Schlage Abode Connected Product Terms of Service & Privacy Policy

 

EFFECTIVE DATE: 01 August, 2020

This Connected Product Privacy Notice (the “Notice”) is brought to you by Allegion (Australia) Pty Ltd or Allegion (New Zealand) Limited (collectively, “Schlage”, "we", "our" or "us"). 

You are being presented with this Notice because you wish to use a Schlage connected product (“Connected Product”) with a Schlage Abode App (“App”) and cloud service that enables certain features and functions such as the App.

Collectively, the features and functions provided by Schlage and the App are referred to in this Notice as the “Services". 

In this Notice we describe how we collect, use, hold and disclose information that we obtain through your use of the Services and the integration of your Connected Product with the App and/or Third Parties (as applicable). Schlage is not responsible nor does Schlage control the practices of Third Parties. Additional documentation regarding Third Party privacy practices can be found at their respective websites.

By using the Services, you agree that your information will be handled as described in this Notice. Your use of our Services, and any dispute over privacy, is subject to this Notice and our Terms of Use, which are incorporated by reference into this Notice and include applicable limitations on damages and the resolution of disputes.

What Information Do We Collect About You and Why?

We collect information about you directly from you and from third parties, as well as automatically through your use of our Services.

Registration and Login. Certain Services require you to register for an account and/or log in using credentials. You can register for an account from our account registration system or a third-party site or service (“Account”). When you register for an Account you may be asked to provide some personally identifiable information, such as your email address, phone number, lock SN code and a username and password that you select. When you are asked to create an Account using your credentials from a third-party site or service, you will be asked for your username, password, and other information to verify that you have an account with the third-party site or service. When you provide credentials for a third-party site or service, we may use those credentials to obtain information about you from that third party. When you register an Account and log in to the Services you must provide your current, complete, and accurate information. It is your responsibility to keep your information up to date. We are not responsible for any problems, interruptions in access, or liability that may arise if you do not give us complete and accurate information or if you fail to update your information so that it is current.

 

Product Set Up. In order to use certain products such as our lock products, we may record information relating to the setup, general performance, and operation of our Service, your application and lock (and of other of our locks in your home or business or that you otherwise may access), including device status, logs of those who lock/unlock the device and Service, the guests that you invite, and those people who may invite you as a guest, to use the device and application. We may store this data along with your personally identifying information other information about your use of our Service. We use this information to allow you (and us) to operate and monitor your device and our Service.

 

Certain features may be available (e.g., an Auto-Unlock), that if enabled, the application will track your location using GPS in order to determine when your application nears Schlage Abode devices that you have permission to access (e.g. when you are near home). This information will only be stored on your device, and not on our servers. This information will tell your mobile device to start listening for your lock more often (increasing the polling). This improves the Schlage Abode device’s performance and saves your mobile device’s battery life.

 

Correspondence. If you send us personal correspondence, such as emails or letters, about your use of the Services, we may save the information in a profile specific to you.

 

Information You Provide to Others. You may choose to share information with third parties such as social networking sites by “sharing” a Bluetooth key.

 

Automatically Collected Information. We will collect some information about you and any product or device you use to access or use the Services automatically using a variety of technologies. In general, automatically collected information about the use of Services does not directly identify you and the information may include your diagnostic log information, IP address, browser type and language, referring/exit pages and URLs, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, the actions performed in the app, the info (OS type/version, network, etc.) of the phone which the app was installed, and the date and time. We collect this information for the purposes described in this Policy, including to better understand our customer base and to improve the quality of our Services. We do not collect information not related to the use of the Alfred services. We may use cookies to track how you are using the Services, our web sites, or our partners’ web sites.

 

Mobile Data. When you use certain features of the Service, in particular our mobile applications, we may receive, store and process different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Service or specific features of the platform). If you access the Service through a mobile device and you do not want your mobile device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your mobile device. See your mobile device manufacturer’s instructions for further details. Of course, if you do this, Service functionality (such as the Auto-Unlock feature described above) may not work.

 

Guest Access. As part of our Services, you may give others (“guests”) permission levels to access your Schlage Abode device – for example to unlock and lock your door (and possibly even to pass this access along to others). Needless to say, you must be careful of the guests that you invite and the access that you give them. YOU ARE RESPONSIBLE FOR ALL USES OF YOUR ACCOUNT, SO BE CAREFUL TO SECURE THIS INFORMATION AND ONLY GIVE ACCESS TO PEOPLE YOU TRUST. Additionally, certain portions of your personally identifying information, device and Service information may be shared with the people that you invite, such as your name and lock location, and the status of the lock (e.g. locked or unlocked).  We may also collect personally identifying information (as required to use the Service as set forth in this Privacy Policy) about the guests that you invite in order to allow them to have access to your Alfred device and Service. All such information (including their Service usage information) is subject to, and will be used and disclosed as set forth in, this Privacy Policy. ALL GUESTS EXPRESSLY CONSENT TO SUCH USE AND DISCLOSURE AS A USER OF THE SERVICE. IF YOU ARE A GUEST AND DO NOT CONSENT TO SUCH USE, YOU SHOULD STOP USING THE SERVICE. GUESTS SHOULD BE AWARE THAT THE PERSON(S) PROVIDING ACCESS TO A SPECIFIC DEVICE MAY BE ABLE TO SEE INFORMATION ABOUT THE GUEST’S USAGE OF THE DEVICE AND OUR SERVICE AND MAY REVOKE OR LIMIT ACCESS RIGHTS IN THEIR DISCRETION WITHOUT NOTICE. GUESTS SHOULD ALSO BE AWARE THAT THEIR PERSONALLY IDENTIFYING INFORMATION AND USAGE INFORMATION MAY BE SHARED WITH THIRD-PARTY SERVICE PROVIDERS AS SET FORTH IN THIS PRIVACY POLICY, INCLUDING THOSE SERVICE PROVIDERS SELECTED BY THE PERSON(S) THAT INVITED YOU TO USE THEIR LOCK (SEE “YOUR THIRD PARTY SERVICE PROVIDERS” BELOW). If you send us a request (for example via a support email or via one of our feedback mechanisms), we may use your information to contact you and provide support or a response. We also reserve the right to publish your request in order to help us clarify or respond to your request or to help us support other users.

 

 

Information We Collect Directly From You. When you create an account to use the Services, you must provide us with your name, phone number, and email address and other information that we may request.

 

Information We Collect Automatically. We automatically collect information about your use of our Services, including: Internet Protocol (IP) address.

 

App and Third-Party Integrations.  We collect the information described in the “Third-Party Integrations” section below.

 

How We Use Your Information

We use your information, including your personal data, for the following purposes:

  1. The performance of our agreement with you and to enable you to use the Services and to provide the Services to you. In order to do so, we use your information:
    • To allow you to register, program, configure, schedule and use your Lock.
    • To allow you to share access to your Lock and your Services account with others.
    • To deliver our Services to you, to communicate with you about your use of our Services, to respond to your queries or complaints, and for other customer service purposes.
    • To inform you of the status of our Services, including but not limited to temporary loss of or degraded performance of the Service or products that you use.
  2. The legitimate interests of Schlage. For this reason, we use your information, including your personal data, for the following purposes:
    • To tailor the content and information that we may send or display to you and personalized help and instructions, and to otherwise personalize your experiences while using the Services.
    • For marketing and promotional purposes. We may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information (including those offered by third parties) we think may interest you.
    • To better understand how users access and use our Services, both on an aggregated and individualized basis, to improve our Services, respond to user desires and preferences, and for other research and analytical purposes.
    • To comply with our legal obligations and assist government and law enforcement agencies or regulators, and to protect our rights and interests as well as the rights and interests of our users and other third parties.

How We Share Your Information

                      

We may share your information, including personal data, as follows:

  • Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal data will be subject to this Notice.
  • Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. These third parties may be located outside of your home country and thus your information may be accessible to law enforcement or regulatory authorities according to the applicable laws of such foreign jurisdictions (see the section "International Transfers" below for more details of those countries in which (or to which) we may use, disclose, process, transfer or store your personal data).
  • Business Transfers. If we are acquired by or merged with another company, if we transfer some or all of our assets to another company, or as part of an asset sale, a sale of business or a bankruptcy proceeding, we may transfer the information we have collected about you to the other company.
  • In Response to Legal Process. We may disclose the information we collect from you where we are required or authorized by law to do so, and to comply with any judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Notice.
  • Aggregate and De-Identified Information. We may share and disclose aggregate, de-identified or anonymized information about you or derived from your use of the Services with third parties for purposes of helping us review use of our Services and improve our Services and marketing, advertising, research, analytical or similar purposes.
  • You have consented. We may disclose the information we collect from you where you have expressly consented to the disclosure or the consent may reasonably be inferred from the circumstances.

·         Third Party Integrations.  We share certain information with Kaadas[A1][A1]  in order to provide the services. All information obtained by the Third Party is subject to use by the Third Party’s policies, including their privacy notice.  We are not responsible nor do we control the practices of any Third Party.

International Transfers and Offshore Storage of Personal Data

We may use, disclose, process, transfer or store information, including personal data, outside the country in which it was collected, such as to the United States and other countries, which may not guarantee the same level of protection for personal data as the country in which you reside.

Additionally, there are situations when personal data is transmitted to third-party service providers (in China, Germany, and/or other countries, including countries in which Schlage operates or as offices) to provide services for Schlage, such as payment processing and web hosting and other services required by law. Schlage uses third-party service providers to process personal data for service-related and administrative purposes. Such service providers are located in the United States and other locations where Schlage does business. When Schlage retains another company to perform a function of this nature, such third party will be required to protect the personal data and will not be authorized to use the personal data for any other purpose.

The countries that we may use, disclose, process, transfer or store your information in are likely to be the China, and Germany, and the United States.

Your Rights

You provide your personal data to us voluntarily. Depending on your jurisdiction, you may have the right, at any time, to learn whether Schlage process personal data about you, to request information as to your personal data being processed, to access personal data that Schlage holds about you; to learn the purpose of the processing and to check whether the data is being processed in accordance with the original purpose, to request that we restrict the use of your personal data or stop using or disclosing your personal data; to request that we update, amend, or delete your personal data; to know the third parties whom your personal data has been transferred, request third parties to be informed of any rectification, update, deletion, object to the occurrence of any result that is to your detriment by means of analysis of personal data exclusively through automated systems, request portability of your personal data or compensation for damages due to unlawful processing of your personal data and to withdraw any previously given consent with regard to your personal data; using the contact information below. You may make such requests by submitting an email to dataprivacy@allegion.com. Once we receive your request, we will verify it. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. Allegion will respond to your requests within fifteen (15) days of receiving the request, unless you are notified otherwise by us in writing. There is no charge for requesting access to your personal data but we may ask you to meet reasonable costs in providing you with access, for example photocopying or postage costs. There are some circumstances in which we are not required to give you access to your personal data. We will take all reasonable steps to ensure that the personal data we hold about you remains accurate, up to date and complete.

Third-party Analytics

We may work with service providers (including Google Analytics) who conduct analytics to help us track and understand how customers use the Services.  Google is an analytics service provided by Google that help us analyze how users use the Services. The information generated about your use of the Services will be transmitted to and stored by Google on servers in Australia, New Zealand, India, the United States, or other countries. For more information about Google’s privacy practices, please see the Google Privacy Policy.

Security

We have implemented measures designed to protect the information we collect from damage, misuse, interference, loss, alteration, destruction, unauthorized or accidental use, modification,disclosure, access or processing, and other unlawful forms of processing data. However, please be aware no data security measures can guarantee 100% security. While we monitor and maintain the security of the Services, we do not guarantee that the Services or any products or services is impervious to attack or that any use of the Services or any products or services will be uninterrupted or secure. In addition, information that you transmit over the Internet, including through email or SMS message, is not secured by us and is inherently vulnerable to attack or interception.

Storage of Personal Data

We store your information in electronic and physical formats. Your data remains stored by us in the Services. After you delete your Services account, we may continue to use and store your information in accordance with our record retention policies and this Notice.  As a general matter, we do not retain personal data for longer than is required or appropriate for the purposes for which it was collected, unless a longer or shorter period is necessary for our legal obligations, or customs of the industry, or to defend a legal claim, or to comply with legal, accounting, regulatory or reporting requirements, and consistent with applicable law.

What Choices Do I Have Regarding Use of My Personal Data?

We may send periodic promotional emails and other communications to you with offers and announcements we think may interest you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Further, you may opt-out of promotional communications by sending an e-mail to auinfo@allegion.com or nzinfo@allegion.com. Please note that it may take up to 10 business days for us to process opt-out requests regarding promotional emails and longer for other types of requests. If you opt-out of receiving promotional communications from us, we may still send you communications about your account or any products or services you have requested or receive from us.

No One Under 18

Our Services are not designed for anyone under 18. If we discover that a person under 18 has provided us with personal data, we will delete such information from our systems.

Do Not Track Disclosure

Currently, our systems do not recognize browser “do-not-track” requests. You may disable certain tracking (e.g., by disabling cookies). To learn more about do-not-track signals, please see https://allaboutdnt.com/.

Additional Information for Residents of Certain Jurisdictions

Depending on your jurisdiction, you may have some or all of the following rights with regard to our processing of your personal data, except to the extent such rights are limited by law:

Right to access, correct and delete your personal data: Schlage will use reasonable measures designed to ensure that all personal data is correct. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address, bank account, etc.) are notified to Schlage so that we can ensure that your personal data is up-to-date.

You have the right to request access to any of your personal data that Schlage may hold and to request correction of any inaccurate personal data relating to you. You furthermore have the right to request deletion of personal data we hold about you.

Right to withdraw consent: In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time by sending an email to dataprivacy@allegion.com, specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.

Data portability: To the extent that we use your personal data on the basis of consent for the performance of a contract and that personal data is processed by automatic means, you have the right to receive all such personal data that you have provided to Schlage in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.

Right to restrict personal data use: You have the right to restrict our use of your personal data where (i) you contest the accuracy of the personal data; (ii) the use is unlawful but you do not want us to erase the personal data; (iii) we no longer need the personal data for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims; or (iv) you have objected to our personal data use justified on our legitimate interests pending verification as to whether Schlage has indeed compelling interests to continue the relevant personal data use.

Lodge a complaint: You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the collection and use of your personal data violates this Notice or applicable law.

You may revoke the consent that, as the case may be, you granted us for the handling of your personal data. However, it is important that you keep in mind that not in all the cases we will be able to answer your request or immediately conclude the use thereof as it is possible that due to some legal obligation we will be required to continue handling your personal data. To revoke your consent you must send your request to the following email address: auinfo@allegion.com or nzinfo@allegion.com.

Changes to this Notice

This Notice is current as of the Effective Date set forth above. We may change this Notice from time to time, so please be sure to check back periodically. We will post any changes to this Notice within the Services. You can obtain a copy of our current Notice by contacting us. If we make any changes to this Notice that materially affect our practices with regard to the personal data we have previously collected from you, we will endeavor to provide you with notice by highlighting the change in the Services or by emailing your email address of record.

Contact Us

Please contact us at Allegion (Australia) Pty Ltd or Allegion (New Zealand) Limited at (email: auinfo@allegion.com or nzinfo@allegion.com) if you have any questions or concerns about this Policy, the personal data we have about you, require assistance in managing your choices, or have other questions, comments or complaints regarding our privacy practices.

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