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Privacy Policy for Software and Mobile Application

Effective: 2/18/2020

Last Reviewed on: 2/18/2020

Last Modified on: 2/18/2020

General

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 software which is licensed by Us to you ( hereinafter the “Software”) or Mobile App. We want to make sure that you understand the type of information We collect about you, how it is used and how We protect it.

This Policy does not apply to information collected by Us offline, through any third party, including through any application content (including advertising) that may link to or be accessible from or on the Software or Mobile App.

This privacy notice describes the personal information We collect about you from Our Software or Mobile App, as may apply to your use access of either Our Software or Mobile App, which may include your name, address, email address, user behavior, mobile telephone number (“Data”) and how that Data is treated and for what purposes We may share the Data and how you can contact Us about your Data.

Please read the 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, do not use the Software or Mobile App. Any person whether on his own behalf, or on behalf of a legal entity who accesses or uses the Software or Mobile App is subject to this Privacy Policy. By accessing or using the Software or Mobile App, you agree to the terms of this Privacy Policy. We may, in Our sole and absolute discretion, modify this Privacy Policy from time to time by sending a notice through the Software application or Mobile App. 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 Privacy Policy indicates your acknowledgement of such changes and agreement with such changes, so please check the Privacy Policy periodically for updates.

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. We will promptly delete information associated with any account for which We obtain actual knowledge that the registered user is not at least 18 years old.

A. Information regarding the collection of personal information

(1) In the following, We provide information regarding the collection of personal data when using the Software or Mobile App. We collect personal information from users of the Software and/or Mobile App. We may collect basic contact information such as name, address, e-mail address, login credentials, demographic data, usage information, telephone and fax numbers. We may collect such personal information as part of the registration process for certain areas of the Software or Mobile App. 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 information tied to the user’s mobile phone number. We may also collect personal information when users submit comments or other messages to Us through Our website.

(2)When using the Mobile App, we collect the personal data described below:

  • Mobile number,
  • Operating System /iOS Version,
  • Hardware type mobile phone,
  • Email address

(3) Period of Retention And Use

Backups of stored data (access rights) remain in place until the data is deleted by the customer/ account owner at which point they are deleted from backups 90 days later. User event data is deleted or anonymized at 90 days whereas non-attributable /anonymized data is kept indefinitely. The duration of these timelines is subject to technical and/or organizational reasons. We will retain the Data for as long as is necessary for the relevant activity related to Software or Mobile App or for as long as We are lawfully required to do so.

{3.1) The Data will be deleted or anonymized if:

i) the purpose of collection and use of Data has been achieved (as described above);

ii) the business related to the Software or Mobile App is discontinued (if earlier than achievement of the purpose as stated above); or

iii) in relation to Data used only for purposes not directly related to providing the Software or Mobile App to you (as mentioned in Section D below) if you request that your Data is deleted by contacting Us (for contact information please see Section I below).

(3.2) Anonymous information used purely for statistical purposes may be stored for a longer period than set out above.

The Mobile App uses anonymous analytics data to analyze and regularly improve the use of Our Mobile App.

Data called up are, such as (but not limited to):

  • changing screens,
  • pressing buttons

The legal basis for the use of analytics data is Clause 6 (1) (f) GDPR. You can object to sending your personal data with effect for the future by clicking on the “Cancel” button during the installation of the Mobile App. It is to be noted that if you “Cancel” the installation of the Mobile App, you may not use the Mobile App.

{3.3) 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.

(4) Data Transmission

Your personal data will be stored on a secure server space maintained by Us or a third-party provider contracted by Us. If We transfer your personal data abroad (or your personal data is accessed from abroad), including jurisdictions that may not have an adequate level of data protection, We will take all necessary measures to ensure sufficient data protection for your personal data (e.g. careful evaluation of third-party providers abroad, flow down of confidentiality provisions, conclusion of data processing agreements etc.). We use appropriate technical and organizational measures to protect your personal data against unauthorized access or use and against accidental loss or destruction (and shall procure that third-parties provider contracted by Us will do so).

(i) When contacting Us by e-mail or using a contact form, the data you supply (your e-mail address, your name and phone number if necessary) are stored by Us in order to answer your questions. We delete the data gathered in this regard once storage of such data is no longer required, or limit processing of such data should statutory storage obligations  apply.

(ii) Should We require Our authorized  service providers to  carry out individual  functions of Our offering or should We like to use your data for commercial purposes, We shall inform you in detail of the respective actions. In doing so, We shall also inform you of the defined criteria  regarding duration of storage.

B. Collection of Usage Information and data when using the Software or Mobile App

dormakaba or its authorized  suppliers  collects information  and data that you or your  users submit, post or otherwise transmit when using the Software or Mobile App. Third party vendors may also collect information and data. You hereby grant to Us a non-exclusive, royalty-free, worldwide license to reproduce, distribute, modify, prepare derivative works of and otherwise use and display your data in connection with your use of the Software or Mobile App. Your  data that  We de-identify  and aggregate with   other data, all  Software  or Mobile  App usage data, and all other  data relating to  the performance of Software or Mobile App, is Our data that We may reproduce, distribute, modify, prepare derivative works of  and otherwise  use and display without restriction.

C. User Access Controls

You are responsible for managing user access controls within the Software including 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 information 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.

D. Use and Disclosure of Personal Information

dormakaba may use and disclose personal information for specific purposes, including without limitation:

  • For compiling aggregate statistics of the use of the Software or Mobile App;
  • For maintenance and administration of the Software or Mobile App;
  • To follow up on comments and other messages that users submit to Us through the Software or Mobile App;
  • To contractors or other third-party suppliers We use to  support Our business;
  • Other third parties, if so required to comply with mandatory law or requirements or to  address fraud or technical issues.
  • 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 of Our assets;
  • To fulfill the purpose for which you provide  it;
  • For local or foreign regulators, governments and law enforcement authorities, including tax collection agencies and stock or other exchanges;
  • For local and foreign courts, tribunals, arbitrators or other judicial committees;
  • To persons to whom We may assign or transfer Our rights or duties under this or any other agreement  We may have with or concerning you;
  • For any other purpose disclosed by Us when you provide the information; and
  • With your consent.

We do not sell or trade the Data or collect or use it for direct marketing purposes.

We base Our right to collect your Data on the need of your Data in order to provide you with use of the Software and Mobile App, as stated above. To the extent that your Data is used to improve and develop new products and services or to maintain and manage the Software and Mobile App and other related services, We base Our use of your Data on Our legitimate interest to perform such actions.

E. Legal Disclosures

We may disclose your personal information in order to enforce our Customer Terms of Use and Service, or the Mobile App Terms of Use Agreement, or this Privacy Policy, or in urgent circumstances to protect personal safety, the public or Our services and products. It is also possible that We may be required by law to disclose your personal information pursuant to  judicial or other government  subpoenas, warrants, or orders, potentially, in any location where We do business.

F. Your Rights

1. GDPR-EU

You especially have the following rights with regard to your personal data:

  • Right to access {Clause 15 GDPR),
  • Right to rectification, completion or deletion {Clause 16 and 17 GDPR),
  • Right to limit the processing {Clause 18 GDPR),
  • Right to object to the processing {Clause 6 GDPR),
  • Right to data portability {Clause 21 GDPR),
  • Right to appeal to a regulatory authority {Clause 77 GDPR).

2. California  – 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 information. To learn more about your California privacy rights, visit [HYPERLINK TO CCPA PRIVACY NOTICE FOR CALIFORNIA RESIDENTS].

G. Correcting, Updating and Removing Personal Information

If a user’s personal information changes or is incorrect, please contact 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 information and later wishes to have Us remove the personal information, please contact BAS.Support.Best.US@dormakaba.com in order to do so.

H. Data Security and Integrity

We have implemented measures designed to secure your personal information 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 information via the internet and mobile platforms is not completely secure. Although We do our best to protect your personal information, We cannot guarantee the security of your personal information transmitted through Our Software or Mobile App. Any transmission of personal information 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 information 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.

I. Contact Us

If  you  have   any   questions   or   concerns   regarding   Our   Privacy   Policy,   please   contact   us  at data.protection@dormakaba.com.