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Privacy Policy for Software and Mobile Application

Effective Date: April 7, 2021

Last Reviewed: December 22, 2020

General Privacy Policy for Software and Mobile Application


dormakaba USA Inc. (“We”, “Us”, or “Our”) respects your right to privacy and are committed to following applicable data protection rules to safeguard your rights when you use Our website (the “Website”),  software which is licensed by Us to you (hereinafter the “Software”) and/or Our mobile application (“Mobile App”). This Privacy Policy (“Policy) aims to inform you about the type of information We may collect about you (“Data”), how it is collected, used, disclosed and stored; and how We protect it. The Policy applies to Our Software, Switch Tech and other related access control products and services offered through the Website, Mobile App or by phone, and any other website or mobile application that utilizes this Policy.

Please read the Policy carefully to understand Our policies and practices regarding your Data and how We will treat it. If you do not agree with Our policies and practices, do not use the Software or Mobile App and do not provide us with any Data and discontinue using the Website. Any person whether on his own behalf, or on behalf of a legal entity who accesses or uses the Software, Website or Mobile App is subject to this Policy. By accessing or using the Website, Software or Mobile App, you agree to the terms of this Policy. Please be assured that We will only use your personal Data in accordance with this Policy.

A. Information regarding the collection of Data

(1) Data We Collect

We may collect various types of Data, including information that identifies or may identify you as an individual, as explained in more detail below.

From Website and/or Software: When you access our Website, we may collect your identifiers (such as your real name, alias, postal address, telephone and facsimile numbers, unique personal identifier, online identifier, Internet Protocol address, email address, account name, title, name of the company, vertical market, type of the company, login credentials, or other similar identifiers); personal information (such as your name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information); commercial information (such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies); device information (such as operating system and its interface, browser, language and version of browser software); Internet or other similar network activity (such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement); geolocation data (physical location or movements, such as which doors were accessed at a location by a user identified through their Mobile App); sensory data (audio, electronic, visual, thermal, olfactory, or similar information such as thermal data from the Switch Cores); and inferences drawn from other personal information (such as profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes).  When you register for access and/or use of our Software, we may collect the above-identified categories of Data as part of the registration process for certain areas of the Software. For example, users’ mobile phone numbers are linked to the user badge number stored in your access control software. We do not know the name or personal Data tied to the user’s mobile phone number.

From the Mobile App: When you access our Mobile App, in addition to the categories and types of Data identified in the subsection From Website and/or Software above, we may collect Data about your mobile device (such as operating system/iOS Version and type of hardware of the mobile device). The Mobile App is downloaded to your mobile device and can be used without access to the Internet, possibly with limited functionalities. When you use the Mobile App, user event Data is logged.

(2) Period of Retention And Use

We endeavor not to retain Data in an identifiable and non-anonymized form for longer than necessary in relation to the purposes for which they are processed or for as long as we maintain an ongoing relationship with you related to the Website, Software or Mobile App, plus the duration of any applicable statute of limitations period in which we may be subject to a legal claim. If any claim, legal process, or enforceable government request is brought, we may continue to retain your Data for an additional time as necessary to protect our legal interests or to comply with any applicable law, regulation, legal process or enforceable governmental request.

We reserve the right to and may retain Data about you beyond the above retention criteria for statistical purposes, and Data retained for such purposes will be in anonymized form that is not identifiable to you.

The Mobile App uses anonymous analytics data to analyze and regularly improve the use of Our Mobile App. Examples may include but not be limited to, information about a user changing screens or pressing buttons.

(3) Data Transmission

Your personal data may be stored by Us or by a third-party provider contracted by Us. To provide you with the services you request as part of your use of the Website, Software and/or Mobile App, we may store, process, and transmit data in the United States and locations around the world—including those outside your country. We use appropriate physical, technical and organizational measures to protect any Data we hold in our records against unauthorized access or use and against accidental loss or destruction.  If We transfer your personal data to third-party providers and/or abroad (or your personal data is accessed from abroad), We will take all reasonable measures to ensure reasonable security for your personal data (e.g. careful evaluation of third-party providers, flow down of confidentiality provisions, use of data processing agreements, etc.).  Data may also be stored locally on the devices you use to access the Website, the Software and the Mobile App.

B. User Access Controls

You are responsible for managing user access controls within the Software and the Mobile App. You define the usernames, roles, and password characteristics (length, complexity, and expiration timeframe) for your users subject to Our requirements. You are entirely responsible for any failure by you, your agents, contractors or employees (including without limitation all of your users, Administrators and installers, to maintain the security of all usernames, passwords and other account Data under your control. Except in the event of a security lapse caused by Our gross negligence or willful action or inaction, you are entirely responsible for all use of the Software or Mobile App through your usernames and passwords, whether or not authorized by you, and any charges resulting from such use. You will immediately notify Us if you become aware of any unauthorized use of the Software or Mobile App.

C. Use and Disclosure of Data

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.
  • To provide support services to you or the owner/customer of the Switch Tech account, which you or the owner/customer of the Switch Tech account have requested.
  • To create, maintain, customize your account and deliver your registration key to your mobile device.
  • To process your requests, purchases, transactions (including any referrals from our service providers, distributors, product integrators, resellers, including independent sales representative agencies, partners), and payments and prevent transactional fraud.
  • 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 improve our services to you.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Website, products, and services and to identify trends in various industries.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To meet our obligations and enforce any of our rights that arise from or are related to agreements between you or us.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of our Switch Deck Website and Switch mobile app users is among the assets transferred.

We 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.

Our use of your Personal Data may be based on our legitimate need for your Personal Data in order to provide you with use of the Software and Mobile App, as stated above, or you consenting to it (e.g. when you request a demo). To the extent that your Data is used to improve and develop new products and services or to maintain and manage the Website, Software and Mobile App and other related services, We base Our use of your Personal Data on Our legitimate interest to perform such actions.

D. Sharing Data with Third Parties

We do not sell or trade Data in exchange for monetary or other valuable consideration. We share and disclose Data (including personal Data) about our users in the following limited circumstances:

  • Service providers: We may share your Data with third-party vendors, contractors or other suppliers We use for the purposes of providing, operating and maintaining the Website, Software and/or Mobile App. These companies include (for example) our payment processing providers, website analytics companies (e.g., Google Analytics), product feedback or help desk software providers (e.g. Salesforce), CRM service providers (e.g., Pardot/Salesforce), email service providers, and others.
  • Our distributors, resellers, partners which have a contract with you or your account owner. In particular, Company has disclosed your personal information to its reseller(s) to follow up in relation to customer inquiries for the products.
  • We may disclose your personal Data in order to enforce our Terms of Use and Service, or the Mobile App Terms of Use Agreement, or this Policy, or in urgent circumstances to protect personal safety, safety of the public or Our services and products. It is also possible that We may be required by law to disclose your personal Data pursuant to judicial or other government subpoenas, warrants, or orders, potentially, in any location where We do business.

E. Your Privacy Rights

You can always opt not to disclose Data to us, but keep in mind some Data may be needed to register with us or to take advantage of the Software and the Mobile App, or to provide you with  other services that you request.

The California Consumer Privacy Act – if you are a California resident

If you are a California resident, California law may provide you with additional rights regarding Our use of your personal Data. This includes the rights to request access or deletion of your personal Data. To learn more about your California privacy rights, visit CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS at

F. Correcting, Updating and Removing Personal Data

If a user’s personal Data changes or is incorrect, please contact Us or your administrator  so that  they may make any necessary updates or corrections. Additionally, in the event that a user of the Software or Mobile App provides personal Data and later wishes to have Us remove the personal Data, please contact [email protected]  in order to do so.

G. Data Security and Integrity

We have implemented physical, technical and organizational measures designed to secure your personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. However, We cannot guarantee that any accidental loss, unauthorized use, alteration, destruction, disclosure or retention will or will not occur, and We make no representations to this effect. We also cannot (and do not) make any guarantees or representations with respect to, or assume any responsibility for, the security of any devices not provided by Us (including your personal cellular device or computer), any infrastructure or materials not exclusively controlled by Us or with respect to the internet in general. Unfortunately, the transmission of Data via the internet and mobile platforms is not completely secure. Although We take reasonable security measures to protect your personal Data, We cannot guarantee the security of your personal Data transmitted through Our Software or Mobile App. Any transmission of personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures We provide.

The safety and security of your Data also depends on you. Where We have given you (or  where you have chosen) a password for access to certain parts of Our Mobile App or Software, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

H. Cookies & Similar Technologies

Our Website uses cookies (small text files placed on your device) in order to remember information about you, such as your preferences, settings and login information.

We collect the following data that we require from a technical point of view to display the Website to you and guarantee its stability and security:

  • IP address
  • Date and time of inquiry
  • Time zone difference to Greenwich Mean Time (GMT)
  • Content of request (specific page)
  • Access status/HTTP status code
  • Volume of data transmitted
  • Website from which the request originated
  • Browser
  • Operating system and its interface
  • Language and version of browser software.

You have a variety of tools to control cookies, including browser controls, to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection. Your browser and other choices may impact your experiences with our products.

I. Data Collected Through Google Analytics

We use a tool called “Google Analytics” to collect Data about use of the Website. Google Analytics collects Data such as how often users visit the Website and what pages they visit when they do so. We use the Data we get from Google Analytics only for the purposes outlined in this Policy. Google Analytics does not collect your name or other identifying information. We do not combine the Data collected through the use of Google Analytics with personally identifiable. Although Google Analytics plants a permanent cookie on your device to identify you as a unique user the next time you visit our Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share Data collected by Google Analytics about your usage of the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. For more information on how Google uses data when you use our Website, click here, and opt out of Google’s practices by downloading the Google Analytics opt-out browser add-on, available here.

J. Data Collected Through Hotjar Analytics

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this Data on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf.

For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.”

K. Children

We do not knowingly collect or solicit personal Data from anyone under the age of 18. We do not intend that the Software or Mobile App will be accessed or used by children under the age of 18, and such use is prohibited. Please do not attempt to obtain access to the Software or Mobile App or send any Data about yourself to us. We will promptly delete Data associated with any account for which We obtain actual knowledge that the registered user is not at least 18 years old. If you believe that a child under 18 may have provided us Data, please contact us at [email protected].

L. Updates to this Policy

We may, in Our sole and absolute discretion, modify this Policy from time to time. We will alert you to material changes by, for example, by providing  a prominent notice to you through the Software application or Mobile App, or posting it on the Website in a manner that will allow you to exercise your privacy rights. You can see when this Privacy Policy was last updated by checking the date at the top of this page. If you object to any such changes, your sole recourse shall be to cease using the Software or Mobile App. Your continued use of the Software or Mobile App after We revise this Policy indicates your acknowledgement of such changes and agreement with such changes. You are responsible for periodically reviewing this Policy.

M. Contact Us

If  you  have   any   questions, requests   or   concerns   regarding   Our   Policy, your privacy and rights,   please   contact   us  at: [email protected].