This privacy policy (the “Policy”) is intended to inform you of the types of information Focal Point Smart Irrigation (“we” or “us”) collects, as well as our policies and practices regarding the collection, use, and disclosure of that information through the web pages at www.focalpointsmartirrigation.com (the “Site”).

Please read this Policy carefully, because by using the Site, you are acknowledging that you understand and agree to the terms of this Policy, and consent to the manner in which we may collect, use and disclose the foregoing information. If you do not agree to the terms of this Policy, please do not use the Site.

We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on the Policy the date it was updated. We encourage you to review this Policy from time to time to make sure that you understand how any Personal Information you provide will be used. Your continued use of the Site following the posting of changes to these terms will mean you accept those changes.

This Policy applies solely to information collected by the Site. It will notify you of the following:

What Information Do We Collect?

How Do We Use Your Information?

Do We Share Your Information?

Your Privacy Rights — Access to and Control Over Information

How to Opt-Out of Targeted Advertising

Does This Policy Apply to Other Websites Linked To Or From the Site?

Do We Collect Information From Children Under the Age of 13?

What Steps Do We Take To Protect Your Information?

What Information Do We Collect?

The technologies used on the Site, including Device Identifiers, to collect Usage Information may include, without limitation:

Cookies and web beacons (together, “Site Cookies”) may enable us to track and target the interests of our users to enhance the experience on our Site, track user actions/behavior on our Site and track the effectiveness of ads.

Analytics

We use one product to analyze activity on our site. We use Google Analytics to understand how users use our site so as to enhance the user experience on our Site. If you wish to opt-out of Google Analytics, go to

http://tools.google.com/dlpage/gaoptout?hl=en-GB.

How Do We Use Your Information?

We will use your information to respond to you regarding the reason you contacted us. We will also use your information as follows:

Do We Share Your Information?

We will not trade, rent, share or sell your Personal Information to third parties, unless you ask or authorize us to do so.

Unless you ask or provide your consent to do so, we will not share your Personal Information with any third party outside of our organization, other than with our service providers, including as necessary to fulfill your request, e.g. to ship an order. Only employees who need the Personal Information to perform a specific job (for example, billing or customer service) are granted access to Personal Information. The computers/servers in which we store Personal Information are kept in a secure environment.

We may share aggregated demographic information with our partners and advertisers. This is not linked to any Personal Information that can identify any individual person.

We will disclose Personal Information when we believe in good faith that such disclosures (a) are required by law, including, for example, to comply with a court order or subpoena, or (b) will help to: enforce our policies; enforce contest, sweepstakes, promotions, and/or game rules; protect your safety or security, including the safety and security of property that belongs to you; and/or, protect the safety and security of our Site or third parties. In addition, if Focal Point Smart Irrigation or all of its assets are acquired, all of the data collected by us through the Site and through other means and services provided by us would be among the transferred assets.

Your Privacy Rights — Access to and Control Over Information

We offer you choices regarding the collection, use, and sharing of your Personal Information. If you receive promotional communications from us, you may indicate a preference to stop receiving further promotional communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at the email address or phone number given on our Site. We do not charge for this service, and your opt-out request will be processed within 30 days of the date on which we receive it.

You can do the following at any time by contacting us via the email address or phone number given on our Site:

See what data we have about you, if any.

Change/correct any data we have about you.

Have us delete any data we have about you.

Notify us if you do not want us to share your Personal Information for marketing and promotional purposes.

How to Opt-Out of Targeted Advertising

You can set most web browsers to notify you if you receive a cookie, or you may choose to block cookies, though either of those actions may affect the use of our Site. If you prefer to not receive targeted advertising, you can opt out of some network advertising programs that use your information. To do so please visit the Digital Advertising Alliance (DAA) Opt-Out Page: http://www.aboutads.info/choices/. Please note that even if you choose to remove your information (via opting out), you will still see advertisements while you are browsing online. However the advertisements you see may be less relevant to you and your interests. Additionally, many network advertising programs allow you to view and manage the interest categories they have compiled from your online browsing activities. These interest categories help determine the types of targeted advertisements you may receive. The DAA Opt-Out Page provides a tool that identifies its member companies that have cookies on your browser and provides links to those companies’ pages where you can opt-out of receiving targeted advertisements from companies.

The Site does not currently respond to ‘Do Not Track’ signals submitted by your browser. You can find out more about your ‘Do Not Track’ options by visiting

http://www.allaboutDNT.com.

Privacy Notice Disclosure Examples

Set out below are examples of the type of information you need to include in your privacy notice. We provide these examples to inspire you while drafting or updating your privacy notice: you are not required to use the exact language below. The disclosures will vary depending on (a) what NextRoll Services you are using’ and (b) what jurisdictions your business operates in.

Collection of Data

Our site uses technologies of third-party partners [such as NextRoll] to help us recognize your device and understand how you use our site(s) so that we can improve our services to reflect your interests and serve you advertisements about the [products and/or services] that are likely to be of more interest to you. Specifically, [NextRoll/these partners] collect information about your activity on our site(s) to enable us to:

measure and analyze traffic and browsing activity on our site(s);

[Optional: if you are using our Media Services to run campaigns include this disclosure] show advertisements for our products and/or services to you on third-party sites;

[Optional: if you are using our Cross Channel Measurement Services include this disclosure] measure and analyze the performance of our advertising campaigns;

Cross-Device [Optional: if you are using our Cross Device or AdRoll Email Services]

We may share data, such as hashed email derived from emails or other online identifiers collected on our site(s) with [NextRoll/ our advertising partners]. This allows our partners to recognize and deliver you ads across devices and browsers. To read more about the technologies used by [NextRoll/our partner] and their cross-device capabilities please refer to NextRoll’s Privacy Notice.

Opting-Out

Our partners [such as NextRoll] may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. For this reason you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:

The NAI’s opt-out platform

The EDAA’s opt-out platform

The DAA’s opt-out platform

Does This Policy Apply to Other Websites Linked To Or From the Site?

The Site may contain links to other websites. Any Personal Information you provide on linked pages or sites is provided directly to that third party and is subject to that third party’s privacy policy. This Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these websites or any other sites that are linked to or from the Site. We encourage you to learn about their privacy and security practices and policies before providing them with Personal Information.

Do We Collect Information From Children Under the Age of 13?

The Site is not intended for use by children under the age of 13, and Focal Point Smart Irrigation does not knowingly collect or use any Personal Information from such children. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such Personal Information from our database.

What Steps Do We Take To Protect Your Information?

We take measures designed to protect your Personal Information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We provide physical, electronic, and procedural safeguards to protect Personal Information we process and maintain. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. To protect the confidentiality of Personal Information maintained in your account, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Site by any person using your password. Please advise us immediately if you believe your password has been misused.

Miscellaneous

This Policy and the privacy practices of Focal Point Smart Irrigation will be subject exclusively to the laws of the State of Idaho in the United States. Focal Point Smart Irrigation makes no representation that this Policy and our practices comply with the laws of any other country or jurisdiction. Users of the Site who reside outside the United States do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. If you reside outside of the United States, by using the Site, you consent to the transfer, processing and use of your information outside your country.

Questions?

If you have any questions about this policy, please contact us at: 208-701-2023