Privacy Policy
We value and respect your privacy
Effective: May 27, 2022 | You may contact us for previous versions of the Privacy Policy.
In a nutshell:
Pool owners and operators worldwide trust PoolScout with protecting people, children and pets in and around their swimming pools through our PoolScout cameras and cloud service. It’s our privilege and duty to protect such customers’ data and yours.
PoolScout platform collects and processes videos, location data, and events from poolside cameras installed on customers’ premises, and lets our customers keep sight of the safety of their family members, friends, and other visitors. In the process, personal data is also collected on the platform.
Our customers manage their PoolScout data independently on our cloud platform. They decide what information to collect through their dashcam devices and for what purposes to use it. If you’ve visited a premises with a PoolScout camera and have any question regarding your data on the platform - please first approach the pool owner or operator, who can assist you with any question and right you might have with respect to such data.
Like most businesses, we at Deep Innovations also collect and process personal information of our website visitors, business contacts, and customers.
We respect your rights regarding your personal information.
Have a question and can't find an answer? Contact us, we're here to help: privacy@deepinnovations.co.uk
Now in more detail:
1. Introduction and Definitions
PoolScout is a technology platform and service owned and operated by us, Deep Innovations Ltd. (and our subsidiary Deep Innovations LLC). You can find our contact details below.
PoolScout platform collects and processes videos, location data, and events from poolside cameras installed on premises of our Customers, and lets them keep sight of the safety of their family members, friends, and other visitors.
PoolScout is a cloud Platform, connected to Camera Devices (which the Customer buys, owns, and operates), and accessible to Customers and their permitted Members through a dedicated Mobile App.
Devices record Videos and transmit various Device and Event Data, which might include personal information or personally identifiable information of the Customer, Members, or Other People (Data Subjects), as explained in detail below.
Our Customers decide the purposes for which they use PoolScout, as well as the means for collecting data from PoolScout’s magnitude of features. Our Customers control the data processed on their behalf on PoolScout and they are responsible under our Terms of Service for handling any data rights and data requests of their family members, friends, and Other People as Data Controllers. We also use the data collected on PoolScout for product improvement and commercial uses, as described in detail below, and therefore assume Joint Controller responsibility with respect to such data. Our responsibilities as Joint Controllers are mostly towards our Customers and detailed in the Joint Controllers Arrangement in our Terms of Service.
To make things clear with an example: if you’re a friend of Sam and visited Sam’s pool, where a PoolScout Device is installed and protects people around the pool, then you are a Data Subject, Sam is our Customer and has full control over your personal data, and we process your personal data on Sam’s behalf and according to his instructions. If Sam gave you access to the PoolScout App, you’re also a Member, and you can access the Platform to view live footage, videos, and take some actions, all according to your permissions as defined by Sam.
If you’re a Member or Data Subject and have any issue regarding your personal information, please contact the pool owner or operator first!
In addition, we also operate several Websites - such as PoolScout.co, DeepInnovations.co.uk, NanoScout.com - and collect personal data of Visitors. Some Visitors and other people who communicate with us, become our business Contacts or Customers. We collect and process various personal information regarding our Visitors, Contacts, and Customers, and we are the Data Controllers for such personal data.
If you are a Visitor, Contact or Customer of ours and have any issue regarding your personal information that we control, please contact us (details below).
2. How Do We Collect Personal Data?
If you’re a Contact or Customer of ours, there might be several ways in which we receive your personal data:
When you share it with us directly, through your communication with us on the Websites’ contact forms, on the mobile App, by email, phone, or facsimile, in conferences, meetings, or via any other communication channel
When other Customers, Contacts, resellers, business partners or third parties, share your information with us, based on their interaction with you, their purposes, their legal bases, and their privacy policy. In such cases, we take responsibility for controlling only the personal data that we have received.
We might augment the personal data we have about you with information you provided us directly, information others have provided us about you, and data we’ve collected about you from your use of PoolScout or Websites (see below).
If you’re a PoolScout Member or Data Subject, there are two ways in which we receive personal data about you that we process on behalf of our Customer:
Our Customer provided us with your personal data through PoolScout, the App, Devices owned and operated by the Customer, Customer’s use of the Platform, or otherwise.
You provide us personal data directly through your use of the App, Websites, customer support channels, or otherwise.
If you’re a Data Subject or another person unrelated to the Customer (Other People), PoolScout might still process some personal data about you. Such data is received from the Customer’s Device that picks your video footage or other visible or inferred personally identifiable information, at the Customer’s premises. If you have any question or request regarding your data on PoolScout, please first approach our Customer, the pool owner or operator.
PoolScout makes no attempt whatsoever to personally identify Data Subjects or Other People, who appear on Customer’s videos processed on the Platform.
If you’re a Visitor to our Websites or a Member using PoolScout, we might receive some personal data through your device, operating system, and browser, and various hosting, tracking, analytics and advertising technologies used on our Websites, such as cookies (see below), Analytics and Advertising technologies, Customer support services, Social media information, and other technologies. Our Websites do not currently respond to “Do Not Track” signals sent by your browser or device.
3. What Personal Data Do We Process?
If you’re a Contact or Customer of ours, or a PoolScout Member, we may collect and process these types of personal data about you:
Identification and Account information, such as full name, identification number, gender, profile photo, username and password
Contact details, such as country/time zone, home, work, and billing addresses, phone numbers, and email address
Social networking information you’ve shared with us
Work-related information, such as company, division, department, role, and title information
Payment information, such as bank account number, credit card details, PayPal account, or other billing information
Any personal data contained in any photos, media, and other files sent to us or uploaded to the Platform
Any other personal data you provide us on any communication channel, such as email correspondence, customer support, and product feedback.
On PoolScout, various types of personally identifiable information are collected. Our Customers decide what personal information of Members to store on the Platform or download from the Platform.
These are the types of personally identifiable information and other personal data about Data Subjects that we may process on Customers’ behalf:
Identification information and contact details of Members, as entered by the Customer or the Members on the Platform, such as name, gender, profile photo, phone numbers, and email addresses
Videos from Devices might be used to identify Customers, Members, Data Subjects and Other People:
People in and around the pool. Footage might include face and body videos, expressions, behaviors and activity in and around the pool. Gender and approximate age can also be inferred from the videos.
If you’re a Customer, please do not place Devices so they record data of other premises or public spaces.
Please be aware that the Device and Platform automatically record and process videos taken in and around the pool. Any conduct near the pool, whether appropriate or not, legitimate or illegal, might be recorded by the Device, stored on the Platform, and become available to the Customer, its permitted Members, and others at the Customer’s discretion (See “Who is Your Information Shared With?” below). If you’re a Customer or Member, make Data Subjects in the premises aware of the Device, about PoolScout, and their processing of personal data. Please don't record, process, transfer, or publish photos or videos in which people are identifiable without their permission, or if you have another legally justifiable reason to do so. When you have control over data in PoolScout, along with this control comes responsibility. Consider your use of the data in your control carefully, and consult with your lawyers when in doubt.
Location information, for example home address, IP address, and other information from the Device, which can indicate, especially in combination with the videos or other data, the location of the pool, Data Subjects, and Other People around the pool.
Any personal data contained in any videos, media, and other files uploaded by Devices, Customers, or Members
Any other personal data our Customers or Members enter or share on PoolScout
We also collect and process these types of personal data about anyone using the Devices, PoolScout Platform, App, or Websites:
Usage, logs, analytics, and other device and technical data collected when you use our Websites or PoolScout, including device information and identification numbers, operating system information, IP address, browser and session information, browsing history and referrals, cookies information, advertising identification numbers, language information, connectivity information, configuration information, metadata of files, and usage information (such as screen views, clicks, and usage time).
4. What About Personal Data of Children?
PoolScout is a technology platform that is specifically intended to save lives, especially of children and pets around pools. While we process visual data of children, we do it with Customer’s explicit consent, assuming the Customer is the parent, family member, or guardian for such children in Customer’s premises. PoolScout makes no attempt whatsoever to personally identify children, Data Subjects, or Other People, who appear on Customer’s videos processed on the Platform.
PoolScout is intended to be used by adult Customers only, with significant parental involvement and approval, and with Data Subjects’ awareness.
Please contact our Customer or contact us if you have any concern with respect to children’s personal data on the Platform.
5. What About Cookies?
A cookie is a small data file that your browser saves on your computer or mobile device. We use cookies to collect information and provide our services. We may use cookies to save your login credentials, enable certain features, understand how you interact with us, monitor your usage of our App and Websites, products and services, and personalize your experience and advertising displayed to you. You can set your browser to prevent the use of cookies. If you don’t accept cookies, our Websites and PoolScout might not function properly.
6. What Are The Purposes for Processing Personal Data? How Is Your Personal Data Used?
PoolScout
The purposes for the processing of personal data on PoolScout are determined by our Customers. Each Customer might use PoolScout for different purposes. Such purposes might include monitoring people’s safety around the pool; protecting Customer assets, such as their premises; protecting the Customers and third parties in case of accidents, legal proceedings, and insurance claims; and more.
If you’re a Member or Data Subject, we collect and use your personal data to provide our services to our Customers, according to their instructions and settings, so they can achieve their respective purposes. PoolScout may use your contact details, according to Customer’s instructions and settings on the App, to communicate with you and to provide you with support and handle requests and complaints. Such interactions are performed on Customers’ request, and based on the Customer’s settings, or on your own requests or based on your settings on the App (if you’re also a Member).
Our purpose in processing personal data on PoolScout is to provide our services to the Customers according to our agreements with them and applicable law. We also use of the data collected on PoolScout to ensure our products and services are working as intended; to analyze, measure and understand how our services are used; to improve our products and services; to develop new features, products, and services; to protect our company, staff, Customers and Members, as well as Data Subjects, and the general public; and to comply with any applicable law and assist law enforcement agencies under any applicable law.
We may also use anonymous, statistical or aggregated information collected on the Platform, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to customers, vendors, partners, and any other third party.
Websites, Customers, Contacts and Visitors
If you’re a Customer, Contact, or Visitor on our Websites, we may process your personal data for our own business purposes, including:
Delivering our products and services, improving them, and developing new features, products, and services
Providing information about our company, products, and services
Providing customer support, billing and invoicing
Contacting you via any communication channel, including email, phone, SMS, App, and other messaging platforms
Analyzing and optimizing Websites traffic and PoolScout usage
Protecting of our company, staff, Customers, and systems
Online advertising in all forms and channels, including targeting you and others who share similar characteristics as you (lookalikes) online on search engines, websites, apps, messaging platforms, social networking platforms, and offline
Direct Marketing in all forms and channels, including email, SMS, messaging, postal service, and more; you can always opt-out from Direct Marketing by unsubscribing yourself through links on any communication or by contacting us and notifying us accordingly.
7. What Is The Legal Basis For The Processing of Data?
PoolScout
As Data Controllers, our Customers usually process personal data on PoolScout (and we process such data as data processor on behalf of our Customers and according to their instructions) based on any or some of the following legal bases:
Processing is necessary for compliance with a legal obligation to which the Customer is subject, for example regulation regarding the security of people in one’s premises;
Processing is necessary for the performance of a contract to which the data subject is party (for example, an agreement for the use of our Customer’s pool, or the Terms of Service of PoolScout) or in order to take steps at the request of the data subject prior to entering into a contract;
Processing is necessary in order to protect the vital interests of the data subject or of another natural person, for example the right to personal safety when visiting a pool, and the right to defend themselves in legal proceedings with relevant evidence;
Processing is necessary for the performance of a task carried out in the public interest, such as increasing personal and public safety near pools;
Processing is necessary for the purposes of the legitimate interests pursued by our Customer or by a third party, for example: safeguarding their property, family members, friends, and visitors; protecting themselves and third parties in case of accidents, legal proceedings, and insurance claims; etc.
The data subject (Customer, Member, or Data Subject) has given consent through forms, the App, Websites, Device, or otherwise (e.g. by approving the installation of a Device in the pool, or by accessing the App and Platform), to the processing of his or her personal data for specific purposes communicated by the Customer or by PoolScout in this Privacy Policy.
As Data Processors and Joint Data Controllers for certain data, we process personal data on PoolScout based on the legal bases above, and also any or some of the following legal bases:
Processing is necessary for compliance with a legal obligation to which we are subject as data processors or controllers, for example data protection and privacy regulation;
Processing is necessary for the performance of our contracts with our Customers or our partners;
Processing is necessary in order to protect the vital interests of our Customers;
Processing is necessary for the purposes of the legitimate interests pursued by us, such as the conduct of our business and the purposes for which we process personal data as detailed in this Privacy Policy;
The data subject (Customer, Member, Data Subject, or another person) has given us consent, through the Websites, App, Resellers’ terms, or otherwise, to the processing of his or her personal data for the specific purposes communicated in this Privacy Policy;
Websites, Customers, Contacts and Visitors
As Data Controllers for our Customers, Contacts and Visitors’ personal data, we process personal data based on any or some of the following legal bases:
The data subject has given us consent to the processing of his or her personal data for specific purposes communicated in this Privacy Policy;
Processing is necessary for the performance of a contract to which the data subject is party - for example, an agreement with us or the terms of use of the Websites - or in order to take steps at the request of the data subject prior to entering into a contract;
Processing is necessary in order to protect the vital interests of the data subject or of another natural person, for example protecting our staff;
Processing is necessary for compliance with a legal obligation to which we are subject, for example the need to maintain billing records for transactions;
Processing is necessary for the purposes of the legitimate interests pursued by us, or our resellers and partners, for example the conduct of our business, the development and delivery of our products and services, and the promotion and sales of such products and services.
8. Who is Your Information Shared With?
Our services sometimes enable our Customers and their Members to share information, including personal data, based on your consent or other legal bases, as referenced above. Our Customers or Members decide about the sharing of videos and other data from the Platform, the identity of the recipients, and the distribution of the information. For example, the Customer may use the Platform to download Videos captured on its Devices and send them to friends who appear in them, insurance companies, law firms, law enforcement agencies, etc.
This section deals with information we share about you with others.
PoolScout
For the delivery of our services, we share all Member, Device, and Platform data on PoolScout (inc. identifiable information of Data Subjects and Other People) with the Customer who is the Data Controller with respect to such data. Our Customers may select to share the information with others, as mentioned above.
Customers, Contacts, and Visitors
We process your details on our servers and computers, cloud CRM services (such as Wix and Squarespace), support systems and services (such as Zendesk), billing systems , SMS gateways, Email and SMS communication services (such as Google/Firebase), project management systems (such as Monday.com), and backup systems. We may share some of your details with our staff, consultants, resellers, affiliates, and other third-party business partners for research and analysis, cooperation opportunities, joint promotions, sales, and events.
Everybody
We use additional processors around the world for various processing activities needed for the performance of PoolScout, our Websites, our App, our other products and services, our operations, and our business, and share information with such processors on a need basis. Such processors include hosting and backup providers (such as Amazon Web Services, Google, and Dropbox), analytics providers (such as Google), website technology (such as Wix and Squarespace), advertising technology (such as Google and Facebook), video playing, editing, and analysis services (such as Razor Labs, Vimeo, and iCare), telecommunication services, media transmission services (such as Wowza), security technology, and more. We limit the information we share with each processor based on the business need in using such processor, to protect your information while still effectively benefiting from the services of such processor.
We may also share non-personally identifiable information and aggregate information for any purpose. Such data is not personal data, and its sharing cannot be used to identify you.
We may need to share your information with law enforcement agencies, courts of law, and other governmental organizations, if ordered to do so by competent bodies and according to applicable law.
Mergers and Acquisitions
If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.
9. How Do We Safeguard Your Personal Data?
We take information security very seriously. We implement the state of the art security standards to prevent unauthorized or excessive access, maintain data accuracy, and ensure the correct use of information. We encrypt all major data communication transmissions to avoid interception and securely backup the information on the Platform to avoidance data loss. We also implement appropriate organizational measures to protect your information.
We apply our security standards also when working with business and technology partners. We only select and contract with processors and third parties who use appropriate security measures and provide sufficient guarantees, including technical and organizational measures, to ensure the appropriate protection of the data we entrust with them. Unfortunately, although we make every effort to keep your data safe, we cannot fully ensure or warrant the security of your personal information.
You can take part in securing your personal data. If you’re a Customer or Member, prevent unauthorized access to your mobile phone, PoolScout App and account, and to personal information by selecting a strong password and protecting your login credentials appropriately. Lock your phone when you’re not using it.
10. Do We Transfer Personal Data Internationally?
Most of our information is stored over the cloud on Amazon Web Services and Google in the U.S.. Amazon and Google take extreme measures with respect to privacy and data security. Our R&D and customer support center are located in Israel.
At the same time, our business is international - we serve Customers that keep sight on their pools around the world on PoolScout, and we utilize additional processors and service providers in various countries. Therefore, we transfer, store or otherwise process your personal information in other countries. We take appropriate safeguards in the selection of our processing vendors around the world to require that your personal information is well protected. Despite our efforts, it may be the case that a country where your personal information is processed has different, or less protective, data protection and privacy regulation than the country you live in.
11. For How Long Do We Keep Personal Data?
We keep personal information we collect for different periods, depending on the type of information, the period of our contract with our Customers, legal requirements regarding certain types of data, and other factors. Generally speaking, we will retain your personal information for a period reasonably needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will also retain your personal information for as long as necessary to resolve disputes, enforce our rights and agreements, and protect our staff and Customers.
If we no longer need your information for the purposes mentioned in this Privacy Policy, we will delete or anonymize it. In certain occasions we might not be able to fully delete or anonymize your personal information due to technical or operational reasons, for example deleting from backup storage and archives. In such cases, we shall take reasonable measures to secure any information still maintained by us according to our standard data security practices.
Please be aware that our Customers may also retain on their own systems and computers copies of personal data collected through PoolScout, even after we completed the provision of our services, ended our contractual relationships, and deleted or anonymized any data related to Customers’ accounts on the Platform. Such data retention by Customers is subject to their purposes, legal bases, Privacy Policy, and any applicable law. We take no responsibility over Customers’ use of personal data outside of the PoolScout Platform.
12. What Are Your Rights With Respect to Your Personal Data?
If you’re a Member or Data Subject on PoolScout, please approach the pool owner or operator to exercise any rights you may have, as they are the Data Controllers of your personal information. Otherwise, please contact us (details below).
According to the data protection and privacy regulation where you live, you may have certain rights with respect to your personal information.
Your rights may include, under certain terms and conditions set in the EU General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), or other applicable law:
Right of Access to your personal data processed by us
Right to Rectification of inaccurate or incomplete personal data
Right to Erasure of your personal data (“Right to be Forgotten”)
Right to Restriction of Processing for a certain period or under certain conditions
Right to Data Portability of your personal data to another data controller in a structured format
Right to Object the processing of your personal data. Specifically, you have the right to object to further processing of your personal data for direct marketing purposes.
Right Not To Be Subject to a Decision Based Solely on Automated Decision-Making. We do not make any decisions based solely on automated decision-making, and our Customers commit to us in our Terms of Service or other agreements that they avoid such practice as well.
Right to File a Complaint with the applicable data protection authority in your country
Right to know whether personal data are sold or disclosed, and to object to the sale of your personal data
Right not be discriminated against for exercising your privacy rights
After deletion or anonymization of your personal data following its retention period, the rights to access, erasure, rectification, and data portability cannot be enforced.
Your Choices with Respect to Your Personal Information
Your personal information is processed based on several legal bases, including your consent. You can withdraw your consent at any time. Other legal bases, including statutory or contractual requirements that apply to you or our Customer might remain intact even following the withdrawal of your consent. If you’re a Customer, you can also turn off, unpower, or disable the Device in the pool - this will stop the Device from recording Videos, collecting data, or sending new personal data to PoolScout. If we do not receive data from the Device, PoolScout might not function properly, and the data provided by PoolScout might be incomplete or inaccurate.
14. Do We Ever Change Our Privacy Policy?
Occasionally, we change this Privacy Policy to accommodate product and service development, industry standards, or new regulation. We will let you know personally if such changes are material, and seek consent for the updated Privacy Policy where required and as needed.
Please read the latest Privacy Policy available here from time to time. Note that we may require your consent to our up-to-date Terms of Service and Privacy Policy whenever you use our Websites, PoolScout, or App. If you do not agree to these terms and privacy policy, please do not use our services.
15. Who Can You Contact Regarding Your Personal Data?
If you’re a Member or Data Subject on PoolScout, please contact the pool owner or operator first with any issue, as they are the Data Controllers of your personal information. If you do not know who your Data Controller is, please contact our customer support and we will let you know.
You can contact us with any question or concern you have at:
Deep Innovations Ltd., a company registered in England # 10950228, 2nd Floor, 201 Haverstock Hill, Belsize Park, London NW3 4QG, United Kingdom