Silver Spring Networks Global Data Privacy Policy

Updated: February 27, 2012

Global Data Privacy Policy Statement

This Privacy Policy covers the collection, storage, and processing of personally identifiable information by Silver Spring Networks and its affiliates (“Silver Spring”) and applies to all of the products, services, and websites provided by Silver Spring.

Introduction and Policy Goals

We recognize the importance of protecting and managing personal information provided to us. Privacy regulations touch almost every aspect of our business: the way we transfer information between employees, information stored and processed in our network operations center, and the way that we handle information obtained from those accessing our external websites.

Applicability: Who Must Follow the Policy?

To serve the goals of protecting our company, our suppliers, and our utility customers, all employees and contractors of Silver Spring Networks must follow this policy when collecting, storing, or processing personally identifiable information.

Exceptions

Each employee of Silver Spring must adhere to this Policy. Managers are responsible for ensuring that reporting employees are familiar with the Policy and follow the Policy. Unless specifically noted, exceptions to the Policy require prior written approval from Silver Spring’s General Counsel.

Policy

Information we collect or process, and how we use it.

Silver Spring does not collect personally identifiable information about you unless you voluntarily submit that information to us by email, through our websites, or by other means.

We collect and process human resources information.

Silver Spring maintains records of current, former and prospective employees, and contingent workers (including temporary workers and other non-employees). We use this information to manage and maintain our employee workforce, to conduct our business, and to ensure the safety and protection of our employees and other workers. Silver Spring processes and stores personal information in our files and on our servers in the United States. In some cases, we process and store personal information outside your country of residence.

We collect and process information related to our utility customers, partners, and facilities.

We maintain utility customer and business partner records. We use this information to perform analysis against these records and to perform various utility customer services activities and partner relationship development activities. We use this information to meet our obligations to customers and partners, to support our relationships with customers and partners, and to assess Silver Spring’s performance.

We monitor access to each of our facilities by requiring guests to sign in at reception, by requiring staff to use badges for entry, and by using closed circuit television. We collect this information to ensure the protection of our trade secrets and to ensure the safety of our employees and other workers.

We process energy consumption information.

Silver Spring provides smart grid networking products and services to utility companies to help them transmit and analyze energy consumption data. These products and services may be provided via (1) utility customer premise software and hardware products managed by the utility customer, (2) utility customer premise software and hardware products managed remotely by Silver Spring (“Managed Services”), or (3) hosted Software-as-a-Service (SaaS) products.

For Managed Services offerings, Silver Spring typically manages energy consumption data remotely, with the data remaining at the utility customer’s facilities. For SaaS offerings, Silver Spring manages hardware and software networking products, including all related energy consumption data, on behalf of its utility customers. In connection with these SaaS offerings, Silver Spring receives information transferred from the utility customers’ locations (including locations in the European Union) to Silver Spring’s systems in the U.S.

Silver Spring acts as a processor on a utility customer’s behalf when Silver Spring stores energy consumption data in Silver Spring’s systems. The data is owned and controlled by Silver Spring’s utility customers, and Silver Spring acts solely as a data processor relating to the data. Silver Spring processes energy consumption data to deploy a broad set of smart grid initiatives for utilities and for consumers. Please refer to our website for more information about our products and solutions.

We collect and process information on your use of our websites.

We may collect information relating to your use of our websites through the use of analytics technologies. For example, we may automatically collect certain non-identifying information about you, such as the domain name that referred you to our site, the type of browser you use, the length of time you remain at the website, and your IP address. If your IP address is associated with a computer owned by Silver Spring then this information may be used to identify you. This information helps us gather statistics about the effectiveness of our websites and to help us tailor our interactions with you.

We may also collect information about the pages you view within our websites and your interaction with our websites. We collect this non-identifying information internally to help us analyze the effectiveness of our websites and enhance our websites’ utility to you.

In addition, we may also use web technologies to determine whether you have opened an e-mail or clicked on a link contained in an e-mail or to confirm your attendance at Silver Spring events. Collecting information in this manner allows us to collect statistics about the usage and effectiveness of our websites, which enables us to tailor our web-based interactions with you.

Silver Spring offers utility customers access to its online customer engagement portal, CustomerIQ. To provide access, Silver Spring collects e-mail addresses and other personal information necessary to establish a user account. Silver Spring acts at the direction of its utility customers in establishing and managing these user accounts.

No online advertising

Silver Spring does not deliver third party online advertisements on its Websites.

Consent to other information sharing

If we use the information described above in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use. However, we reserve the right to share your personal information with governmental authorities (in response to authorized requests for this information) or when otherwise required to do so by law.

Information security

We intend to protect your personal information and to maintain its accuracy. We take appropriate security measures to protect against unauthorized access to data and unauthorized alteration, disclosure, or destruction of data. Our security measures also include internal reviews of our data collection, storage, and processing practices, including appropriate technical (encryption), administrative, and physical security measures to guard against unauthorized access to systems that store personal data.

We restrict access to personally identifiable information on a need to know basis. Access is limited to Silver Spring employees, contractors, and agents who will process the personally identifiable information on our behalf. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We also require that our suppliers protect personal information from unauthorized access, use and disclosure.

Accessing and updating personal information

When you provide personal information to Silver Spring, we make good faith efforts to provide you with access to your personal information. We also make good faith efforts to maintain the accuracy of this personal information. We will either correct your personal information if it is inaccurate or delete this data at your request (unless we are required to keep it by law or for legitimate business purposes).

For example, employees can log on to our human resources website using a valid user name and secure passcode, then modify certain account information such as legal name, mailing address, telephone number, and emergency contact information. Additionally, users of our energy management web portal are able to log on to our website using a valid user name and secure passcode and then modify certain account information.

Compliance and enforcement

Silver Spring complies with the U.S. Department of Commerce “U.S.-EU Safe Harbor Framework” regarding the collection, use, and retention of personal information from European Union member countries. Silver Spring has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. You can learn more about the Safe Harbor Privacy Principles, the Safe Harbor program, and view Silver Spring’s certification at the Safe Harbor Web site.

We regularly review our compliance with this Privacy Policy. When we receive formal written complaints, it is our policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local government data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Silver Spring and the individual.

If you have comments, questions or complaints about this Privacy Policy please contact us at privacy@silverspringnet.com or write to us at:

Privacy c/o Office of the General Counsel
Silver Spring Networks, Inc.
555 Broadway Street
Redwood City, California 94063 USA.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time but will not reduce your rights under this Privacy Policy regarding data we collect from you without your consent. We will post any Privacy Policy changes on this page and if the changes are significant we will provide a summary of the changes.