What Is This Policy About? 

    dormakaba (China) Technologies Ltd. ("dormakaba" “Us”, “Our” or "We") respect your right to privacy and are committed to following applicable data protection rules to safeguard your rights when you use our mobile application and services. This policy describes Our practices for collecting, using, maintaining, protecting and disclosing personal data we may collect, or that you may provide when you download, install, and register your account for access, or use of the dormakaba DDL APP (the "App") or the features and functionality that you may access from the App (“Services”) as applicable. 

    This policy applies only to information we access or collect by virtue of Your use of the App and Services and in email, text, and other electronic communications sent through or in connection with this App and any information you may share. 

    This Privacy Policy DOES NOT apply to information that We collect offline, through any third party, including through any application content (including advertising) that may link or interface to or be accessible from the App or on the Services or through any other means, including on any other website operated by dormakaba or any third party (including any dormakaba affiliates). 

    Our websites and apps, and these other third parties may have their own privacy policies, which We encourage you to read before providing information on or through them. We are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave Our App or website and to read the statements of each application and website that collects personal information. 

    Please read this policy carefully to understand our policies and practices for processing and storing your information and how We will treat it. If you do not agree with our policies and practices, do not download, register an account, or use this App or the Services. By accessing or using this App or the Services, you agree to this Privacy Policy. 

How Do We Collect Your Information? 

    We collect information from and about users of Our App. We can collect it directly from you when you provide it to Us, or through the download, installation and set-up of the App to your device, registration of an account from or within the App, when you register another user, and when you electronically communicate with Us. We may ask you for information when you report a problem with the App or Service. You may be required to provide financial information before placing an order for additional services through the App. We also can collect the information automatically when you use the App or access the Services, and any media information or content that you may upload, publish, store or share on the Services or the App. 

    At present, the released app version does not collect any of the above user information. if app first startup and need user set name, telephone number, user can input anything to use the app. it is just stored in the local for help user to memorize information. 

    The app requires camera permission, which is only used for product QR code identification. When using camera permission, we will not collect any personal information or take photos for storage.

    The app requires location permission to locate surrounding BLE devices. but no positioning information has been collected & stored. 

    The app requires the user to provide telephone permission, which is only used to read the IMEI number of the mobile phone. This IMEI number will participate in the generation of the link encryption key of the app, which is mainly used to improve the security of APP communication. IMEI information will not be collected, but only stored in the private storage area of the app, and encrypted storage is used to ensure that the information will not be stolen and used by malicious programs.

    "The app requires the use of a clipboard. We only use the clipboard when generating offline sharing PIN for smart locks, enabling customers to easily enter sharing PIN in WeChat, email, and other tools, solving issues in APP sharing that cannot be compatiable in some android systems.". We promise not to share any user information to the clipboard.

What Information Do We Collect? 

    When you download, register with, or use this App or the Services, We may collect basic contact information of a personal nature such as name, address, email address, login credentials, telephone/mobile numbers, email and password, user name or similar identifier, or any other identifier We may use to contact you online or offline. We do not know the name or personal information tied to a user’s mobile phone number. 

    We may also collect non-personal information that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as the device you use to access the Services provided through the App, including the hardware model, operating system and version, and a unique device identifier, demographic information, location, language, statistics, or other information in an aggregated form. Statistical or aggregated data does not directly identify a specific person, but We may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific App feature or Service. 

    You may also provide information for publication or display ("Posted") on public areas of websites you access through the App or the Services (collectively, "User Contributions"). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information through your mobile device, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons and We are not responsible, nor will We be liable if your User Contributions are viewed and used by third parties. 

Automatic Information Collection and Tracking 

    When you download, access, and use the App or access and use the Services, we may use technology to automatically collect:

 •Location Information. This App does not collect real-time information about the location of your device. 

 What Information Technologies Do We Use For Tracking? 

 The technologies We use for automatic information collection may include: 

 •Cookies or mobile cookies. A cookie is a small file placed on your smartphone. Cookies may store unique identifiers, user preferences and other information. You can reset your device browser to refuse all cookies or to indicate when a cookie is being sent. However, some website and app features or services may not function properly without cookies. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of Our App or Services. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends, and providing relevant information to you. 

Do Third Parties Collect Information from You? 

    When you use or access the App or Services, certain third parties may use automatic information collection technologies or tracking technologies to collect information about you or your device. These third parties may include:

     •Our licensors; 

     •Other third-party application and service providers; 

     •Your mobile device manufacturer; 

     •Your mobile service provider; 

     •Your government. 

    These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use Our App or Services or when you access their website from Our App or Services. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 

    We do not control how these third parties' tracking technologies operate, nor their privacy and data protection policies or how they may use the information they collect. Before providing your personal information to third parties, please read the privacy policy of these third parties. You can choose whether to access links, contents, and services provided by third parties. We take no responsibility and are not liable when your information is misused or improperly disclosed by any third party on such occasions. If you have any questions about an advertisement or other targeted content, you should contact the responsible third-party provider directly.

How Do We Use Your Information? 

    We use information that We collect about you or that you provide to Us, including any personal information, to: 

     •provide you with the App, its contents, and the services, and any other information, products or services that you request from Us; 

     •provide you with customer support in response to your requests and inquiries; 

     •fulfill any other purpose for which you provide it; 

     •send you notices about your account/subscription, including expiration and renewal notices; 

     •carry out our obligations and enforce our rights arising from any contracts entered into between you and Us, including for billing and collection; 

     •notify you when App updates are available, and of changes to any products or services We offer or provide though it; 

     •provide notices to you in relation to the access Services provided by Us; 

     •provide you with Value-Added Services that you subscribe to separately through the App; and 

     •administer Our App and the Services and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes. 

    We do not sell or trade your information or data or collect or use it for direct marketing purposes. Our right to collect the data is based on Our need of your data in order to provide you with use of the App and access to the Services, as stated herein. To the extent that your data is used to improve and develop new products and services or to maintain and manage the App and Services, We base Our use of your data or information on Our legitimate interest to perform such actions. 

Who Do We Share Your Information With? 

    We may disclose aggregated information about Our users, and information that does not identify any individual or device, without restriction. In addition, We may disclose personal information or data that We collect or you provide: 

     •To Our subsidiaries and affiliates; 

     •To contractors, service providers, and other third parties We use to support our Services and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which We disclose it to them; 

     •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 dormakaba’s assets; 

     •To fulfill the purpose for which you provide it. For example, if you give Us an email address or mobile number to add another registered user, We will transmit the contents of that email and your email address to the new registered user; 

     •For any other purpose disclosed by Us when you provide the information; 

     •With your consent; 

     •For local or foreign regulators, governments and law enforcement authorities, including tax collection agencies and stock or other exchanges, and in order to comply with any court order, law, or legal process, including to respond to any government or regulatory request; 

     •For local and foreign courts, tribunals, arbitrators or other judicial committees; 

     •To enforce Our rights arising from any contracts entered into between you and Us, including the App EULA, and if applicable for billing and collection; and 

     •If We believe disclosure is necessary or appropriate to protect the rights, property, or safety of dormakaba, Our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. 

What Are Your Rights With Regards To Your Personal Information? 

    We strive to provide you with choices regarding the personal information you provide to Us. This section describes your rights for you to control certain uses and disclosures over your information. 

    You especially have the following rights with regards to your personal data which are also in compliance with the privacy legislation of EU GDPR: 

     •Right to access; 

     •Right to rectification, completion or deletion; 

     •Right to limit the processing; 

     •Right to object to the processing; 

     •Right to data portability; 

     •Right to appeal to a regulatory authority. Exercising your rights may affect your use of the App or Services. If you wish to inquire about any of the rights set forth above, please contact Us at: china.kps@dormakaba.digital; 

Is Your Information And Data Secure? 

    We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to Us is stored on Our or Our service providers secure servers behind firewalls. Although We do Our best to protect your personal information, and 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-party service providers with whom We contract will exercise similar precautions), We cannot guarantee the safety or security of your personal information transmitted through Our App or Services. We cannot guarantee that any accidental loss, unauthorized use, alteration, 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, applications or services not provided by Us (including your mobile device or the devices of your registered users), any infrastructure, services or materials not exclusively controlled by Us or with respect to the internet in general. Unfortunately, the transmission of information and data via the internet and mobile platforms is not completely secure. Any transmission of personal information is at your sole and exclusive risk. We are not responsible for the 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 App or Services, you are responsible for keeping this password confidential. We recommend that you do not share your password with anyone.  

Where Does Your Data Or Information Go? 

    Your personal data will be stored on a secure server space maintained by Us or a third-party service provider contracted or certified 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.). 

    If you need to contact us Us by e-mail, the data you supply (your e-mail address, your name and/or 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. 

    Backups of stored data (access rights) remain in place until the data is deleted by You and then said data is 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 requirements. We will retain the data for as long as is necessary for the relevant activity related to the App or Services or for as long as We are lawfully required to do so. 

    dormakaba have established affiliates or partners in different locations around the world and We offer Our services through the use of different cloud service providers who have servers located in different countries. As such, your information might be transferred outside the region and country from where you access and use Our App and Services, including to regions/countries where you access or use the App and Services, which may have different legal regulations and legislation and might not offer an adequate level of protection as determined by the local privacy and data protection legislation. However, We have taken the necessary measures to ensure that your information is processed in conformity with applicable laws and appropriate technical security measures are adopted to safeguard your privacy. Your continued use of this App and/or Services after We revise this policy means you acknowledge and accept those changes, so please check the policy periodically for updates. 

Amendment to Privacy Statement

If the dormakaba DDL APP upgrade, the privacy statement will be modified. We will publish these changes on a special webpage and update the revision date of this document. For significant changes, we will also provide more significant notifications (such as pop-up windows).

If you have any questions, opinions or suggestions regarding privacy rights, you can contact us at our company phone number+86755618999 to 6758, or by email tony.zhang@dormakaba.com

Last updated: 15 December 2023