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External Data Privacy Policy

 

Information We Collect

We collect information directly from you, from third parties, and automatically through your use of our Site or any TRELOCK services. To the extent permitted by law or with your consent, we may combine all of the information that we collect about you from various sources.

Information We Collect Directly from You. We collect information from you when you submit a registration card, request information from us, contact us, or otherwise use our products and services. The information we collect varies depending on your interaction with us, but may include your name, job title, mailing address, billing address, telephone numbers, fax number, e-mail address, payment information (including financial account numbers or credit or debit card numbers), and purchase history. We also collect any other information that you choose to provide to us (e.g., registration information if you register one of our products or register for anti-theft protection, responses to any questionnaire or surveys, or information that you provide as part of a sweepstakes or contest) through our Site or offline.

You are not required to provide us with any personal data, but, you may not be able to take advantage of certain offerings (e.g., registering your lock) if you do not do so.

Information We Collect About You from Third Parties. We also may collect information about you from third parties. For example, we may collect your username, name, or e-mail address from social media platforms if you interact with us through social media.

Information We Collect Automatically. We automatically collect information, including personal data, through cookies, web beacons, and other technologies when you visit our Site or use our services. The information that we automatically collect includes, but is not limited to: domain name; browser type and operating system; web pages viewed; links clicked; Internet protocol (“IP”) address; the length of time on our Site and or use our services; and the referring URL, or the webpage that led you to our Site. To the extent permitted by law or with your consent, we may combine this information with other information that we have collected about you. Please see Cookies and Tracking Mechanisms below for more information.

 

Use of Your Information

We use your information, including your Personal Data, for the following purposes:    

  • To Provide Our Products and Services to You. We use your information to provide our products and services to you; to take, verify, process, and deliver orders and returns; to process payments; for warranty, technical support, or other similar purposes; and to establish and maintain customer accounts.
  • For Vendor Management Purposes. We use your information to establish and maintain vendor accounts, provision the requested products and services, and take other actions in furtherance of vendor management. The information that we collect from our vendors is used also for the purposes set forth in this section.
  • Customer service. We use your information for customer service purposes, including for warranty, technical support, or other similar purposes; to respond to your inquiries, and for other purposes for which you contact us.
  • Communication. We use your information to communicate with you, including to respond to requests for assistance. We may communicate with you in a variety of ways, including postal mail, e-mail, telephone, and/or text message. 
  • Administration. We use your information for administrative purposes, including to manage our inventory; to help us better understand access to and use of our Site; to provide information and reports to investors, prospective partners, service providers, regulators, and others; to implement and maintain security, anti-piracy, fraud prevention, and other services designed to protect our customers, users, vendors, us, and the general public; to enforce this Policy, our Terms, and other policies.
  • Research and development. We use your information for research and development purposes, including to improve our Site, products, services, and customer experience; to understand our customer and user demographics; and for other research and analytical purposes.
  • Legal compliance. We use your information to comply with applicable legal obligations, including to respond to a subpoena or court order.
  • To protect us and others. We use your information 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 or this Policy.
  • Marketing. We use your information where required by law, to the extent permitted by law, or with your consent (where required by law) for marketing and promotional purposes, including through e-mail. For example, we may use your information, such as an e-mail address, to send news and newsletters, special offers and promotions, or to otherwise contact you about products, services or information we think may interest you. We also may use your information to assist us in advertising our services on third-party websites or through other venues.

 

Disclosure of Your Information

We may disclose your information, including Personal Data, as follows:

  • Users of Our Site. User name and any information that you post to our Site, including without limitation pictures, comments, and text, may be available to all other users of our Site and may be publicly available upon posting.
  • Affiliates and Subsidiaries. We may disclose your information to any current or future affiliates or subsidiaries, for the purposes described above under Use of Personal Data. For example, we may share your information with one of our U.S. entities for storage purposes.
  • Service Providers. We may disclose personal data to third-party vendors, service providers, contractors or agents to enable them to perform functions on our behalf. These service providers may, for example, help us administer our Site, process job applications, or process payments.  
  • Other Non-Affiliated Third Parties. We may disclose your information to non-affiliated third parties, such as wholesalers, distributors, promotional partners and others with whom we have marketing or other relationships for their own marketing purposes. To the extent permitted by law or with your consent, those third parties may use your personal data for their own marketing purposes, such as to market products and services that they believe would be of interest to you.
  • We also may disclose your information, including personal data, for the following reasons:
  • Business Transfers. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.    
  • In Response to Legal Process. We may disclose your information in order to comply with the law, a judicial proceeding, court order or other legal process, such as in response to a subpoena or other lawful governmental request.    
  • To Protect Us and Others. We may disclose your information when 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 or this Policy. 
  • Aggregate and Anonymized Information. We may disclose aggregate or anonymized information about you with third parties for marketing, advertising, research or similar purposes.    

 

Cookies and Tracking Mechanisms 

We and our service providers use cookies, tracking pixels and other tracking mechanisms, to track information about your use of our Site and the services available through our Site. We or our service providers may combine this information with other information we have received about you.

Cookies. A cookie is a text-only string of information that a website transfers to the cookie file of the browser on a computer’s hard disk so that it can remember the user. A cookie will typically contain the name of the domain from which the cookie has come, the ‘lifetime’ of the cookie, and a value, usually a randomly generated unique number. This helps us to provide you with a good experience when you browse our Site and to improve our Site, products and services. We predominantly use cookies for the following purposes:

  • Where they are essential to make our Site work.
  • To compile anonymous, aggregated statistics that help us to understand how users use our Site and to help us improve the structure of our Site.  

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags) in connection with our Site to track the activities of visitors to our Site, help us manage content, and compile statistics about usage of our Site. We or our service providers may also use clear GIFs in HTML e-mails to our users, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

Third-Party Analytics. We use automated devices and applications to evaluate usage of our Site and services. We use these tools to help us improve our services, performance and user experiences. These devices and applications may use cookies and other tracking technologies to perform their services

Please see our Cookie Policy for additional information about our use of cookies, your ability to accept/decline cookies, and related information.

 

Interest-Based Advertising

We use third parties such as network advertisers to serve advertisements on our Site and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs, and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal data, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Users in Canada may go to the Digital Advertising Alliance of Canada (“DAAC”) Opt-Out Tool to opt out of certain third-party ad networks’ interest based advertising. Additional information is available on the DAAC’s website at youradchoices.ca. 

Users in the European Union may go the European Interactive Digital Advertising Alliance (“EDAA”) Your Online Choices website and select their country to learn more about interest-based advertising and how to opt out in their own country. For example, users in France may go to the Contrôler ses cookies website to opt out of certain third-party ad networks’ interest-based advertising and find additional information at www.youronlinechoices.com/fr.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page, the DAAC Opt-Out Tool, or through the various EDAA websites will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA, NAI, DAAC, and/or EDAA websites, your opt out may not be effective. Please note that if you use multiple devices you will have to opt out on each individual device.

 

Do Not Track Disclosure

Currently, our systems do not recognize browser “do-not-track” requests. You may disable certain tracking as discussed above in our Cookies and Tracking Mechanisms section (e.g., by disabling cookies). To learn more about do-not-track signals, please see this resource.

 

Third-Party Links

Our Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

 

International Transfers and Offshore Storage of Personal Data

We may use, disclose, process, transfer or store 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 the United States and/or other countries, including countries in which TRELOCK operates or as offices) to provide services for TRELOCK, such as payment processing and web hosting and other services required by law. TRELOCK 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 TRELOCK does business. When TRELOCK 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.

 

Security of Personal Data

We have taken steps to protect against unauthorized or unlawful processing of personal data, unauthorized or accidental access to personal data, and accidental or unlawful loss or destruction of personal data. However, we cannot guarantee against any loss, misuse, unauthorized access, unauthorized disclosure, alteration or destruction of personal data or any unlawful forms of processing.

Users should safeguard any password or user ID obtained for use on our Site and are responsible for any misuse or unauthorized use of our Site via their password and user ID maintaining the secrecy of their own passwords. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us using the contact information below.

 

Retention of Personal Data

We will retain your Personal Data for as long as we have a reasonable legal or commercial need for it, after which time we will destroy it through currently available secure destruction means.

 

Your Rights and Choices

Your Rights. You provide your personal data to us voluntarily. Depending on your jurisdiction, you may have the right, at any time, to access personal data that TRELOCK holds about you; to request that we stop using or disclosing your personal data; to request that we update, amend, or delete 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 contacting your country-specific National Data Protection Officer or local Privacy Manager at the Contact Us information provided below.

Your Choices. You can always choose not to provide information, even though it might be needed to take advantage of certain services.

Opting Out of Cookies. Please see our Cookie Policy for more information about blocking or disabling cookies.

Opting Out of Marketing Communications. We may send your promotional e-mail messages if you request to receive information from us. You may request to stop receiving promotional e-mail messages by following the link contained in the e-mail itself. Please note that if you opt out of receiving e-mail marketing communications from us, we may continue to communicate with you for other purposes (e.g., to respond to your inquiries or for service-related purposes). You may otherwise opt out of receiving marketing communications from us by contacting us at the mailing addresses set forth in the Contact Us section below.

 

Job Applicants

You may apply for employment through our Site. If you do so, we will collect name, contact information, national identifying information, job history, resume, and other job or application-related information. We will also collect any other information (e.g., demographic information) that you choose to provide to us through our Site. The employment portal of our Site is hosted in the United States, which may not have the same level of protection as your home country.  The employment portal may contain additional privacy notices that apply.

If you apply for an open position with a particular company, and we think that your qualifications are applicable for a different position within that company or an affiliated company, we may share your information with such other division and/or affiliate/subsidiary. We use the information that you submit to us through this portal for the purpose of processing your application. If required by law, or as appropriate to protect our rights and interests, we may share your information with law enforcement and other third parties as set forth in our disclosure section above. We do not use your information for marketing purposes.

Please also see above with regard to your Rights and Choices as well as the ability to access and correct your information.

Should you become an TRELOCK employee, in accordance with applicable law, we will provide you with a notice about how we use your personal data.

 

Changes to this Policy

We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the Personal Data we have previously collected about you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site or e-mailing you. Your continued use of our Site, purchase of our goods or services or provision of further information constitutes your acceptance of our revised Policy.

 

Contact Us

Please contact us at dataprivacy@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.  The messages you send to us will be transferred to and reviewed in the United States.

 

Additional rights (from 25 May 2018)

As of May 25, 2018, with regard to personal data subject to the General Data Protection Regulation of the European Union, you also have the following rights:

  • Data portability - to the extent that we are relying upon the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for processing, and that personal data is processed by automatic means, you have the right to receive all such personal data which you have provided to the TRELOCK in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible
  • Right to restriction of processing - you have the right to restrict our processing of your personal data where:
  • you contest the accuracy of the personal data until we have taken sufficient steps to correct or verify its accuracy;
  • the processing is unlawful but you do not want us to erase the data;
  • we no longer need the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims; or
  • you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether the TRELOCK  has compelling legitimate grounds to continue processing.
  • Where personal data is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise or defence of legal claims.

Right to object to processing justified on legitimate interest grounds - to the extent that we are relying upon legitimate interest to process data, then you have the right to object to such processing, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the data for the establishment, exercise or defence of legal claims. Normally, where we rely upon legitimate interest as a basis for processing  we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

You also have the right to lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the processing of your personal data infringes the European Union's General Data Protection Regulation.

For further information regarding your rights, or to exercise any of your rights, please contact dataprivacy@allegion.com.