Particle Products Privacy Addendum
A Supplement to the Digi International Inc. Privacy Policy
Purpose and Scope
The Digi International Inc. Privacy Policy available at https://www.digi.com/legal/privacy (the “Corporate Policy”) states that it applies to all Digi products and services “except those Products that have a separate Privacy Policy.” This Addendum is that separate policy for Particle-branded products and services (the “Particle Products”), including the Particle Web IDE, the Particle Device Cloud, Particle Console, and any physical hardware products shipped by Particle that connect to these services.
This Addendum supplements, and does not replace, the Corporate Policy. Except as expressly modified below, the Corporate Policy — including its sections on Your Choices, Your Rights, Third Party Websites and Services, Safeguarding Your Information, Privacy Obligations for Minors, and the general EEA/UK provisions — applies in full to the Particle Products. Where this Addendum and the Corporate Policy conflict as applied to the Particle Products, this Addendum governs.
Particle’s Role: Controller and Processor
The Corporate Policy describes Digi as determining how Personal Information is used, in the role of a data controller. For the Particle Products, this is only sometimes accurate, and the distinction matters because it determines who is responsible for responding to a given privacy request.
Particle as controller
Where Particle collects Personal Information directly from an individual — for example, through account registration, a hardware purchase, or a marketing sign-up — Particle acts as a data controller (or, under the CCPA, a “business”), and this Addendum and the Corporate Policy apply directly.
Particle as processor
Where an enterprise customer uses the Particle Device Cloud to operate its own connected-device product or service, Particle acts as a data processor (or, under the CCPA, a “service provider”) on that customer’s behalf. In this role, Particle does not determine the purposes of processing and cannot independently respond to end-user privacy requests concerning that data. Individuals with such requests should direct them to the relevant enterprise customer, who will coordinate with Particle as needed.
This controller/processor distinction, and the associated request-handling process, is a departure from the Corporate Policy as generally written and applies specifically to the Particle Products.
Categories of Personal Information Collected
In addition to the categories described in the Corporate Policy, the Particle Products may collect:
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Technical identifiers such as device IDs and SIM card IDs, used to operate and support connected hardware.
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Device and account geolocation information, including GPS coordinates transmitted by connected devices.
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Usernames and other account identifiers specific to the Particle Device Cloud and Particle Console.
Subprocessors
The following subprocessors support the Particle Products. This list will be reviewed and updated periodically as appropriate.
| Subprocessor | Location | Processing Purpose |
|---|---|---|
| Amazon Web Services, Inc. | Seattle, WA, United States | Hosting infrastructure |
| MongoDB, Inc. | New York, NY, United States | Hosting infrastructure |
| Stripe, Inc. | South San Francisco, CA, United States | Payment processing |
| Google, LLC (Workspace + Analytics) | Mountain View, CA, United States | Corporate email hosting and website analytics |
| Adobe, Inc. (Marketo) | San Jose, CA, United States | Marketing automation |
| Zendesk, Inc. | San Francisco, CA, United States | Support ticket tracking |
| Snowflake, Inc. | Bozeman, MT, United States | Data warehousing |
| Twilio, Inc. (Segment) | San Francisco, CA, United States | Website analytics |
| Outreach Corporation | Seattle, WA, United States | Email automation |
| Salesforce.com, Inc. | San Francisco, CA, United States | Customer relationship management |
Security Certifications and Practices
In addition to the safeguards described in the Corporate Policy, the infrastructure supporting the Particle Products maintains the following certifications and practices:
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SOC 2 Type II compliance, with an annual third-party audit.
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Hosting infrastructure audited against ISO 27001, in addition to SOC 2.
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Payment card data processed by a subprocessor audited against PCI-DSS.
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Encryption in transit between Particle hardware devices and the Particle cloud, using a modern set of cryptographic ciphers.
Data Storage Location
Personal Information collected through the Particle Products is processed and stored in the United States, using third-party Infrastructure-as-a-Service providers audited against SOC 2 and ISO 27001.
California Consumer Privacy Act (CCPA) Disclosures
For California residents, and in addition to the Corporate Policy:
Categories of personal information collected
Particle collects the following categories of information, as defined under the CCPA:
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Identifiers
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Commercial Information
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Geolocation data
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Inferences about personal preferences and attributes drawn from profiling
Do not sell or share
Particle does not sell personal information to third parties for financial gain, and does not maintain a separate opt-out page for the Particle Products beyond the mechanisms described in the Corporate Policy.
Authorized agents
A California customer may use an authorized agent to make a CCPA privacy request concerning the Particle Products. To do so, the authorized agent must provide either (a) a letter signed by the customer authorizing the agent, or (b) a valid power of attorney issued pursuant to California Probate Code sections 4000 to 4465, together with a phone number where the agent can be reached during business hours.
Particle Legal Entities
The following Particle subsidiaries support delivery of the Particle Products:
| Entity | Location | Function |
|---|---|---|
| Particle Industries (Hong Kong) Limited | Hong Kong | Service delivery and technical support |
| Padikeji Shenzhen Technology Co. | Shenzhen, China | Service delivery and technical support |
| Particle Labs México S.A. de C.V. | Nuevo León, Mexico | Service delivery and technical support |
Contact for Particle-Specific Privacy Inquiries
Privacy inquiries concerning the Particle Products may currently be directed to data.privacy@digi.com contact.
Updates to This Addendum
Digi may update this Addendum from time to time to reflect changes in the Particle Products or applicable law. Material changes will be communicated consistent with the notice provisions of the Corporate Policy.
Last updated: October 1, 2026