BELKIN PRIVACY POLICY
Updated January, 2024
We at Belkin are committed to protecting your privacy. Our goal is to provide you with a positive experience on our websites and when using our apps and products and services, while at the same time being transparent regarding our information practices.
This privacy policy (“Privacy Policy”) describes our privacy practices. In limited circumstances, and where it is relevant, we may also provide additional information on privacy issues in the terms of use or supplementary privacy notices, for example when one of our products is accompanied by an app. Otherwise, Belkin terms of use are subject to this Privacy Policy.
California Residents. If you are a California resident, please review the Additional Information for California Residents for important information about our privacy practices and your rights under California privacy laws.
Canada Residents. If you are a resident of Canada, please review the Additional Information for Residents of Canada for important information about our privacy practices and your rights under Canadian privacy laws.
This Privacy Policy covers our collection, use and other processing of Personal Information related to all Belkin and Wemo products (whether physical or digital), websites, related services and other online or offline interactions you have with us.
If anyone else in your household is using one of our products, please ensure that they are also aware of this Privacy Policy as appropriate.
If you are visually impaired, you may access this Privacy Policy through your browser’s audio reader.
For ease of reference, we will use the following terms in this Privacy Policy:
- Belkin, our, us or we means (and the corresponding entity who will be the ‘controller’ of your Personal Information, or the equivalent term under local law); depending on where you are, is:
- Belkin International, Inc., of 555 Aviation Boulevard, Suite 180, El Segundo, CA 90245, USA, if you are in North America, Central America or South America;
- Belkin B.V. of Eduard van Beinumstraat 8, 1077 CZ Amsterdam, The Netherlands, if you are in the European Economic Area (EEA) or anywhere else in Europe except the United Kingdom;
- Belkin Ltd of Unit 1, Regent Park, Booth Drive, Park Farm South, Wellingborough, Northamptonshire NN8 6GR, United Kingdom, if you are in the UK, the Middle East or Africa;
- Belkin Asia Pacific Ltd of Room 2601, 26th Floor, Harbourside HQ, No.8 Lam Chak Street, Kowloon Bay, Kowloon, Hong Kong, if you are anywhere in Asia except the Middle East; and
- Belkin Ltd of Suite 11, 14 Pioneer Avenue, Tuggerah NSW 2259, Australia, if you are in Australia or New Zealand.
- Belkin products includes all Belkin and Wemo branded products, apps and services; and
- Belkin websites includes all Belkin and Wemo websites operated by us.
Collectively, the Belkin products, website and other services are the Services.
Types of Information Collected and Purposes for Collection and Use
Personal Information. This means any information that relates to you, where you are identified or identifiable (either from that information alone, or other information that we hold) which may include your name, address, email address, phone number, any ID number or location data, and in some cases IP addresses.
Aggregated Information. When information is aggregated, it is added to other information about other customers and users. Where information is sufficiently aggregated, it may become anonymized.
Anonymized Information. When information is anonymized, it is converted into a form which means it can no longer be used to identify you. This may be done by removing data, or by other means. Once information is anonymized, is it is no longer considered Personal Information under applicable data protection and privacy laws.
Children’s Personal Information. We do not knowingly collect Personal Information of persons under the age where such collection is permitted. If we are informed that we have collected the Personal Information of a child under the age of majority, 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 majority, please contact us here.
We collect Personal Information directly from you, and in some cases from third parties. We also collect Personal Information automatically from you, related to your use of our Services and interactions with us. Below, we have identified the types of Personal Information we collect as well as the purposes for collecting and processing your Personal Information. These are set out below together with the legal basis we rely on in each case under GDPR and UK GDPR, to the extent that these laws apply to our collection of your Personal Information depending on your country of residence. In some instances, we have noted where Personal Information is required for the functionality of your product or for us to provide a particular service.
| Purpose | Categories of Data | Legal Basis |
|---|---|---|
| 1) Registering your Belkin product or account and maintaining your account with us | We collect contact information when you create an account and/or register your product. It will include an email address and may also include your name and postal address. We also collect information relating to the actions that you perform while logged into your account. | We use this information to take steps at your request to enter into, and perform, our contract with you in connection with the Belkin product you have purchased, and also to notify you about changes to our terms, conditions and policies. |
| 2) Managing the business relationship with our Customer, Partner and Supplier | We collect the name, and business contact information (e.g. email address, phone numbers), of the employee of our B2B customers, partners, suppliers with whom we may interact. |
We use Customer, Partner and Supplier Information to comply with tax, financial reporting and other legal requirements, in particular in order to conduct billing activities. Also, we use Customer, Partner, and Supplier Information in order to contact our B2B clients, suppliers, and business partners. We also communicate with them to conduct projects and provide services, as necessary processing to take steps to enter into and perform our contract with them. |
| 3) Cookies and first party tracking | We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a web site is viewed. See our Cookie Policy for more information. | We have a legitimate interest in making our website function and operate efficiently, for example, to support users to log in or fill out forms. |
| 4) Conducting behavioural advertising | We participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can provide advertising about products and services tailored to your interests on our website, or on other websites. See our Cookie Policy for more information. We also use cookies and other web tools for data and statistical analysis. | Where required by law, we obtain your consent prior to collecting personal data using any cookies or other tracking technologies which are not essential for the service provided by our websites or apps. |
| 5) Managing your participation in our competitions, sweepstakes or contests |
We collect information such as name, email address, age and in certain circumstances, physical address, that you provide as part of entering one competitions managed by us. When you participate in a sweepstake or contest, we collect information about you, including contact information to notify you if you are selected and to add your name to a winners list. |
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| 6) Providing customer support | If you report a problem or contact us for support, we will collect your name, phone number and email address. If you need to return your product, we will collect your physical address and sometimes your credit card number, as well as any other content that you send to us, in order for us to provide support. |
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| 7) Measuring email interconnectivity | If you receive emails from us, we use certain tools to capture data related to when you open our message, click on any links or banners contained in the email, or if you make a purchase. |
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| 8) Customer satisfaction (feedback, customer / technical support and social media) | If you provide us with feedback or interact with us via one of our customer / technical support channels (‘Live Chat’ agent / chatbot or telephone), or on one of our social media sites, we will collect your name and email address, as well as any other content that you send to us, in order to reply to you and to develop new products and improve current ones. |
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| 9) Sending you notifications, updates and other service messages | We will use your contact information to provide you with service messages, including updates about your order, changes to our terms and conditions, and notifications where you leave items in your shopping cart. |
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| 10) Conducting direct marketing activities, and sharing your Personal Information with third parties for marketing purposes | When you sign up for one of our marketing lists, we collect your email address and possibly your postal address or phone number. |
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| 11) Managing your Order Placement and Purchase | We collect your name, billing address, shipping address, email address, phone number, and credit card number when you place an order on one of our e-commerce sites. | We use your information to perform our contract to provide you with products or services. |
| 12) Conducting surveys to understand your expectations and improve our products and services | When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider on our behalf, the third party’s privacy policy applies to the collection, use, and disclosure of your information. | Only when this is authorized by applicable laws, when we have a legitimate interest in understanding your opinions and collecting information relevant to our organization. |
| 13) Personalizing the Services | We use cookies and other tracking technologies and device identifiers to determine your general geographic locations and preference settings in order to personalize the services and optimize your user experience. | With your consent, we may tailor content we send or display on our websites and other Services (e.g., for your geographic area), to offer your personalized help and instructions, and otherwise to personalize your experiences with the Services. |
| 14) Website interactions, logs and analytics | We use technology to monitor how you interact with our website. This may include noting which links you click on, information that you type into our online forms, products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page. This may also include information about your device or browser, such as browser type, operating system, Internet Protocol (IP) address, domain name, click-activity, referring website, language preferences and/or a date/time stamp for visitors. |
Where required by law, we obtain your consent prior to collecting Personal Information using any cookies or other tracking technologies which are not essential for the service provided by our websites or apps. Where exceptions to the consent requirement apply, we have a legitimate interest in:
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| 15) Ensuring our compliance with legislation and legal process | We might use some information such as the information related to your order and purchase. | We have a necessity to comply with our legal obligations such as providing information in the context of our tax and financial legal obligations. |
| 16) Establishing our rights or defend ourselves against any dispute that may arise. | All the personal information that you might provide to us during your interaction with us or that we may have collected indirectly. | We have a legitimate interest to ascertain, exercise and / or defend our rights and ensure our business continuity. |
| 17) Transferring of your personal data in case of merger, acquisition, restructuring or sale of our business. | All the personal information that you might provide to us during your interaction with us or that we may have collected indirectly. | We have a legitimate interest to develop our business activities, which may result in the transfer of all or part of your personal data. |
In addition to the information that we collect from you directly, we may also receive information about you from other third-party sources, including third parties, business partners, our affiliates, outsourced customer service providers, retailers of Belkin products or publicly available sources. When you provide Personal Information to us, we will only use your Personal Information for the purposes set out in this Privacy Policy, and any notification provided to you at the time of collection. Where permitted by applicable law, other compatible purposes of processing may also be used.
Where we process your Personal Information to perform a contract with you or to comply with a legal obligation, the provision of your Personal Information is compulsory so far as it is either a contractual or statutory requirement, or a requirement necessary to enter into a contract. In such cases, provision of your Personal Information is mandatory since it would not otherwise be possible to enter and perform our contract with you, or to comply with our legal obligations.
However, in the case of processing of your Personal Information based on your consent, you can at any time withdraw the consent you previously provided. You can also object to the processing based on our legitimate interest where that is the basis for our processing, in either case by contacting us. No further data processing will be carried out by us, except where we have compelling legitimate grounds for the processing or we need the Personal Information for the establishment, exercise or defence of legal claims.
Information Collected Automatically. We may collect personal data about how you use our services and your interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), as well as information we derive about you and your use of the services. We use cookies, log files, pixel tags and other technologies to automatically collect information when users access or use our services, such as IP address, general location information, domain name, browser type, device type, device ID, internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. We may also collect or derive location information about you, such as through your IP address. We also collect activity information related to your use of our Sites and Services, such as information regarding what pages you accessed and when, the date and time of your visit, the links clicked, searches, features used, items viewed, and time spent within the services. We may also use pixels in HTML emails to understand if individuals read or open the emails which we send to you.
Disclosing Information
Where it is a legal requirement in your location, we will only disclose your Personal Information to third parties for our marketing purposes if you have granted us permission to do so, and in accordance with the Marketing section below.
We disclose Personal Information in the following ways:
- within Belkin's corporate group, including with our subsidiaries, affiliated companies and divisions. For example, for efficiencies across the group in data storage, and because certain service providers may be contracted to a particular group company. As such, any of the above entities may use your Personal Information in accordance with this Privacy Policy;
- to Belkin’s service providers, for example, cloud service providers. Our service providers are not allowed to use, disclose, or retain your Personal Information except as permitted by us;
- to service providers, advisors or other third parties to the extent reasonably necessary to proceed with the negotiation or completion of a merger, acquisition or sale of all or a portion of our assets. If Belkin merges with, acquires, or is acquired by another entity, Personal Information will normally be transferred to the successor entity;
- to comply with the law or legal process (such as responding to subpoenas or court orders or regulator requests), to comply with government reporting obligations and to exercise our legal rights or defend against legal claims;
- to protect our legal rights or those of others, such as protecting the Belkin brand or investigating violations of Belkin terms of use, violations of law, intellectual property infringement, misuse of Belkin websites, fraud or potential threats to personal safety; and
- with other third parties with your consent. Please note that if you consent to the disclosure of your Personal Information to a third party, that third party will apply its own privacy practices. You should carefully review the privacy notice of any third party before providing them with your Personal Information.
In addition, we share anonymized information, including usage data about Belkin products, with third parties and service providers for a variety of purposes, including to analyze trends about home networking and utility use, and to show third parties how their products could work with Belkin products.
We may provide the opportunity for you to connect and interface some of our products with one or more third party products and services, which will involve the provision of information from your Belkin or Wemo product to the third party product or service. This occurs, for example, when you use a Belkin smart speaker which is connected to the Amazon Alexa Voice Service or Google Assistant. In these cases, if you purchase, use or download a third party product or service that connects to a Belkin product, your Personal Information may also be collected by that third party, and their use of your Personal Information will be addressed by the third party's privacy policy. We are not responsible for the privacy practices of such third parties, and we encourage you to carefully read their privacy policies.
Marketing
You have the right to ask us not to process your Personal Information for marketing purposes, by either withdrawing your consent or opting out from receiving marketing communications. Where it is a legal requirement in your location, 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 give you choices about your Personal Information. Some choices are presented up front in the form of opt-in notices or acceptance boxes relating to marketing to you or disclosing your Personal Information with third parties. You will always have the choice to opt out later if you change your mind. One form of opt-out is clicking the Unsubscribe link in a marketing email. This will remove you from our marketing email list. Please note that these opt-in/opt-out choices do not apply to the receipt of mandatory transactional website, service or software communications, such as update or downtime information. They also do not apply to or receipt of order or shipping confirmations on Belkin website stores, which you may receive periodically as part of Belkin performing its contract with you, 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 materials from us or a third party on our behalf, in addition to following the "Unsubscribe" instructions in a marketing email, you can send us a request here.
Where We Store Your Information
The Personal Information that we collect from you may be transferred to, and stored at, various locations globally, in particular the United States where Belkin is headquartered. It may also be processed by Belkin staff or contractors operating outside of your state, territory, province, or country of residence or region 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 of your state, territory, province, or country of residence or region.
Subject to the requirements of applicable local law, we implement policies and processes designed to ensure a globally consistent level of protection for Personal Information within Belkin.
In addition, where required by law we implement appropriate safeguards to protect your Personal Information when it is transferred internationally, whether within the Belkin group or to third party service providers. If you are resident in:
- the EEA - this may include (i) our entering into standard contractual clauses approved by the European Commission with the party outside the EEA or (ii) entering into Belkin’s Intra Group Data Transfer Agreement; or
- the UK - this may include our entering into the UK international data transfer agreement or addendum issued by the UK Information Commissioner, including in the form of Belkin’s Intra Group Data Transfer Agreement,
- In each case – our implementing supplementary measures (contractual, technical, or organizational) as may be required further to a transfer impact assessment, notably to mitigate any risk of interference by public authorities of third countries.
Data protection standards in countries where we transfer, process and store your Personal Information may be different from those in your country, but Belkin will make sure that an equivalent level of protection to the one in the EEA/UK or your territory or province of residence in Canada is guaranteed by implementing supplementary security measures.
To the extent provided by the applicable law, you have a right to contact us for more information about the safeguards we have put in place to ensure an adequate protection of your Personal Information when it is transferred as mentioned above.
Accessing and Updating Your Personal Information
Please notify us of any changes to your Personal Information so that we can keep it accurate and up to date. You can access and update your Personal Information and communication preferences at any time in the following ways:
- by clicking the "Unsubscribe" link in any email you receive from us;
- by sending a request to us here. Please be sure to include your name, email address and specific relevant information about the information you would like to change or the material that you no longer wish to receive; or
- for many Belkin websites and Belkin products, by signing into your online account.
Your Rights in relation to your Personal Information
Depending on applicable data protection and privacy laws in your location, you may have rights in relation to your Personal Information. Subject to applicable exceptions, these include rights to:
- Right of rectification: correct your Personal Information if it is inaccurate or incomplete;
- Right of portability: transfer Personal Information which you have provided to us, to a third party if we are processing that data either on the basis of your consent or to perform a contract with you;
- Right of erasure: delete your Personal Information, unless we are required to retain it by law, or to establish, exercise or defend legal claims, or for another one of our business purposes, such as performing a contract or fulfilling a warranty;
- Right of access: get access to and / or receive a copy of your Personal Information as well as information about our processing of your Personal Information. Where permitted by applicable law, if you are outside the EEA, UK or California, we may make a reasonable charge if records must be accessed from backed up or archived records;
- Right to withdraw consent: withdraw your consent to our processing of your Personal Information at any time after you have consented, including opting-out of receiving marketing materials. The easiest way to do this is by clicking the "Unsubscribe" link in any email you receive from us;
- Right of restriction: restrict our processing of your Personal Information if you think that the data is inaccurate, our processing is unlawful, or that we no longer need to process your data for a particular purpose (unless we are not able to delete the data due to a legal or other obligation); and/or
- Right to object: object to our processing of your Personal Information on grounds relating to your particular situation, where the legal justification for our processing of your Personal Information is our legitimate interest. We will abide by your request unless we consider that we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise or defend legal claims;
- Digital legacy: If you are a French resident, you have the right to set out instructions (general or specific) about what happens to your Personal Information after your death.
Please address written requests and questions about your rights to privacy@belkin.com. You may request a copy of the Personal Information that we hold about you through our online portal, located here.
We will respond to your request promptly upon receipt. If you are in the EEA or UK, this will be within one month of receipt, or, if further time is required, we will inform you of this and the reason for the delay. If we cannot be sure of your identity, we may ask you to verify your identity before we can act on your request. We may conduct identity verification by phone call or by email. Depending on your request, we will ask for information such as your name, the last item you purchased from us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf. You must provide us with a copy of the signed permission that you have given to the authorized agent to submit the request on your behalf and verify your own identity directly with us.
If you are an authorized agent submitting a request on behalf of an individual you must attach a copy of the completed Authorized Agent Designation Form indicating that you have authorization to act on the consumer’s behalf. If we do not receive this information, the request will be denied.
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.
Depending on applicable law, you may also have the right to lodge a complaint with your local data protection authority, if you believe that we have not complied with applicable data protection laws. For example, please click here for a list of contact details for the EEA data protection authorities. The UK’s data protection authority is the Information Commissioner’s Office.
Information for Italian Residents
If the Italian Privacy Code applies to the processing of your Personal Information, in case of death, the aforesaid rights relating to your Personal Information may be exercised by anyone who has a personal interest, or acts to protect you as your representative, or for family reasons worthy of protection pursuant to article 2-terdecies of the Italian Privacy Code. You may expressly prohibit the exercise by your assignees of some of the rights above by written notice to be sent to us to the address below, without prejudice to your right to withdraw or modify such expressed intention later according to the same procedure.
Information for California Residents
If you are a California resident, please review the “Additional Information for California Residents” section below for additional information regarding California privacy laws and your privacy rights under California privacy laws.
Information for Residents of Canada
If you are a resident of Canada, please review the “Additional Information for Residents of Canada” section below for additional information regarding your privacy rights under applicable Canadian privacy laws.
Retention of Personal Information
As a general rule, we will only retain your Personal Information to fulfil the purposes for which it was collected, as required for legitimate business purposes as described in this Privacy Policy, or otherwise permitted by law. When we no longer need to use Personal Information, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it.
Reasons for retaining your Personal Information include:
- Needing to respond to customer complaints and queries, for example regarding orders, products and customer service;
- Defending Belkin against legal claims, in accordance with limitation periods under applicable law; and
- Complying with legal obligations to preserve documents, e.g., retaining evidence of customer sales for tax or accounting law purposes.
Belkin maintains a record retention policy that defines retention periods applicable within the business from time to time.
Cookies, Web Beacons and Other Web Tools
We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities, and use of the Sites and Services. We may combine this “usage data” with other personal data we collect about you.
To learn more about how we use cookies, web beacons, pixel tags and other web tools, and how to control which cookies, web beacons and other web tools are used, please see our Cookie Policy.
Advertising and Targeting
We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising on our websites and services, as well as to manage our advertising on third-party sites, mobile apps, and online services. We and these third-party ad companies may use cookies, pixel tags, and other tools to collect activity information on our sites (as well as on third-party sites and services), as well as IP address, location information, device ID, cookie and advertising IDs, and other identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content on our sites and on third-party sites and apps, and to evaluate the success of such ads and content.
You can review and manage your cookie preferences for our sites and opt in or out of certain cookies, including targeting cookies and tags on our sites, either by editing your browser settings or by reviewing and changing your preferences by adjusting your preferences through our cookie preference manager. This can be done here or by clicking the “Privacy Choices” link in the footer of our sites. Cookie preferences are browser and device specific, which means that you need to set the preference for each browser and device you use to access our sites. In addition, if you delete or block cookies, you may need to reapply these preferences. Further, opting out of cookies and advertising as discussed below does not mean that you will no longer receive advertising content from us. You may continue to receive generic or “contextual” ads from us, they may just be less relevant to you. For more information, see our Cookie Policy.
Security
We strive to maintain appropriate administrative, technical, and physical safeguards designed to protect the information collected by Belkin websites and Belkin products, although unfortunately the transmission of information via the Internet is not 100% secure. In the event that we are required by law to inform you of a breach to your Personal Information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
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, numbers and other characters when creating passwords, and make sure you use a secure browser. You should also be aware that names that you give your devices (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.
Third Party and Social Media Linked Sites
Belkin websites and online services may contain links to websites or online services operated by third parties. As explained under “Disclosing Information” above, Belkin products may also use or offer products and services provided by third parties, such as a third party app that works with a Belkin Product. Once you leave Belkin websites and Belkin products, your activities are governed by the terms of use and privacy policies of the third party websites and online services. We are 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.
Belkin websites may contain social media features, such as Facebook “Like” buttons. These features may collect certain Personal Information about you, such as your device’s IP address, device identifiers, 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 third-party company providing the feature.
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 changes to our Privacy Policy that materially affect our processing of the Personal Information which we have previously collected from you, we will notify you by email or by prominently posting 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 here.
If you have complaints or concerns about this Privacy Policy, please contact us at privacy@belkin.com. We treat all complaints about a breach of privacy laws seriously. Someone from Belkin will investigate your complaint and respond to you within a reasonable time.
Additional Information for California Residents
In this California specific section, we provide information as required under California privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, CCPA), which require that we provide information to California residents about how we handle their personal information (as defined by the CCPA), whether collected online or offline. This section does not address or apply to our handling of publicly available information made lawfully available by state or federal governments or other personal information that is subject to an exemption under California privacy laws.
Categories of Personal Information That We Collect and Disclose. Our collection, use, and disclosure of personal information about a California resident will vary depending upon the circumstances and nature of our interactions or relationship with them. The table below sets out generally the categories of personal information (as defined by the CCPA) about California residents that we collect, use, and disclose to others for a business or commercial purpose.
| Categories of Personal Information Collected | Categories of Third Parties to Whom We May Disclose this Information for Business or Commercial Purposes | |
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| Identifiers | such as name, postal address, phone number, unique personal identifier, online identifier, internet protocol (IP) address, device ID, email address, account name, signature, or other similar identifiers. |
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| Customer Records | Includes your account and profile information and customer records that contain personal information, such as username, name, demographics and other characteristics or descriptions, email, address, telephone number, and other contact information, account credentials, communications preferences, billing and payment information, customer service and support tickets and records, and other information individuals provide us to register for, access, purchase or use our Services. |
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| Commercial Information | Includes records of personal property, products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies, such as information about your subscriptions and current and past payments and purchases, products and services you use or are interested in, and your purchase tendencies. |
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| Internet or Other Electronic Network Activity Information | Includes browsing history, clickstream data, search history, access logs, information regarding your interactions with our websites, mobile applications and other Services and our marketing emails and online ads, and other usage data related to your use of the Services, such as language and preferences, as well as your comments, posts, and interactions in public forums and communities. |
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| Location Data |
Includes location information about a particular individual or device, such as device location information for mobile application users. |
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| Audio, Video and Electronic Data | Includes audio, electronic, visual, thermal, olfactory, or similar information (e.g., pictures, a recording of a customer service call, security video surveillance footage). |
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| Inferences | Includes inferences drawn from other personal information identified in this table to create a profile based on your account and activities, that reflect your preferences, characteristics, behavior, attitude, and abilities related to the Services. |
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| Protected classification characteristics under California or federal law | Includes characteristics of protected classifications under applicable laws, such as disability information |
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Do We “Sell” or “Share” Personal Information? California privacy laws define a “sale” as disclosing or making available to a third party, personal information in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. We do not disclose personal information to third parties in exchange for monetary compensation. We may “sell” (as defined by the CCPA) Identifiers and Internet or Other Electronic Network Activity Information to third-party advertising networks, analytics providers, and social networks. We may “share” (as defined by the CCPA) Identifiers, Customer Records, Commercial Information, Location Data, and Internet or Other Electronic Network Activity Information to third-party advertising networks, analytics providers, and social networks, as well as our Affiliates. We do not “sell” or “share” (as defined by the CCPA) sensitive personal information, nor do we “sell” or “share” any personal information about individuals who we know are under sixteen years old.
Sources of Personal Information. As noted above, in general, we may collect the categories of personal information identified in the table above directly from you, and automatically related to your use of our Services and interactions with us, as well as from third parties. This may include:
- Our Affiliates and subsidiaries
- Third-party platforms
- Third-party sites and services
- Ad networks
- Analytics providers
- Social networks
- Internet service providers
- Operating systems and platforms
- Our vendors and service providers
- Publicly available information
Purposes for Collecting and Disclosing. As described in more detail in the table provided in the “Types of Information Collected and Purposes for Collection and Use” section above, in general, we collect and otherwise process the personal information identified in the table above to provide our Services to you, respond to and fulfill your orders and requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:
- Providing our Services and related support
- Protecting the integrity of the Services
- Analyzing and improving the Services and our business
- Personalizing the Services
- Advertising, marketing, and promotional purposes
- Securing and protecting our business
- Defending our legal rights
- Auditing, reporting, corporate governance, and internal operations
- Complying with legal obligations
Retention. We will retain your personal information as long as necessary for the purposes for which the personal information was collected and is used by us, as stated in this Privacy Policy. Further, to the extent permitted by law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.
Sensitive Personal Information. Notwithstanding the purposes described above, we do not collect, use or disclose of sensitive personal information about California residents beyond the purposes authorized by the CCPA (pursuant to Cal Civ. Code § 1798.121 and § 7027(l) of the CCPA regulations). Accordingly, we only use and disclose sensitive personal information about California residents as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.
California Residents’ Rights. California residents have the right to receive certain information about how their personal information is used and disclosed and to not be discriminated against for exercising their privacy rights under the CCPA. In addition, California residents have the right to understand the material terms of any “financial incentive” offered to them and to not be included in such without consent.
The CCPA also grants California residents the following rights, in each case subject to certain exceptions:
- Opt out of sales and sharing: the right to opt out of our sale and sharing of their personal information.
- Delete: the right to request deletion of their personal information that we have collected about them.
- Know/access: the right to request and, subject to certain exemptions, receive a copy of the specific personal information that we have collected about them and to have this delivered either (a) by mail or (b) electronically in a portable and, to the extent technically feasible, readily useable format that allows the individual to transmit this information to another entity without hindrance. California residents also have the right to request that we provide them certain information about how we have handled their personal information, including the:
- categories of personal information collected;
- categories of sources of personal information;
- business and/or commercial purposes for collecting, selling, and sharing their personal information;
- categories of third parties with whom we have disclosed or shared their personal information;
- categories of personal information that we have disclosed or shared with a third party for a business purpose; and
- categories of third parties to whom the residents’ personal information has been sold and shared and the specific categories of personal information sold and shared to each category of third party.
- Correct: the right to request that a business that maintains inaccurate personal information about the resident correct that personal information.
- Limit use or disclosure of sensitive personal information: the right to limit the use or disclosure of sensitive personal information to those uses authorized by California privacy laws. However, we do not use or disclose sensitive personal information except for the purposes described above under “Sensitive Personal Information,” as authorized by California privacy laws.
Submitting CCPA Requests to Know, Correct, and Delete. California residents may submit a request to exercise their CCPA rights to know, correct, and delete by submitting a request via our webform or calling our toll-free number at 877-310-2443.
When you submit a request to know, to correct, or to delete, we will take steps to verify your request by matching the information provided by you with the information that we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information, e.g., via email) and verify your access to the registered email address for your account, to validate your request. In some cases, we may request additional information to validate your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us in writing at the contact information set forth in the “How To Contact Us” section above. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent. We will respond to verifiable requests received from California residents as required by law.
Requests to Opt Out of Sales and Sharing. California residents may submit requests to opt out of “sales” and “sharing” as set forth below:
- Browser Opt Out: You may opt out of “sales” and “sharing” (if applicable) via your browser on our websites by:
- Turning on “global privacy control”—or GPC—signals for your browser. If we recognize that your browser is transmitting a GPC signal, we will opt that browser out of “sales” and “sharing.”
- Turning off “Sales and Sharing of Personal Information” under the Cookie Preferences and Opt Out settings for that website, which you can access by clicking the “Your Privacy Choices” link in the footer of that website.
- Webform: You may submit a request to opt out of “sales” and “sharing” of personal information via our cookie preference manager. Your opt out is browser specific and applies to “sales” and “sharing” on the website you are browsing (i.e., via cookies). If you come to the website from a different device or a different browser on the same device, you will need to apply your preferences or turn on GPC for that browser or device as well. More information on GPC is available at https://globalprivacycontrol.org/.
- Apps: Some of our apps may include third-party targeting. You may opt out of “sales” and “sharing” (as applicable) for these apps via the in-app settings menu.
Financial Incentives. We may make available certain programs or offerings that are considered “financial incentives” under the CCPA (each a “Program”). Your participation in a Program is entirely voluntary, and you are free to withdraw from the Program any time. If you choose to register for and participate in a Program, we may make available to you any certain incentives, such as special offers, programs, discounts and other benefits, as described here. The value of these incentives is reasonably related to the value of the personal information we collect and process related to the Program. In our analysis, when estimating the value of the personal information, we take into account, without limitation, the expenses that are incurred with the collection of your personal information, the offering and administration of the incentives (including third-party costs), any improvements made to our products and services based on the information obtained through the Program and the revenue generated by the use of the financial incentive by our customers.
Do-Not-Track Signals. Please note that our websites do not recognize or respond to any signal which your browser might transmit through the so-called “Do Not Track” feature your browser might have. However, you can set your preferences for cookies on our websites via your browser settings or via our preference manager available below.
Rights Under California's Shine-the-Light Law. If you are a California resident, you may contact us by requesting a list of any third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing via the contact details set out in the “How to Contact Us” section above.
For more information about our privacy practices, you may contact us as set out in the “How to Contact Us” section above.
Other U.S. State Privacy Laws
Residents of certain U.S. states (including Virginia, Colorado, and Connecticut) have additional privacy rights under applicable privacy laws, subject to certain limitation, including:
- Right to Correct: to correct inaccurate personal information, taking into account the nature and purposes of the processing of the personal information.
- Right to Delete: to delete personal information provided to or obtained by us.
- Right of Access: to confirm whether we are processing personal information and to obtain a copy of personal information in a portable and, to the extent is is technically feasible, a readily usable format.
- Rights to Opt Out: to opt out of certain types of processing, including:
- to opt out of the “sale” of personal information by us
- to opt out of the use and disclosure of personal information for the purposes of targeted advertising (i.e., cross-contextual behavioral advertising).
- to opt out of processing (if any) of personal information for purposes of making decisions that produce legal or similarly significant effects.
- to opt out of certain uses and disclosures of sensitive personal information by us.
You and an authorized agent acting on your behalf may submit a request to opt out of certain types of processing by us (as applicable) and to access, correct, or delete your personal information here. We will respond to your request as required under the applicable privacy law(s).
In addition, you can also set your browser to transmit a “global privacy control” (GPC) signal or another approved “universal opt-out mechanism” to opt out of targeted advertising and sales (as defined under applicable law). If we detect that your browser is transmitting a GPC or other recognized universal opt-out signal when you visit one of our websites, we will opt that browser on your device out of targeting cookies on that website. Please note that if you come back to that website from a different device or from a different browser on the same device, you will need to apply the signal for that browser and/or device as well.
If we deny your request, you may appeal our decision by contacting us as set out in the “How to Contact Us” section above.
Additional Information for Residents of Canada
If you are a resident of Canada, the following additional clauses apply to our handling of your Personal Information. You may have different rights depending on your province or territory of residence within Canada: please consult the section below relevant to your place of residence.
Unless otherwise allowed by the laws applicable in your province or territory of residence, we will only collect, use, or communicate your Personal Information with your consent. You are generally not obliged to provide your Personal Information, however please note that we may be unable to provide certain services to you if you refuse to provide certain Personal Information.
Residents of Canada have the following rights regarding your Personal Information that we hold, subject to any conditions or limitations set out in applicable law:
Access. You have the right to obtain information about our processing of your Personal Information and obtain access to and a copy of your Personal Information. Upon written request and authentication of identity, we will provide you with your Personal Information under our control. We will also give you information about the ways in which that information is being used and a description of the individuals and organizations to whom that information has been disclosed. We may charge you a reasonable fee for doing so.
In some situations, we may not be able to provide access to certain Personal Information. We may also be prevented by law from providing access to certain Personal Information. Where an access request is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
Rectification. You may have the right to update, complete, or correct inaccuracies in your Personal Information. If you demonstrate the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If appropriate, we will send the amended information to third parties to whom the information has been disclosed. If a challenge regarding the accuracy of Personal Information is not resolved to your satisfaction, we will annotate the Personal Information under our control with a note that the correction was requested but not made.
Withdrawal of consent. You have the right to withdraw your consent to our processing of your Personal Information, without affecting the lawfulness of processing up until withdrawal. Please note that we may be unable to offer you certain services if you withdraw your consent. Withdrawing your consent does not create an obligation for us to delete Personal Information which we are otherwise allowed or required to retain under applicable law.
If you are a resident of the province of Québec, the following rights are available to you, in addition to the rights identified above:
Portability. You may have the right to obtain a machine-readable copy of your Personal Information or to have us transfer it to another third party of your choice.
De-indexation: You have the right to request, in certain circumstances, that we cease disseminating your Personal Information or to de-index any hyperlink that allows access to that Personal Information by technological means, if such dissemination contravenes applicable law or a court.
Retention: We will only keep your Personal Information for a period of up to three years. In certain cases, applicable laws may require us to retain specific records for a set period of time which may be longer than three years.
Please contact us using the information set out in the “How to Contact Us” section above, if you wish to exercise any of your rights or if you have any inquiries or complaints regarding the processing of your personal information by us. If you are not happy with how your rights are handled, you can submit a complaint to the relevant data protection authority.
Your Personal Information may be communicated, stored and processed outside of your province or territory of residence, in any country where we have facilities or in which we engage service providers. These countries may have data protection rules that are different from those of your country, and governments, courts, law enforcement or government or regulatory agencies in those countries may be able to access or obtain disclosure of your Personal Information under a lawful order or otherwise through the country’s laws, regardless of the safeguards we have put in place for protecting your Personal Information. Such transfers will only be made in full compliance with all the requirements of applicable privacy laws, and we will ensure that adequate safeguards are in place so that your Personal Information will receive an adequate degree of protection in the destination country.
