CCPA Privacy Notice
dormakaba Privacy Notice for California Residents
Effective Date: April 7, 2021
Last Reviewed: December 22, 2020
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information“). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have or may have collected the following categories of personal information from consumers within the last twelve (12) months from the Switch Mobile App and/or the www.timeforaswitch.com Website:
- Identifiers: A 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 categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, address, telephone number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information.
Some personal information included in this category may overlap with other categories.
- Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Device Information: Information as to user’s operating system and its interface, browser, language and version of browser software or similar information.
- Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
- Geolocation Data: Physical location or movements. Specifically, we may collect information 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;
- Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
To the extent we obtain the categories of personal information listed above, this information emanates from one or more of the following categories of sources:
- Directly and indirectly from you and/or your authorized representative(s). For example, from the set up, registration and use of the Switch Deck software application, or a third party’s physical access software application which interfaces with the Switch Deck software application, the Website and Switch Mobile app.
- Indirectly from you. For example, from observing your actions on our Website and access to a Switch Core by a user of the mobile app;
- From our service providers, distributors, product integrators, resellers, including independent sales representative agencies, partners which have a contract with you or your account owner
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.
- 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.
Sharing Personal Information
We 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 may share your personal information with the following categories of third parties:
- Service providers.
- Our distributors, product integrators, resellers, including independent sales representative agencies, and partners which have a contract with you or your account owner.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Company has or may have disclosed your personal information for a business purpose to the following categories of third parties:
- Service providers.
Our distributors, resellers, and partners which have a contract with you or your account owner.
Sales of Personal Information
We do not sell personal information within the scope of the application of the CCPA, nor have we sold any personal information in the past twelve months.
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).
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 product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 submit a verifiable consumer request to us by contacting us at the contact information indicated at the end of this Privacy Notice.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.
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, which may include: Your email address, phone number or mailing address
- 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.
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 45 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 our 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.
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.
We reserve the right to amend this privacy notice at our discretion and at any time. If there are material changes to this privacy notice, we provide a prior, prominent notice to you in a manner that will allow you to exercise your privacy rights.
Phone Toll Free: 1 800 313-5784
Email: [email protected]