Legal & Privacy

Placement Assistant App

Last updated: April 9, 2026

Notice of Data Sharing

We share your Information with selected third parties, including:

Internet Service Provider Customers of Saffron

The internet service provider that is providing you with internet services via the 4G/LTE/5G Gateway device as with respect to which you are using the Saffron Placement Assistant App is a customer of Saffron. When you use the Saffron Placement Assistant App, we share the following personal data about you with your internet service provider: any redemption code provided to you by your internet service provider, the date you redeemed such code via the App Services, and your 4G/LTE/5G Gateway's device identification information (i.e., IMEI number) (collectively, the "Provider Requested Information"). Upon your internet service provider's receipt of your Provider Requested Information from Saffron, your internet service provider becomes a data controller of your Provider Requested Information in its workspace; please see your internet service provider's privacy policy for information about its privacy practices. Note further that, in collecting the Provider Requested Information, Saffron will also collect the admin password associated with such Gateway device in order to enable the operation of the Saffron Placement Assistant App. Such admin password is set by your internet provider or the Gateway device's manufacturer (the "Default Code"). In the event you or someone else has updated or otherwise modified the Default Code with a different code (each, a "Replacement Code"), the Saffron Placement Assistant App will require that you provide the Replacement Code prior to the Saffron Placement Assistant App being able to communicate with such Gateway device. Saffron does not provide the Default Code and/or the Replacement Code associated with the Gateway to your internet service provider. Indeed, Saffron does not retain or otherwise store the Default Code or Replacement Code, as applicable, on its systems. For Saffron's purposes, then, the Default Code or Replacement Code remains on your mobile phone and not in Saffron's systems.

Vendors and Service Providers

We rely on vendors and service providers for the provision of the App Services, including:

• Cloud service providers who we rely on for data storage, including Microsoft Azure and Amazon Web Services which are based in the U.S. and Google Cloud.
• Customer support solution providers, who help us manage and respond to our customer questions and complaints and triage issues. This includes Zendesk Inc., which is based in the U.S. and which hosts our customer support function.
• AI Service Providers. We may disclose information we receive to vendors that provide artificial intelligence services that provide backend support for our App Services.
• Analytics providers. We work with a number of analytics, segmentation and mobile measurement service providers who help us understand our user base. This includes Google LLC, which is based in the U.S. You can learn about Google's practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Communications platform providers, who help us manage and send newsletters to you in relation to the App Services. This includes Constant Contact, which is based in the U.S.

Law Enforcement and Legal Authorities

We disclose Information to law enforcement agencies, public authorities or other judicial bodies and organizations if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).

Change of Corporate Ownership

If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

With Your Consent

We may also disclose your information with your permission.