1. Quick Summary

Here's the short version. The full details follow.

• What we are: A passive home awareness platform that uses WiFi motion sensing. We are not a medical device.
• What we collect: Account information (name, email, billing), motion data from your home network, device and usage data, and limited technical information.
• Who processes it: Us, and our technology partner Cognitive Systems Corp., which provides the underlying WiFi sensing technology.
• Where it's stored: Cloud infrastructure located in the United States or Canada.
• What we don't do: We do not sell your personal information.
• Your rights: You can access, correct, delete, and download your data. Email privacy@dar.win.

2. Information We Collect

Account Information

When you create an account or purchase the Service, we collect:

• Name
• Email address
• Phone number
• Billing address
• Payment information (processed by our payment provider; we do not store full credit card numbers)
• Shipping address
• Information about the home or person being monitored (such as the address where Hardware will be installed and information about the residents you choose to provide)

Motion and Sensing Data

When the Service is operating, we and our partner Cognitive Systems Corp. collect:

• WiFi signal data used to detect movement and motion patterns within the monitored space
• Aggregated motion patterns over time used to provide insights, notifications, and analytics
• Device pairing and signal strength data

This data does not include audio, video, or images.

Device and Network Information

We collect technical information about the Hardware and the network it operates on:

• Device identifiers (such as serial numbers, MAC addresses)
• Network information (such as SSID, signal strength, router information)
• IP address and geolocation derived from IP address
• Operating system and app version of devices accessing the Service

Website Interaction Data

When you visit dar.win or related websites, we collect:

• Browser type, language, and version
• Pages visited, time on page, click activity, scrolling, and similar interaction data
• Referring URLs
• Device and operating system information

Communications

When you contact us by email, web form, phone, or chat, we collect the contents of your communication and any information you choose to share.

What We Don't Collect

• We do not capture audio or video from your home
• We do not store the content of conversations
• We do not collect biometric data, vital signs, or directly measured health data
• We do not collect data from devices that are not part of the Service

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, maintain, and improve the Service
• Process Motion Data to generate insights, notifications, and analytics
• Authenticate users and authorized users
• Process payments and manage subscriptions
• Provide customer support
• Send transactional communications (account, security, billing, service notifications)
• Send marketing communications (only if you have opted in or where permitted by law; you can unsubscribe at any time)
• Improve the Service through research, analytics, and product development
• Train and improve the underlying technology, including AI and machine learning models, in accordance with our agreement with Cognitive Systems Corp. and applicable law
• Comply with legal obligations and respond to lawful requests from authorities
• Detect and prevent fraud, abuse, or violations of our Terms
• Enforce our agreements

4. Who We Share Information With

We share information only as described below. We do not sell your personal information.

Cognitive Systems Corp.

DAR.WIN is built on WiFi motion sensing technology provided by Cognitive Systems Corp. ("Cognitive"). Cognitive processes Motion Data on our behalf and uses it to:

• Operate the WiFi sensing platform
• Improve and develop the underlying motion sensing technology and AI models
• Maintain platform security and performance

Cognitive is bound by confidentiality and security obligations under our agreement with them. Cognitive does not sell your personal information.

Service Providers

We share information with vendors who help us operate the business, including:

• Cloud hosting and infrastructure providers
• Payment processors
• Customer support tools
• Analytics providers
• Marketing and email service providers
• Logistics and shipping partners

Service providers are contractually required to protect your information and use it only for the services they provide to us.

Legal and Safety

We may disclose information when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with a subpoena, court order, or legal process
• Establish or exercise our legal rights or defend against legal claims
• Investigate, prevent, or take action regarding suspected illegal activity, fraud, threats to physical safety, or violations of our Terms
• Protect the rights, property, or safety of DAR.WIN, our customers, or others

Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, or sale of all or part of our business, your information may be transferred to the successor entity, subject to this Privacy Policy.

With Your Consent

We may share information for any other purpose with your consent.

Aggregated and De-Identified Data

We may share aggregated or de-identified data (which cannot reasonably be used to identify you) with third parties for any lawful purpose.

5. Where Your Information Is Stored

We operate primarily in the United States. Motion Data and Usage Data processed by Cognitive Systems Corp. are stored on cloud infrastructure (Amazon Web Services) located in the United States or Canada.

If you are accessing the Services from outside the United States or Canada, you understand that your information will be transferred to and processed in those countries. Data protection laws in those countries may differ from the laws in your country of residence.

6. How Long We Keep Information

We retain your information for as long as your account is active or as needed to provide the Service. We may retain certain information for longer periods to comply with legal obligations, resolve disputes, prevent fraud, or enforce our agreements.

Specifically:

• Account and billing records: Retained for the period required by tax, accounting, and consumer protection laws (typically 7 years).
• Motion Data and Usage Data: Retained for at least five (5) years after the end of your subscription, as required by our agreement with Cognitive Systems Corp.
• Marketing data: Retained until you unsubscribe or opt out.
• Support communications: Retained for the period necessary to provide ongoing support and resolve issues.

When we no longer need information, we delete or anonymize it in accordance with our retention practices.

7. How We Protect Information

We implement industry-standard administrative, technical, and physical safeguards, including:

• Encryption of data in transit (TLS) and at rest (AES-256 or equivalent)
• Strict access controls limiting employee and contractor access to a minimum necessary basis
• Regular security audits and monitoring
• Confidentiality obligations on employees, contractors, and Cognitive Systems Corp.
• Incident response procedures

No system is completely secure. We cannot guarantee absolute security, but we work hard to protect your information. If we become aware of a breach affecting your personal information, we will notify you and applicable authorities as required by law.

8. Your Privacy Rights

Depending on where you live, you have rights regarding your personal information. We honor these rights for all customers, regardless of jurisdiction, where reasonably possible.

You may have the right to:

• Access the personal information we hold about you
• Correct inaccurate information
• Delete your personal information (subject to legal and operational retention requirements)
• Restrict or object to certain types of processing
• Receive your data in a portable, machine-readable format
• Withdraw consent where we rely on your consent
• Opt out of marketing communications at any time
• Opt out of certain data uses as described below

California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to know what personal information we collect, the right to delete, the right to correct, the right to opt out of "sale" or "sharing" of personal information, and the right to limit the use of sensitive personal information. We do not sell or share your personal information for cross-context behavioral advertising.

EU/UK/EEA Residents

If you are in the European Union, the United Kingdom, or the European Economic Area, our legal basis for processing your information depends on the context: your consent, the performance of our contract with you, our legitimate interests, or compliance with legal obligations. You have the right to lodge a complaint with your local data protection authority.

Exercising Your Rights

To exercise any of these rights, contact us at privacy@dar.win. We will respond within the timeframes required by applicable law (typically 30-45 days). We may need to verify your identity before fulfilling certain requests.

We will not discriminate against you for exercising your privacy rights.

9. Cookies and Tracking Technologies

We use cookies and similar tracking technologies on our website to:

• Remember your preferences
• Understand how you use the website
• Measure advertising effectiveness
• Personalize content

Categories of Tracking Technologies We Use

• Essential cookies: Required for the website to function (login, checkout, security)
• Analytics cookies: Google Analytics — measures website usage to help us improve. Google Analytics collects IP addresses but not personally identifiable information directly, and we do not combine it with personal data.
• Advertising cookies:
  • Meta (Facebook) Pixel — measures advertising effectiveness on Facebook and Instagram and supports targeted advertising. See Meta's Data Policy.
  • Reddit Pixel — measures advertising effectiveness on Reddit. See Reddit's Privacy Policy.

Managing Cookies

You can control cookies through your browser settings. You can opt out of interest-based advertising through:

• Network Advertising Initiative: optout.networkadvertising.org
• Digital Advertising Alliance: optout.aboutads.info
• Your Facebook Ad Settings
• Your Reddit account settings

Note that opting out of cookies may limit some functionality on the website.

We honor "Do Not Track" signals and Global Privacy Control (GPC) signals where required by law.

10. Children's Privacy

DAR.WIN is not intended for children under 18, and we do not knowingly collect personal information from anyone under 18. If we learn we have collected information from a child without parental consent, we will delete it. If you believe we have collected information from a child, please contact us at privacy@dar.win.

If DAR.WIN is being used to monitor an environment that includes minors (such as a multigenerational household), the parent or legal guardian responsible for that environment is the customer of record and is responsible for compliance with applicable laws.

11. HIPAA and Healthcare Customers

DAR.WIN is sold primarily as a consumer product for personal home use. If you are a "Covered Entity" or "Business Associate" under the Health Insurance Portability and Accountability Act (HIPAA), or if you intend to deploy DAR.WIN in a healthcare setting, you must execute a separate Business Associate Agreement (BAA) with us before doing so. Contact compliance@dar.win to begin that process.

Without a BAA in place, DAR.WIN should not be used to process Protected Health Information (PHI).

12. Third-Party Links

Our websites and the Service may contain links to third-party websites and services. We are not responsible for the privacy practices of those sites. Please review their privacy policies before providing any information to them.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will:

• Update the "Last Updated" date at the top
• Notify you via email, in-app notification, or website posting at least thirty (30) days before material changes take effect

Continued use of the Services after the effective date means you accept the updated Privacy Policy.

14. Contact Us

For privacy questions, requests, or complaints:

• Email: privacy@dar.win
• Mail: Darwin Software Systems, Inc., Attn: Privacy, New York, NY 10001
• Website: dar.win/privacy-request (request form for access, deletion, and other rights)

If you are in the EU/UK/EEA, you may also contact your local data protection authority.