide to us, this Privacy Notice governs any combined Personal Information we maintain.

We may share statistical or aggregated non-personal information about our users with advertisers, business partners, sponsors, and other third parties. This data is used to customize Flock website content and advertising to deliver a better experience to our users.

We may choose to buy or sell assets, and may share and/or transfer customer information in connection with the evaluation of, and entry into, such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information collected as described in this Privacy Notice could be one of the assets transferred to or acquired by a third party.

Data Retention

We will only retain Personal Information for as long as needed for the specific purpose in which it was collected, or as required by applicable law or regulation. For more information on how long a certain data set is retained, please contact us at privacy@flocksafety.com. Note, this is very different from our retention policy for Customer Data, which is deleted after 30 days, unless otherwise required by law.

Cookies and IP Tracking

This site may use cookies for site administration purposes. If, for any reason, you do not wish to take advantage of cookies, you may have your browser not accept them, although this may disable or render unusable some of the Site’s features. The Site may also detect and use your IP address or domain name for internal traffic monitoring and capacity purposes or to otherwise administer our website. No Personal Information is obtained; rather, the patterns of usage of our various users may be tracked to provide you with improved service and content based on aggregate or statistical reviews of user site traffic patterns. For more information on your cookie settings, please see the contact information and links below.

Special Cases

Flock reserves the right to disclose Personal Information in special cases, when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to, or interference with (either intentionally or unintentionally), our rights, property, customers, Site users, or anyone else that could be harmed by such activities. We may also access, use, preserve, and/or disclose your Personal Information to law enforcement authorities, government officials, and/or third parties, if legally required to do so, or if we have a good faith belief that such access, use, preservation, or disclosure is reasonably necessary to: (a) comply with a legal process or request; (b) enforce our Terms and Conditions, including investigation of any potential violation thereof; (c) detect, prevent, or otherwise address security, fraud, or technical issues; or (d) protect the rights, property, or safety of Flock, its customers and users, a third party, or the public, as required or permitted by law.

Policies for Children

The features, programs, promotions, and other aspects of this website requiring Personal Information are not intended for children. Flock does not knowingly collect Personal Information from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe they have disclosed Personal Information to us, please notify us at the contact point specified below. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s Personal Information.

Linked Sites

Please be advised that this website may contain links to third party websites. The linked sites are not under the control of Flock, and we are not responsible for the contents or privacy practices of any linked site or any link on a linked site. For specific details on such third parties’ privacy practices, please visit their privacy policies.

California Residents

The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), requires companies to disclose whether they sell, share, or otherwise make Personal Information available to third parties. Flock is subject to the CCPA and therefore does not sell Personal Information. However, we may share Personal Information with third party advertisers for purposes of targeting advertisements, and we may allow third parties to collect Personal Information from the Flock Services, in the event such third parties are authorized service providers that have agreed to Flock’s contractual limitations regarding retention, use, and disclosure of such Personal Information, or if you use the Flock Services to interact with third parties or direct us to disclose your Personal Information to third parties.

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California law grants state residents certain rights, including the rights to know and access certain types of Personal Information, to learn how Flock processes Personal Information, to request deletion of Personal Information, to request correction of Personal Information, to opt-out of sharing your Personal Information for third party advertising purposes, and not to be denied products or services for exercising these rights. Please note that Flock may need to verify your identity and place of residence before completing your rights request pursuant to this section. For more information on how to exercise your rights, please refer to the “Your Rights” section below.

Your Rights

You have a number of rights available to you in relation to your Personal Information. To the extent Flock has the ability to authenticate your identity, you may:

request access to, and obtain a copy of, your Personal Information on request;
change incorrect or incomplete Personal Information;
delete or stop processing your Personal Information (e.g., where the Personal Information is no longer necessary for the purposes of processing);
object to the processing of your Personal Information where Flock is relying on its legitimate interests as the legal ground for processing; and withdraw your consent in circumstances where consent is the legal basis for processing.

Kindly note that Flock cameras do not collect Personal Information and would not be able to authenticate your identity to process any of the above rights.

Security

Flock has established commercially reasonable policies and procedures, including administrative, technical, and physical safeguards, to protect the confidentiality, integrity, and security of your Personal Information. Flock will take appropriate steps to ensure compliance across Flock’s employees, contractors, agents, and affiliates to prevent any unauthorized access, use, modification, disclosure, or other misuse of your Personal Information.

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately by limiting access to your computer or device and browser by signing off after you have finished accessing your account. We take security seriously and endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. As such, to the extent Flock is not grossly negligent, you assume the risk of security breaches and all consequences resulting from them. Unauthorized entry or use, hardware, or software failure, and other factors, may compromise the security of user information at any time. 100% complete security does not presently exist anywhere online or offline. To that end, please safeguard your credentials.