SeaAir WiFi Connectivity & Data Use Disclosure

At a glance

When you connect your SeaAir controller to WiFi, your equipment sends status updates to SeaAir's cloud and can receive commands from the SeaAir mobile app. Here's what that means in plain terms:

• What we collect. Operational data from your equipment (sensor readings, status, fault codes), commands you send from the app, and connection metadata.
• What we use it for. To make the mobile app work, to show you performance metrics for your own equipment, to help you when you contact us for support (including the in-app Help Beacon), and to improve our products.
• What we don't do. We don't sell your data. We don't share it with advertisers. We don't combine it with outside data to profile you.
• Who sees your data. You, through the app. Our support staff, only when you ask for help and only as much as we need. Our cloud infrastructure provider (Amazon Web Services), acting as a processor on our behalf.
• How long we keep it. Stream data is held in a rolling window; older records are automatically purged as newer ones come in. Account information persists while your account is active.
• How to stop. WiFi is optional. Disconnect your controller from WiFi at any time and the device immediately stops sending data to SeaAir. Stream data already stored ages out automatically.

The full disclosure follows.

1. What this disclosure covers

This disclosure explains how SeaAir ("SeaAir," "we," "our," or "us") processes data when you choose to connect your SeaAir controller to a WiFi network and use SeaAir's connected features (the "WiFi Feature"). It supplements, and should be read together with, the SeaAir Privacy Policy and SeaAir Terms of Service.

If anything in this disclosure conflicts with the Privacy Policy or Terms of Service on a topic specifically addressed here, this disclosure controls for the WiFi Feature.

2. The WiFi Feature

The WiFi Feature lets your SeaAir controller communicate with the SeaAir mobile app and our cloud infrastructure over the internet. With the WiFi Feature on, you can:

• Monitor your equipment remotely from the SeaAir mobile app
• Send commands to your controller from the SeaAir mobile app
• View performance metrics and history for your own equipment
• Use the in-app Help Beacon to request support from SeaAir, with relevant context attached

The WiFi Feature requires that your controller send and receive data through SeaAir-operated infrastructure hosted in the United States. Specifically, your controller publishes status updates to a message stream we operate, and the mobile app reads from and writes to that same stream.

3. Data we process when the WiFi Feature is on

While the WiFi Feature is active on your controller, the following categories of data are sent to and processed by SeaAir:

Equipment operational data. Status messages from your controller, including sensor readings, operating mode, runtime, fault codes, configuration values, and similar telemetry generated by your equipment.

Commands and control inputs. Commands you issue from the SeaAir mobile app (for example, mode changes, setpoints, or remote actions) and the controller's acknowledgments of those commands.

Connection metadata. Timestamps, controller identifiers, firmware version, mobile app version, and similar metadata necessary to route messages, diagnose problems, and maintain service quality.

Account identifiers. The account identifier we use to associate your controller with your SeaAir account so that only you can see your equipment's data in the app.

We do not intentionally collect, through the WiFi Feature:

• Audio, video, photos, or other media from your phone or any non-SeaAir device
• Contents of your text messages, email, or other apps on your phone
• Real-time location of your phone (location data, if any, comes only from what you provide during setup or from your equipment if it is location-aware)
• Financial account numbers, payment card information, government identifiers, or health information
• Data from any device that is not your SeaAir controller

4. How we use this data

We use the data described in Section 3 for the following purposes, and only these purposes:

1. Operating the WiFi Feature. Routing messages between your controller and your mobile app, maintaining session state, and delivering the connected experience.
2. Showing you your own equipment's performance. Producing the analytics, history, and metrics you see in the SeaAir mobile app and any associated customer-facing dashboards. Each customer sees only their own equipment's data.
3. Customer support. When you contact SeaAir for help — including by phone, email, or by raising the in-app Help Beacon — our support team may review recent operational data and command history from your controller to diagnose problems and assist you. Our support team identifies your account through a separate secure lookup against our identity provider (Amazon Cognito); the message streams themselves do not contain your name, email, or other direct personal identifiers.
4. Product, algorithm, and service improvement. We analyze operational data — typically in aggregate, and on an account-segregated basis when individual review is needed for diagnosis — to improve our firmware, algorithms, mobile app, cloud infrastructure, and product roadmap.
5. Security, fraud prevention, and legal compliance. Detecting abuse of our systems, protecting our infrastructure, and complying with applicable laws and lawful requests.

We do not:

• Sell your data
• Share your data with advertisers or data brokers
• Use your data to send you marketing on behalf of third parties
• Combine data we collect through the WiFi Feature with data acquired from outside SeaAir to build a behavioral or marketing profile of you

5. Legal basis: your consent

For users in jurisdictions where consent is the relevant lawful basis (including the European Economic Area, the United Kingdom, and U.S. states with comprehensive privacy laws such as Florida, California, Colorado, Connecticut, Virginia, and others), our processing of your data through the WiFi Feature is based on your consent, given by:

• Affirmatively enabling the WiFi Feature on your SeaAir controller, and
• Acknowledging the in-app consent prompt that links to this disclosure.

You can withdraw consent at any time. See Section 8.

6. How we identify you for support

The message streams that carry your equipment's operational data are keyed by controller identifier and account identifier — not by your name, email address, or phone number. Direct personal identifiers (such as your email address) are stored in our identity provider (Amazon Cognito), separate from the message streams.

When you contact SeaAir for support — for example, by raising the in-app Help Beacon — our support team performs a secure server-side lookup that resolves your account identifier to the email address on file. This lookup happens only when needed for the support interaction. We do this so that:

• Your equipment's operational data is not sitting in our message infrastructure tagged with direct personal identifiers
• Our support team has the minimum information needed to help you when you ask for help

7. Retention and automatic deletion

Message stream data. Operational data, commands, and connection metadata flowing through SeaAir's message streams are retained in a rolling window. As newer messages arrive, older messages are automatically purged. The size of this window is set by SeaAir for operational and reliability reasons and may change over time. In practice, this means that data sent through the WiFi Feature is automatically deleted from our message streams within a bounded period of time without any action required from you.

Help Beacon records. When you raise an in-app Help Beacon, a short summary of the request (controller, time, your message, and your account identifier) is retained for up to 24 hours so that support staff can act on it. After that, it is automatically deleted unless we have separately escalated it into a longer-lived support ticket as part of helping you.

Account information. Information associated with your SeaAir account (such as your email address and account preferences) is retained while your account is active and for a reasonable period afterward to handle warranty, support, and legal obligations. Account-level retention is described in the SeaAir Privacy Policy.

Aggregated and de-identified data. Data that has been aggregated or de-identified such that it can no longer reasonably be linked to you may be retained for product, analytics, and research purposes for longer periods, including after you stop using the WiFi Feature.

8. Your choices and controls

Turning the WiFi Feature off. You can disconnect your SeaAir controller from WiFi at any time, through your controller or through the SeaAir mobile app. Once your controller is no longer connected to WiFi, it stops sending data to SeaAir. The connected features of the mobile app will no longer be available for that controller until you reconnect.

Effect of disconnecting. Stream data that was already stored before you disconnected continues to age out under the retention rules in Section 7 and is not retroactively deleted on disconnection. If you want all stored data associated with your controller deleted sooner than the rolling-window purge, contact us using the contact information in Section 12.

Withdrawal of consent. Turning off the WiFi Feature constitutes withdrawal of your consent to the processing described in this disclosure with respect to data that has not yet been collected. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

9. Service providers

We use a small number of service providers ("processors") to operate the WiFi Feature. They process data only on our instructions and under contractual data protection commitments. They include:

• Amazon Web Services, Inc. (AWS): cloud hosting, message infrastructure (Amazon ElastiCache, Amazon DynamoDB, Amazon SNS, AWS App Runner), identity (Amazon Cognito), and email delivery for transactional notifications. AWS resources we use are hosted in the United States.

10. Your privacy rights

Depending on where you live, applicable law may give you specific rights regarding your data, including:

• Right of access. Request a copy of personal information we hold about you.
• Right to correct. Ask us to correct inaccurate personal information.
• Right to delete. Ask us to delete personal information we hold about you.
• Right to opt out of sale or targeted advertising. SeaAir does not sell personal information or use it for targeted advertising as those terms are defined under U.S. state privacy laws, but you have the right to confirm this.
• Right to data portability. Request a copy of certain information in a portable format.
• Right to withdraw consent. As described in Section 8.
• Right to non-discrimination. We will not deny you service or charge you a different price for exercising any of these rights, except as permitted by law.

To exercise any of these rights, contact us using Section 12. We may need to verify your identity before acting on your request. If we deny a request in whole or in part, we will tell you why and how to appeal where applicable.

Florida residents: Under the Florida Digital Bill of Rights, you may have additional rights, including the right to opt out of the processing of personal data for purposes of profiling that produces legal or similarly significant effects. SeaAir does not use your data for such profiling.

California residents: Under the California Consumer Privacy Act (as amended by the CPRA), you also have the right to know the categories of personal information collected, the categories of sources, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it — all of which are addressed above.

EEA / UK residents: You also have the right to lodge a complaint with your local supervisory authority.

11. Children

The WiFi Feature is not directed to children, and we do not knowingly collect data from children through the WiFi Feature. If you believe a child has provided data to us, contact us and we will delete it.

12. Contact us

To exercise privacy rights, ask questions about this disclosure, or request deletion of stored data:

• Email: info@seaair.com
• Phone: (954) 256-5588

13. Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect data sent through the WiFi Feature, including encryption in transit (TLS) for connections between your equipment, our cloud, and the mobile app; authentication on every API call; and access controls that limit which SeaAir personnel can see customer data. No method of transmission or storage is perfectly secure; we cannot guarantee absolute security.

14. Changes to this disclosure

We may update this disclosure from time to time. If we make material changes — for example, expanding the categories of data we collect or the purposes for which we use it — we will notify you through the SeaAir mobile app, by email, or by another reasonable means before the change takes effect. The "Last Updated" date at the top reflects the most recent revision.

If a material change requires renewed consent under applicable law, we will ask for it before processing your data under the new terms.

15. Definitions

• "Controller" — your SeaAir-manufactured marine equipment controller.
• "WiFi Feature" — the cloud-connected functionality available when your Controller is connected to a WiFi network and registered to your SeaAir account.
• "Help Beacon" — the in-app feature that lets you raise a support request to SeaAir directly from the mobile app.
• "Operational data" — sensor readings, status, fault codes, configuration values, and similar machine-generated telemetry produced by your Controller.

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