This notice applies to citizens of the United States.
What is the purpose of this Notice?
The purpose of this Notice is to protect the rights of all users Master Lock Company LLC (“Yale”) with respect to the products or services sold under the Yale brand and/or Yale operated mobile apps. Ensure equal and secure treatment of user personal information, inform about your rights, and ensure Yale with data protection law.
Your rights with respect to Notice
You have the right to know which personal information is disclosed and to who. You are free to, at any time and without cause, op-out from the sale of personal information.
Selling data to third parties
Yale does not sell your personal information. Yale could share your personal information with service providers and with affiliated entities only for "necessary" purposes according to this Notice. The service providers and affiliated entities perform processes on behalf of Yale. Neither the service provider nor affiliated entities sell personal information.
Contact details
For questions and/or comments about our policies and this statement, please contact us by using the following contact details:
Yale Privacy
500 3rd Street, Suite 110
San Francisco, CA 94107
E: privacy[at]august.com
Phone: 1-855-213-5841
Privacy Notice - Canada
Your personal information
This policy applies to Master Lock Company LLC (“Yale”) with respect to the products or services sold under the Yale brand and/or Yale operated mobile apps. Yale is responsible for the processing of your personal information.
What personal information do we collect?
Personal Information We Request for the Use of the Services. When you download the App, and in order to use the Services, we require you to establish an account, for which we collect and store the following: your name, email, password, telephone number, the identification number for your locksets (“Products”) and user and account verification identifiers.
Personal Information is collected based on your use of the Services. When you use the Services, we collect Personal Information that you may provide about yourself, such as your user name, as well as Personal Information about other people who have access to your Products, such as other family members, guests, and service providers like gardeners, house cleaners and/or others (“Invitees”). For example, you may include email addresses and telephone numbers of Invitees who you are allowing to access your Products. We may ask for access to your contact list, and you may consent to provide access to such a list, which includes Personal Information.
We collect Personal Information that you may include in help requests, customer service correspondence, product ratings or reviews, and/or in any feedback you send to us. We also collect Personal Information included in messages that you may send from within the App, whether those messages are sent to us, an Invitee, or a third party.
Also, if you enable the Auto-Unlock feature, the App will request your consent in order to track your location in order to determine when your App nears Products that you have permission to access (e.g., when you are near home). Location 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 device’s performance and saves your mobile device’s battery life.
Personal Information we automatically collect. When you use the App, we will create a user ID for your account, and we also gather the following information for purposes of providing the Services when you download the App and/or access the Services: usage data about how and when you interact with the Services and Products, logs of when your Products are locked/unlocked, logs of those who lock/unlock your Products, the people that you invite to use your Products, and those people who may invite you to use their products.
We also collect the following information about the devices on which the App is downloaded and the Products you use: the operating system of the device on which the App is downloaded (e.g., you, your invitees), the version of the App on such devices, information about your Products, including serial numbers, MAC address, software versions on such Products and installation dates.
Additionally, if you choose to use the App to connect your Products with other products and services through the “Connected by” feature, we will collect information about your use of those other products.
Personal Information we receive when you use third-party products and services. If you access the Services through a third party (e.g., by managing your device via your television remote or connecting your device to your home security system), use third-party applications or services through the “Works With” feature, otherwise use a third-party service provider in connection with the Services and Products, or request or authorize us to give access or data to a third-party service provider (e.g., a delivery service, property management or rental service), then that third party will send us data about you, such as a user ID.
Invitees. As part of our Services, you may give Invitees permission levels to access your Products - e.g., to unlock and lock your door, and possibly even to pass this access along to others. You must be careful of the people 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 Personal Information, as well as other information about your use of the Service and your Products, may be shared with Invitees, such as your name and the status of the lock (e.g., locked or unlocked).
In connection with the guest invitation process, we may ask for access to your contact list. We will only store information for contacts that you add as guests. We will only access and store such information with your express consent.
If you are an Invitee, we collect your Personal Information when you use the Services and Products, as set forth in this Privacy Policy. All such information (including your service usage information) is subject to and will be used and disclosed as set forth in this Privacy Policy.
How and why will we use your personal information?
Why do we process this Personal Information? |
What is the legal basis for processing? |
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To provide you with the Services, including registering and management of your account, your use of the App and access to the Products you purchase, identifying/authenticating you when you use the App, providing any features and functionality in the App and the Products that you elect to use, customer service requests, maintenance which includes software updates, and communicating with you specific to the Services. |
Performance of a contract (i.e., the end-user agreement between you and us). |
To personalize the Services for purposes of you signing in and using the Services and your Products. |
When you use the services, you implicitly provide consent for us to process your data as described. |
To ensure only you and your guests have access to the Products. |
Performance of a contract (i.e., the end-user agreement between you and us). |
To carry out statistical analysis about the use of the Services and Products for purposes of making improvements. |
When you use the services, you implicitly provide consent for us to process your data as described. |
To send you communications and content about relevant solutions and services in accordance with your marketing preferences. |
We will only send you relevant content where we have your consent to do so. |
To comply with legal requirements to which we are subject, such as tax, accounting/financial reporting requirements, mandatory disclosures, and/or law enforcement. |
Using your Personal Information in this way is necessary for us to comply with our legal obligations. |
Who and where is your personal information transferred to?
We will transfer Personal Information for the purposes set out above:
Additionally, we may also similarly share your information with your Invitee.
We take measures to protect all Personal Information transferred to a third party, or to other countries, in accordance with applicable data protection laws and as stated above.
Privacy policies of other websites.
When you use the “Works With” feature in the App, you may be linked to third-party services and websites that you choose. Also, when using the App, you may use features that link you to social media websites, such as Facebook or Twitter. We are not responsible for the privacy practices or content of any of these third parties or the linked sites. Linked sites may collect Personal Information from you that is not subject to our control. We encourage you to review the privacy policies on any linked website you visit.
Information Retention
We may store collected information for as long as necessary to fulfill the purpose for which the Personal Information has been collected and in accordance with our internal record retention schedule. If you purchase Yale products or services, your billing and shipping address and the last four digits of your credit card information will be stored by Yale and our billing service providers. Lock activity is stored alongside your account information for the duration of your account being active. Doorbell camera photos and videos are available for download through our mobile application for up to thirty (30) days or as referenced in the selected subscription terms of service unless the information is necessary to be preserved based on a valid law enforcement obligation.
We will delete your Personal Information when the information is no longer necessary to process a request, at your request, or to manage your account or our client relationship. We will continue to store mobile application use and lock activity, including guest activity, for a period of at least ninety (90) days following account deletion.
We may store any aggregate or anonymous information indefinitely.
Exercising Your Choices or Rights
Right to access and rectification
You have the right to request access to the personal information relating to you. This includes the right to be informed whether or not personal information about you is being processed, what personal information is being processed, and the purpose of the processing.
You can self-exercise your rights in the following situations:
Communications- If you are a registered user, you may change your phone number or email address and update your preferences within the mobile application in order to manage your product-specific communications.
Mobile Data: 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 immediately above) may not work.
Right to deletion
You may request that your personal information be deleted, for example, in the following situations:
We also give you the ability to unsubscribe from marketing-related emails by clicking on a link in each such email.
Please note that we may reject your request if the processing is permitted or required according to law or any other relevant legal ground. We are not required to delete personal information that: (1) federal or state law requires a third party or us to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for the deletion or (5) you received compensation or other consideration for providing the Content or personal information. The deletion of your personal information does not ensure the complete removal of that personal information from our systems or the systems of our service providers.
Product owners are always responsible for the photos, videos, and other Personal Information captured of their guests, and Yale provides no remediation for guests to remove photos, videos, or other Personal Information from our systems unless expressly authorized by the registered account of the product owner.
Children’s Privacy
The “service” is Not for or Directed to Children nor anyone under 18 years old; we do not intend to and will not knowingly collect any Personal Information from children under the stated age. If we learn that we have collected Personal Information from an under the age of 18, we will remove that Personal Information immediately and delete it from our servers (if not required or resulted by applicable law and this Privacy Notice). If you believe content from an under 18 years has been posted in our “service,” please notify us by contacting us at privacy[at]august.com. Categories of Personal Information - Unique browser or device identifiers such as cookies, mobile ad IDs (IDFAs for iOS and Android Ad IDs), device hardware identifiers, timestamps, user agent strings, IP addresses, and precise geographic location data.
Purposes for collection and use of Personal Information - We use personal information to facilitate our mobile applications, hardware devices, customer account services, and for marketing or communications.
Categories of sources from which Personal Information is collected - Websites, mobile applications, advertising services, technology platforms, and customer support services.
Categories of Personal Information used - We enable third-party advertising services to use cookies with our website visitors.
Purposes for advertising - Third-party advertising services use cookies associated with our website visitors to facilitate ads to our visitors on other websites.
Categories of Third Parties - Third-party advertising services use cookies associated with our website visitors.
Categories of third parties to whom information was shared for a business purpose - Advertising services, technology platforms, website, and mobile application analytics.
Changes to this Policy
We may update this privacy notice from time to time in response to changing legal, regulatory, or operational requirements. We will take appropriate and feasible steps to notify users of any such changes (including when they will take effect). The latest version of our Privacy Notice is available through our website.
Your continued use of the “service” after any such updates take effect will constitute acceptance of those changes. If you do not accept any updates to this privacy notice, you should stop using this digital “service.”
We will make good faith efforts to resolve any requests to correct inaccurate Personal Information except where (1) the request is unreasonable, (2) requires disproportionate technical effort or expense, (3) jeopardizes the privacy of others, or would be impractical. We will comply with the specific time required in the applicable law to address your concerns, free of charge, if possible, for the business and the allowed number of times, under applicable law guidance.
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