Privacy Policy

Community Privacy Protections

Last Updated: July 2019

As technology continues to advance, balancing its benefits against some of its inherent risks to privacy continues to be an issue which confronts us all. What’s true for technology in general is also the case in the realm of public safety. Technological advances have provided significant benefits to those tasked with keeping us safe while at the same time raising appropriate dialogue about how we can leverage those benefits while minimizing unwarranted intrusions on personal privacy.

Several police tools and technologies capture information that is already in public view: license plate readers, video cameras at stoplights and ATMs, combined video/audio surveillance cameras, facial recognition algorithms, etc. Unlike general audio and video surveillance devices, such as the tens of thousands of video cameras deployed in our nation’s cities which monitor general activities, gunshot detection technology is designed to trigger on loud explosive or impulsive sounds that may likely be gunfire and occur only rarely—and that the public already “hears”.

The company takes privacy very seriously and has structured its technology, processes and policies in such a way to minimize risk of privacy infringements while still delivering important public safety benefits.

Independent Privacy Audit

Policing Project NYU School of Law
The non-profit Policing Project at the New York University School of Law conducted an independent audit of ShotSpotter’s privacy practices in the spring of 2019. The audit concluded that “the risk of voice surveillance is extremely low.” The report notes that there are important design frameworks and operational safeguards built into how ShotSpotter operates to prevent this from happening.

“While it is surely possible that ShotSpotter sensors will, on occasion, capture some intelligible voice audio related to a gunfire incident, we have little concern that the system will be used for anything approaching voice surveillance…Other policing technology companies should follow ShotSpotter’s leadership and proactively embrace their responsibility to protect individual liberty with their products.” Barry Friedman, Policing Project Faculty Director.

Protections Prior to Activating the System

  • When ShotSpotter comes to a new city, we strongly encourage our clients to engage with their communities about the decisions to acquire and use our technology.
  • Using a data-driven approach, ShotSpotter works with our clients to determine the geographic area they want covered by ShotSpotter (i.e. the most gun violent areas).
  • When the coverage area is set, ShotSpotter engineers determine where to place sensors so as to allow even gunshot detection throughout the area. Police do not determine where to place sensors and do not have access to a database of sensor locations.
  • ShotSpotter acoustic sensors are not positioned, tuned or specialized to pick up human voices. The sensors use ordinary microphones that are similar to ones found in cellphones and are placed high above the street.

Before and During an Incident

  • Sensors “listen” for gunshot-like sounds and trigger only when detecting an impulsive sound that is instantaneous and sharp. When at least three different sensors detect a gunshot-like sound at the same time and determine a location, they send a short audio snippet to ShotSpotter headquarters.
  • Human voices and street noise will never trigger a sensor because they do not produce an instantaneous sharp sound and they are not loud enough to be picked up by three or more sensors.
  • Live streaming of sensor audio is not possible by company employees, police or third parties.
  • Upon detecting a likely gunshot, trained ShotSpotter personnel listen to a short computer-generated audio snippet of the gunfire to double check that it is actually gunfire.
  • It is highly unusual for a human voice to be included in a snippet. For this to occur, the voice must be loud enough to be heard over the gunfire. There is no personally identifiable information in any audio snippet.
  • If a snippet is determined to be gunfire, police are notified and provided with the audio snippet that contains the gunfire to better help them understand number, sequence, and caliber of rounds fired.

After an Incident

  • If ShotSpotter receives a request (including a subpoena) for additional audio beyond the gunshot snippet, the company has and will continue to fight the request.
  • Sensors store 30 hours of audio and automatically delete audio older than 30 hours. Neither police nor third parties ever have direct access to this audio.
  • Under strict conditions, ShotSpotter personnel can access this audio ONLY if presented with hard evidence that a gunshot was missed. In this case, company personnel look back at specific portions of the audio to determine if the system picked up the gunshot. If a missed gunshot is found, an audio snippet is provided to police.
  • The company made changes to the system around 2012 to prevent access to extended audio.
  • ShotSpotter never modifies the audio in any way.

Summary

In the end, we believe that the privacy of our communities and social benefits of decreased gun violence are not at odds with each other. Our ultimate goal is to ensure that both are satisfied. We believe we have taken all reasonable and necessary precautions to assure a robust and strong privacy posture. We will continue to review and revise our technology, processes and policies.

General Privacy Policy

Last modified: Tuesday, May 19, 2020

Introduction

This Privacy Policy (“Policy”) explains how your personal data is collected, used, and disclosed by ShotSpotter, Inc. and its affiliates (collectively “ShotSpotter,” “we,” “our”, or “us”) in particular, but not limited to, in connection with your use of our website located at https://www.shotspotter.com, email, text, and other electronic messages between you and this website, ShotSpotter software applications, or online services operated by ShotSpotter, (collectively, “Site(s)”), which all link to this statement.

ShotSpotter Website Terms and Conditions require all users to be at least 18 years of age. You are responsible for any and all account activity conducted by individuals under the age of 18 on your account or on your behalf.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Please check the policy periodically for updates.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (”personal information”);
  • That is about you but individually does not directly identify you, such as title, city and state, or organization; and/or
  • About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us

The information we collect may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting product information or consultation, requesting professional services, inquiring about becoming a partner, requesting support, or inquiring about investor relations. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence, including email addresses, if you contact us.
  • Information that you provide at conferences and/or tradeshows, such as contact information.
  • If you register to apply for job opportunities through our website, we will collect your name, email address and any additional application information that you submit.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically may not include personal information, but regardless of whether it does, we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit ShotSpotter, for example, to count users who have visited those pages and for other related website statistics (for example, verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some applications and services embedded within, or linked from, our website, such as links to social media platforms, are controlled by third-party providers. These third-parties may use cookies, alone or in conjunction with other tracking technologies, to collect information about you when you use our website or navigate away from our website. These third parties may also have privacy policies that differ from ours. For example, they may collect personal information about your online activities over time and across different websites, and other online services, and may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third-parties or their privacy practices, and this Privacy Statement does not apply to any third-party website or service you may access through our website. If you have any questions about a third-party provider’s privacy policies or advertising, you should contact the responsible provider directly.

Do Not Track Requests

Certain state laws require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Policy and do not monitor or follow any Do Not Track browser requests.

Linked Websites

For your convenience, some hyperlinks may be posted on the Website that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control. We cannot be responsible for the privacy practices of any such websites or pages not under our control and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website that our Website links to, even if you reached that site through the Website, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how personal information that is collected about you is used and protected.

User-Provided Content

Any information, communications, or material of any type or nature that you submit to the Website by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”) is done at your own risk. We cannot control the actions of other users of the Website and we are therefore not responsible for any Submissions contained on the Website.

Additionally, in the event that we offer a message board or any other interactive or social-type feature on the Website, please be aware that these areas may allow you to post, and share with other users, certain messages, content, or other information. We encourage you to be wary of giving out any personal information, or any personal information of others to which you may have access, in such forums. The information you post can be collected and used by other people. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.

Social Media Platforms and Websites

Any Submission that you submit to any of our pages contained on a social media platform or website by e-mail, posting, messaging, uploading, downloading, or otherwise is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of a social media platform and we are therefore not responsible for any Submissions contained on a social media platform or website. Before visiting any of our pages that are contained on any social media platform or website, you should review the applicable privacy policy and terms of use of such website or social media platform and abide by all such provisions contained therein.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  • To understand and analyze the usage trends and preferences of our users, to improve our Website, and to develop new products, services, features, and functionality.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about ShotSpotter products, services, and events that may be of interest to you. If you do not want us to use your information in this way, please contact us to opt-out of receiving this information.

Disclosure of Your Information

We do not sell or otherwise share personal information with third parties for direct marketing purposes. We may disclose personal information that we collect, or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our business or assets.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • To enable third parties to perform services on behalf of ShotSpotter including, but not limited to, payment processing, research, analytics, human resources, and security.
  • With your consent.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of sale and/or service and other agreements, including for billing and collection purposes.

Accessing and Correcting Your Information

ShotSpotter will always honor the rights to which you are entitled to by the laws of the country, state, province, territory, or commonwealth in which you reside or are located when using our services with regards to your personal data. Depending on your location, such rights may include, but are not limited to: (i) data access and portability (including the right to obtain a copy of personal data you provide to ShotSpotter); (ii) data correction; (iii) data deletion; and (iv) withdrawal of consent for processing and sharing of data. You may exercise the rights to which you are entitled by such applicable laws by contacting us.

A Note to Users Outside of The United States

If you are a non-U.S. user of the Site, not residing or located in a Member State of the European Union, by visiting the Site and providing us with personal data, you acknowledge and agree that your personal data may be processed for the purposes identified in the Policy. In addition, your personal data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal data may be less stringent than or otherwise differ from the laws of the country in which you reside or are located when using our services. By providing your personal data, you consent to such transfers.

International Transfers of Information

The United States, the Member States of the European Union (“EU”), and the other countries forming together with the EU, the European Economic Area (EEA), and other countries all have different laws. When your personal data is transferred from the country in which you reside or are located when using our services to another country, the laws that govern your personal data in the country to which your personal data is transferred may be different from those in the country in which you live.

Your California Privacy Rights

In you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, please visit our California Consumer Privacy Act notice.

Data Security

We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to our products, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on our website. If we make material changes to how we treat personal information that we collect from you, we will notify you by email or through a notice on the Website home page, or through another reasonable form of notice. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

CCPA Privacy Notice

Effective Date: Friday, November 15, 2019
Last Reviewed on: Tuesday, May 19, 2020

This Privacy Notice for California Residents supplements the information contained in ShotSpotter’s General Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

The great majority of our customers are law enforcement agencies, and therefore when we share any information in our business, the great majority of it is with law enforcement agencies concerning conduct or activity that may violate local law, an exception to the CCPA. Please refer to the ShotSpotter Community Privacy Protections policy for more information on privacy and our technology.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, we have collected the following categories of personal information from consumers within the last 12 months:

Category Examples
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, or email address.
B. Internet or other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
C. Geolocation data. Physical location or movements.
D. Sensory data. Audio or similar information.

ShotSpotter obtains the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from information requests you complete, products and services you purchase, or through authorization forms you provide to partner with our company.
  • Indirectly from you. For example, through information we collect from our clients in the course of providing services to them.
  • Directly or indirectly from activity on our website ( https://www.shotspotter.com ). For example, from submissions through our website portal or website usage details collected automatically.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery.
  • To provide you with information, products or services that you request from us.
  • To provide you with email alerts, event registrations, and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To create, maintain, and secure your account with us.
  • To improve our website and present its contents to you.
  • To contact and interact with you as necessary when you have partnered with us to locate company equipment on your property.
  • To cooperate with law enforcement agencies concerning conduct or activity that ShotSpotter reasonably and in good faith believes may violate federal, state, or local law.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • To carry out our obligations and enforce our rights arising from any contracts entered between you and us, including for billing and collections.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

ShotSpotter will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

ShotSpotter may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal contact information in connection with the installation, maintenance, and removal of our equipment at your facilities.

Sales of Personal Information

In the preceding twelve (12) months, we have not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please utilize one of the methods listed under Contact Information.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

We do not sell any personal information.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Changes to Our Privacy Notice

ShotSpotter reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Opt Out from ShotSpotter Communications Request Form

CCPA Data Rights Request Form

Phone: 1-888-274-6877, option 4