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 or Schlage Ease 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.
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.
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.
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:
How We Share Your Information
We may share your information, including personal data, as follows:
· 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.
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 email@example.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.
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 firstname.lastname@example.org or email@example.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 firstname.lastname@example.org, 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: email@example.com or firstname.lastname@example.org.
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.
Please contact us at Allegion (Australia) Pty Ltd or Allegion (New Zealand) Limited at (email: email@example.com or firstname.lastname@example.org) 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.