Privacy Policy

SMART THREADS LLC is the business responsible for the information described here. This policy covers: (a) information from the Store, such as orders and messages; (b) information in your App account and profiles; (c) information that comes from someone tapping a SMART BAND or SMART POD; and (d) notifications we send you. It does not cover other companies' websites, apps or services that we link to or that you use with our products.

Information from the Store

• Contact and delivery details: name, email address, phone number, and shipping and billing address.
• Order information: items ordered, order number, order history, discounts used, and delivery status.
• Payment confirmation: whether a payment was completed and basic details such as the last four digits and card type, as provided by the payment processor. We do not receive or store your full card number.
• Messages to us: what you send through the Contact form or by email, and any photos or attachments you include.
• Account details, if you create a Store account: email address and order history.
• Sign-ups: your email address (and phone number, if you give it for text messages) when you choose to join a list.
• Device and usage information: IP address, browser and device type, pages viewed, referring page, and approximate location from your IP address, collected by cookies and similar technologies (see Section 11).

Information in your App account

• Account information (required): your email address and a user ID we assign. You sign in with your email and a 6-digit code that we send to that email. We do not use passwords and we do not store them.
• Profile information (optional, entered by you): names, photos, phone numbers, address, emergency contacts, notes, and health or medical information. See Section 14.
• Push notification token: if you allow notifications, a device token so we can send you alerts.
• Device and diagnostic data: device identifiers and crash information used to run and fix the App.
• Subscription status: see Section 12.

Information from someone who taps a product

See Section 3.

SMART BANDS and SMART PODS contain a small NFC chip. The chip has no battery and stores only a link to a profile page. On its own that link is not personal information.

When someone taps a product with a phone:

• They see the public profile fields the owner chose. Each item in a profile can be turned on or off by the account owner. Whatever is turned on can be seen by anyone who taps the product. They may also screenshot, save, or share it, and we cannot take that back.
• We record the time of the tap and basic technical information from the tapper's browser or device.
• The tapper's phone location may be shared, but only if the tapper chooses. The phone asks for permission first. The location comes from the tapper's phone at that moment. It may be approximate or inaccurate. SMART THREADS does not track location continuously, and the product itself cannot report its own location.
• The tapper may choose to send a photo or message to the account owner. We pass it along with the tap alert.
• The tapper can use the call buttons the owner chose to show.

If you or someone else wrote information (for example a phone number) directly onto a chip using a different NFC app, that information sits on the chip itself. Anyone with an NFC reader can read it, and App settings cannot hide it.

When a linked product is tapped, we may send a push notification to the account owner's phone, which is often a parent, caregiver or other adult who looks after the person wearing the product. The notification can include that a tap happened, the time, and, if the tapper chose to share them, a location, photo or message.

• We use a notification token and service providers to deliver notifications (see Section 9).
• Notifications depend on the phone, its network connection, notification settings and the App, and may be delayed or not delivered. Do not rely on them as your only way to keep someone safe.
• You can turn notifications off in your phone's settings. The App will still work, but you will not receive alerts.
• The notification may appear on a lock screen. Consider who can see your phone.
• These notifications do not contact police or emergency services. In an emergency, call your local emergency number.

In the App we collect the information below. We use it to provide App features, it is associated with your account, we do not use it for advertising, and we do not use it to track you across other companies' apps and websites.

Missing Mode is a feature the account owner can turn on to show a missing-person or missing-item message on the profile. It does not notify police or emergency services, and it does not guarantee that anyone will see the message or respond. If someone is missing or in danger, call your local emergency number.

We use information to:

• Process and deliver orders, handle returns and provide customer support.
• Create and run App accounts and profiles, show a profile to someone who taps a product, and send tap alerts and other notifications you allowed.
• Show a tap location on a map to the account owner.
• Provide, secure and improve the Store, the App and our products.
• Send service messages such as order confirmations, shipping updates and account notices.
• Send marketing emails or text messages only where you have opted in.
• Measure our advertising and show you our ads on other websites and apps, using cookies and pixels on the Store website (see Section 11).
• Prevent fraud and misuse, enforce our terms, and meet legal obligations.

We do not use health information, children's information or location information for advertising.

Where the law requires a legal basis, we process personal information based on: performance of a contract (such as filling your order or providing the App); our legitimate business interests (such as security, support and improving our products); consent (such as marketing messages and optional health information); and legal compliance.

We share information only as needed to run our business, with the providers below and in the other cases listed after the table. Providers receive only what they need to do their job for us.

We may also share information with:

• People who tap a product, who see the profile fields the owner chose to make public.
• Legal authorities, when required by law or to protect safety, rights or property.
• A successor, if SMART THREADS is involved in a merger, acquisition or sale of assets. We would require the successor to honor this policy.

Advertising partners. We share information collected on the Store website through cookies and pixels with Meta, Google and TikTok, as explained in Section 11. Sharing personal information for targeted advertising may be considered a "sale", "sharing" or "targeted advertising" under certain U.S. state privacy laws. To opt out, see our Your Privacy Choices page. We do not use health information, children's information or location information for advertising.

When you place an order, Shopify collects the details needed to complete it, including your name, email, phone number, delivery and billing address and order contents. Shopify and Shopify Payments handle your payment. We receive confirmation of the payment and limited details. We keep order records for fulfillment, support, accounting, tax and legal purposes. Shopify processes this information under its own terms and privacy notice as well as ours.

The Store is built on Shopify. Like most online stores, it uses cookies and similar technologies for:

• Store functions: keeping items in your cart, checkout, and remembering preferences.
• Security and fraud prevention.
• Analytics and performance: Shopify analytics that help us understand how the Store is used.

Advertising and marketing: The Store website uses advertising pixels and similar technologies from Meta, Google and TikTok. They use cookies and device identifiers to measure our advertising and to show you ads that may be more relevant to your interests on other websites and apps, and they may share that information with those companies, which handle it under their own privacy policies. Sharing personal information for targeted advertising based on your activity across different websites may be considered a "sale", "sharing" or "targeted advertising" under certain U.S. state privacy laws. Depending on where you live, you may have the right to opt out. To opt out, use our Your Privacy Choices page. If you visit the Store with the Global Privacy Control opt-out preference signal turned on, then, depending on where you are, we treat it as a request to opt out of that activity for the device and browser you used.

You can control cookies through your browser settings. Blocking some cookies may affect how the Store works.

App subscriptions (Starter, Plus and Unlimited, billed monthly, each with a 7-day free trial) are bought through Apple in-app purchase, not through the Store.

• Apple handles payment, billing, renewal, cancellation and refunds. Apple holds your payment method and billing details under Apple's own terms and privacy policy. We do not receive or store your full payment card number.
• RevenueCat tells us your subscription status so the App can turn the right features on, for example your plan, trial status and renewal status.
• We do not use Store checkout for subscriptions, and buying a product in the Store does not start a subscription.
• Deleting your SMART THREADS account does not cancel an Apple subscription. Manage subscriptions in your Apple account settings.
• Android coming soon.

SMART THREADS accounts are for adults 18 and older. A child's profile is created and controlled by a parent or legal guardian through the parent's own account. Children do not create accounts, sign in, or send information to us directly, and we do not knowingly collect personal information directly from children.

What we collect about a child

Only what the parent or guardian chooses to enter on the child's profile, for example a first name, photo, emergency contacts and notes, plus tap information described in Section 3. We use it only to show the profile the parent controls, send tap alerts to the parent, and run App features. We do not sell a child's information or use it for advertising or tracking. We disclose it only (a) as the public profile fields the parent chooses to make visible, (b) to the service providers listed in Section 9 that help us run the App, and (c) where the law requires.

Parental consent

Where the Children's Online Privacy Protection Act (COPPA) and the FTC's COPPA Rule apply, we obtain parental consent before we collect, use or disclose personal information from a child under 13. In the App, a parent or legal guardian creates the account and the child's profile, and children do not create accounts. You may create a child's profile only if you are the child's parent or legal guardian, or are otherwise authorized to act for the child.

2025 changes to the COPPA Rule

The FTC amended the COPPA Rule in 2025. The amendments took effect on June 23, 2025, and the general compliance date was April 22, 2026. We design our practices to follow the amended Rule, including these points:

• Separate consent for sharing with third parties: if we disclose a child's personal information to a third party, and that disclosure is not integral to the service, we ask the parent for separate consent, and the parent can agree to collection and use without agreeing to that disclosure.
• Information security: we maintain safeguards appropriate to the sensitivity of the information.
• Retention: we keep a child's personal information only as long as reasonably necessary for the purpose it was collected, and not indefinitely (see Section 16).

Parent rights

A parent or guardian can review, edit, hide or delete any information on a child's profile at any time in the App. To delete one child's profile, open the profile, choose Edit, then choose Delete. A parent can also ask us to tell them what categories of information we hold about the child, to stop further collection or use of it, and to delete it, by contacting us (Section 24). We take reasonable steps to confirm that the requester is the child's parent or guardian.

If you believe a child gave us personal information without the required parental consent, contact us and we will delete it.

Adding medical, allergy or emergency information to a profile is optional. The account owner enters it. We do not verify it and we do not review it for accuracy or completeness. SMART THREADS is not a medical device and does not give medical advice. If you choose to make medical information visible, the App asks you to confirm that anyone who taps the product can see it. We use health information only to provide the App features you ask for, and we do not use it for advertising.

We send marketing emails or text messages only if you opt in, for example by checking a consent box or signing up for an offer. Message frequency varies, and message and data rates may apply. You can unsubscribe from marketing emails using the link in the message, and you can opt out of texts at any time by replying STOP. Consent to marketing is not a condition of any purchase. We do not sell or share your phone number or text-message consent with third parties for their own marketing. Order and service messages are sent whether or not you opt in to marketing.

We keep information only as long as needed for the purposes described in this policy, to meet legal, tax and accounting requirements, to resolve disputes and to enforce our agreements.

• Order and billing records: kept as long as needed for tax, accounting and legal requirements.
• App account and profile data: while your account is active, and deleted right away when you delete it (see Section 17).
• Tap history, finder uploads (photos, messages, any location a finder chose to share) and your own photos and videos: kept as part of your account data while your account is active, and deleted right away when you delete your account.
• Children's personal information: only as long as reasonably necessary to provide the child's profile and related App features, and then deleted.
• Support messages: kept as long as needed to respond to you and keep a record of your request.

You can delete a profile, or your whole account, in the App at any time. To delete one profile, open the profile, choose Edit, then choose Delete. To delete your whole account, go to Settings, then Danger Zone, then Delete account. You can also ask us to delete your account and data without the App by emailing support@smartthreadsusa.com or using our Delete Your Account page.

Deleting your account removes your profiles (including any children's profiles), tap history, contacts, uploaded photos and videos, and account details from our active systems right away. We may keep limited records the law requires, such as order and billing records. Deleting your account does not cancel an Apple subscription. To cancel, use your Apple account settings.

To ask us to delete Store information such as order or contact details, contact us using Section 24.

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate information.
• Request deletion.
• Receive a portable copy.
• Restrict or object to certain processing.
• Opt out of targeted advertising, and of the sale or sharing of personal information, where those terms are legally defined. Use our Your Privacy Choices page. We treat the Global Privacy Control signal as described on that page.
• Opt out of marketing messages.
• Withdraw consent where we rely on consent.

You can edit or delete much of your information directly in the App. To make a request, contact us using Section 24. We may need to verify your identity first, and we will respond within the time the law requires. If we deny a request, you may ask us to reconsider. We do not treat you differently for using your privacy rights.

Residents of Florida and some other states may have additional privacy rights, including rights to know, access, correct and delete personal information, and to opt out of the sale of personal information, targeted advertising or certain profiling. The state laws differ, and some apply only to businesses above certain size or data-handling thresholds. Some states, such as Washington, also provide rights about consumer health data. You may ask us to access or delete health information you added, or withdraw your consent to our use of it, by deleting it in the App or contacting us.

All data is encrypted in transit. We use reasonable administrative, technical and organizational measures to protect personal information. No online system is completely secure, and we cannot guarantee absolute security. Information on a profile that is set to public is, by design, visible to anyone who taps the product.

The Store links to and works with other companies, including Shopify, payment processors, carriers, Apple, and social media platforms. They have their own privacy policies and we are not responsible for their practices.

We are based in the United States, and the Store is intended for customers in the United States and currently ships only to addresses in the United States. If you use the Store or the App from another country, your information may be transferred to and processed in the United States and in other countries where our providers operate.

We may update this policy. We will post the new version on this page with a new "Last updated" date. For material changes that affect children's information, we will give parents direct notice and ask for consent again where the law requires.

SMART THREADS LLC
Parrish, Florida
Mailing address: 13120 Bayberry Way, Parrish, FL 34219
Contact form: the Contact Us page (goes to support@smartthreadsusa.com)
Support and privacy requests: support@smartthreadsusa.com
General business: info@smartthreadsusa.com
Phone: (941) 909-3968

For privacy questions, to make a request about your information or your child's information, or to report a concern, contact us.