Global Privacy Notice
Sense Labs Inc. and all subsidiary companies, including Sense Labs International, hereafter “Sense”/”we”/”us”/”our”, was built from the ground up with the privacy of your data in mind. Keeping your data secure, and in your control, is central to how we run our company and how we build and sell our product. Most importantly, we believe that your data belongs to you, and that it is confidential. We use best-in-class practices and technology to keep it private and secure. Sense Labs International Ltd, our UK subsidiary, registered office, Greenacres. Woolton Hill. Berks, Newbury. RG20 9TA, Company Number 13024316. is registered with the UK Information Commissioners Office, Registration number: ZA877105.
Some Data Protection Laws, such as the EU GDPR and UK GDPR, distinguish between a “data controller” and a “data processor” (or similar terms). Sense is a data controller because we make decisions about how we use your personal data when delivering our services.
Sense processes your personal data in a way that is:
- Lawful, fair and transparent;
- Compatible with the purposes that we have told you about;
- Adequate and necessary, we only use the data we need to use for the reason we told you;
- Accurate and up to date;
- Not excessive, we only keep your data for as long as we need it; and
- Secure and protected.
How do we collect your personal data?
Personal data is information that can be used to identify you directly or indirectly, such as your name, location, or an online identifier. We collect personal data about you from various sources including directly from you, from your use of the Sense monitor and application and we may collect data from some third parties.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
What personal data do we use?
Contact data. If you purchase a product from our Site, we will process your name, email address, billing and shipping address, and (optionally) your phone number, for the purpose of processing your order, payment and delivery of your Sense monitor. Our basis for processing your data in this way is that it’s necessary to fulfil our contract with you.
Account data. When you register with Sense to create an account and download the Sense application we will process personal data including your name, address, email address, phone number and username and password and we’ll use this data to send you information related to your account, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages. Our basis for processing this data is also contract as we use this data to provide you with Services.
Product Data. The Sense monitor collects detailed data about the usage of electricity through the electrical panel in which it is installed. Your Sense monitor will collect data about your household appliances such as your fridge and any personal electronic devices you connect to the monitor, including detailed wattage and voltage information, and uses this data to generate hypotheses about specific devices in use. This information is used to provide you with information specific to your house, like a summary of device usage over time, or comparative information relative to others. A subset of this data is sent to our servers, where it is stored. These servers are located in the USA and we have put in place EU approved standard contractual clauses as an appropriate safeguard for the transfer of data to a country outside the EEA.
Profile Data. When providing our service to you, we use this data to identify opportunities for you to improve the efficiency of your home, such as ways to reduce electricity consumption, or identifying devices that are running inefficiently or may be failing. We gather consumption data and process it using artificial intelligence to create a customised virtual model of your home. We also send you alerts that you have consented to and enabled, which notify you that a device that has finished running (like a dishwasher) or that has been left on for an extended period of time (like a stove). Our basis for processing this data is contract as it is required for us to provide you with Services.
Service Data. The Sense application collects various information at setup time, and during usage, namely location data to set your time zone and to enhance product operations (for example, to correlate to weather); application usage information to monitor customer experience; and crash and error information for improving application experience.
Direct Marketing Data. When you create your account with us, we ask you to set your marketing preferences to confirm whether you consent to receiving marketing materials from Sense. We will also ask you if you agree to us sharing your information with third party marketing agencies we work with. You may instruct us to notify you by email, push notification or text and we will communicate with you in this way. Our basis under law for processing your personal data in this way is consent.
You may opt out of receiving promotional messages from us by following the instructions in those communications. If you opt out, we may still send you non-promotional messages, such as service emails about your accounts or our ongoing business relations.
We may engage in non-targeted advertising activities online and via social media. If you engage with our online adverts or visit our website as a result of engaging with our adverts, we may process your personal data to respond to your contact and we do so on the basis of legitimate interest. More information about the personal data we process when you visit our website is stated below.
You may send requests about your contact preferences and changes to your information including requests to opt-out of sharing your personal information with third parties at any time by emailing firstname.lastname@example.org.
General Website Data. We collect information about you in various ways when youvisit our website. We collect personal information including your name, email address, and other information you provide via the website when you submit inquiries or request more information about our product and service.
When you visit our website, some information is collected by us about your computer’s operating system, Internet Protocol (IP) address, access times, browser type and language, and the website you visited before our site are logged. Our basis under law for processing this data is legitimate interest.
Cookies. We may collect information using “cookies.” Cookies are small data files stored on your hard drive by a website. Some cookies are essential for our website to function properly but others are non-essential and allow us to collect data which we can use to help us improve our website and your experience. Cookies enable us to collect information about your usage and activity on the website to help us to understand your preferences and to enhance your experience and enjoyment when using our website, product, and service.
Third Party Cookies. We may use tools offered by third party services, such as Facebook, to send data about actions users take on our site and to place Sense ads on other websites you may visit. These third-party services may use set cookies to provide measurement services to Sense on our advertising campaigns or to target ads. You may disable the targeting advertising features by following the instructions at https://www.criteo.com/privacy/.
Web Beacons. We may collect information using web beacons. Web beacons are electronic images that may be used via the service or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
Sharing of Your Personal Data. We may share your personal data with third party vendors, consultants and other service providers who work for us and need access to your information to do that work. Where third parties process data on our behalf, they won’t use your personal information for their own purposes and we only permit them to use it in accordance with our instructions and the law.
We may share anonymised data relating to your energy consumption to energy companies who will use this data for the purpose of introducing enhanced time of use tariffs, demand side response services, grid health monitoring and control.
We may also share additional information with home insurance and home services companies so they can provide proactive and predictive maintenance services and smart insurance cover. This data is anonymised and cannot be used to identify you or we will share information with these parties if you provide us with your consent to do so.
How long do we keep your data for? We will only keep your data for as long as we need to for the reason we have collected it. If you close your Sense account, we will keep your data for a reasonable period of time to enable us to fulfil our legal and regulatory obligations.
Security of your Personal Data. We have put in place appropriate technical and security measures to protect your personal data against loss, misuse, and unauthorised access, disclosure, alteration, and destruction.
International Transfers of Personal Data. Sense may transfer, store and process personal data which is collects from its customers within the United States, UK, EU, Australia and other countries which have data protection rules that are different from those of your country.
We may share this information between our global offices to provide you with agreed services and to help to analyse and improve our products.
If you are a customer based in the UK or EEA, we may share your personal data within our group of companies and with our third party service providers. This involves transferring your personal data to countries outside the EEA and the UK.
For customers based outside of the EEA and/or the UK, we may transfer personal data to locations in the UK, EU and the United States and other countries.
If you are a customer based in Australia, we will seek your consent before making any cross-border transfer of your personal data.
Where we are required to transfer your personal data across borders, we will only share the minimal amount of personal data necessary for the purpose of processing and, where possible, we will share the personal data in an anonymised form.
Whenever we transfer your personal data to other countries, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission (in the case of transfers out of the EEA) or the UK Government (in the case of transfers out of the UK); and/or
where we use certain service providers, we may use specific contracts approved by the European Commission (in the case of transfers out of the EEA) and/or the UK Government (in the case of transfers out of the UK), in both cases which give personal data the same protection it has within the EEA and/or UK as applicable. Please contact us at email@example.com if you would like further information about the specific mechanism used by us when transferring your personal data.
Your Data Protection Rights. You have a number of rights under data protection law in relation to your personal information and if you want to exercise any of these rights, please contact us at firstname.lastname@example.org and we’ll be happy to help. These rights are as follows:
- right to request access to your personal information – you can request a copy of the personal information we hold on you;
- right to request correction of your personal information – if any personal information we hold on you is incorrect, you can request to have it corrected;
- right to request erasure of your personal information – you can ask us to delete your personal information in certain circumstances;
- right to object to processing or restrict processing of your personal information – you may object to our processing of your personal data in certain circumstances;
- right to request the transfer of your personal information – to provide you, or a third party you have chosen, with your personal information;
- right not to be subjects to automated decision making and profiling; and
- right to withdraw consent – where we process your data on the basis of consent, you can notify us that you want to withdraw consent any time.
Changes to this Policy. We may change this Policy from time to time. If we make any changes to this Policy, we will change the “Last Updated” date below and publish the updated version on or website. If we make an important change that we need to tell you about, we’ll email you to let you know.
Questions about this Policy. If you have any questions about this Policy or to access personal information we may have of yours, please contact us at email@example.com
or by writing to:
Sense Labs, Inc.
485 Massachusetts Avenue
Cambridge, MA 02139
Last Updated: September 16, 2022