HID® Mobile Access® Application Privacy Notice

This Privacy Notice was last updated: March 13, 2020

HID Global Corporation, an ASSA ABLOY group company, ("HID") provides this Privacy Notice in order to demonstrate HID's commitment to privacy. We collect some information about you so that we can provide you with the Licensed Materials and Services, as defined in the HID Mobile Access License and User Agreement (“Agreement”). We want to make sure you understand the type of information we collect about you, how it is used, how we protect it and your rights with regard to your personal data when you use the HID Mobile Access Application (App).

ENTERPRISE
You should also bear in mind that, as your use of the Licensed Materials and Services has been requested by a company that is one of HID’s customers (an “Enterprise”), the Enterprise may also receive and use some or all of your personal data, either directly from you or from our systems.

The Enterprise will be collecting and/or using your personal data independently of us, and you agree that we are not responsible for the type of information that the Enterprise collects and/or uses about you, or how and why the Enterprise collects and/or uses your personal data. The Enterprise should give you a copy of its privacy policy which describes what information it collects and/or uses about you and why. This Privacy Notice does not apply to the systems that the Enterprise may use to upload your personal data. We use data that we receive from the Enterprise to provide the Services. Personal data that we receive from the Enterprise may include your name, photo, phone number, email address, ID and password, and other data which the Enterprise uses to identify you when making it possible for you to use the Service.

Changes to the Privacy Notice

This Notice may be updated from time to time as the Services and Apps change and expand. HID suggests that each individual review the Notice periodically. In the event of a material change to the Notice, HID will notify you of a change notice through the App. If HID amends the Notice, the new Notice will apply to personal data previously collected by HID only insofar as your rights are not reduced.

THE DATA WE COLLECT ABOUT YOU

When you download and use the App, we automatically collect technical information about the mobile device and application, as well as usage information.

Technical Information about the Device and Application

  1. Device manufacturer and model
  2. Hardware capabilities, such as Bluetooth and NFC support
  3. Operating system version
  4. Identifier and version information for the app
  5. Unique push notification identifier
  6. Unique application identifier
  7. Carrier

Usage Information and Analytics

  1. Application state, events and usage statistics
  2. Reader interaction logs (including reader identifiers and technical reader information)
  3. Location data (e.g. GPS positions) in conjunction with presenting a Mobile ID to a reader
  4. Error logs
  5. Country and city based on IP address lookups

If we need to collect additional information or access certain parts of your Device, we will first inform you and/or ask for your consent (as applicable) and your personal data will only be used in accordance with this Privacy Notice.

HOW IS YOUR PERSONAL DATA COLLECTED?

HID will collect and process the following data about you:

  • Information we collect about you and your device. When you install and use the App, we will automatically collect personal data including device and usage data. We collect this data primarily using a software development kit we use in the App.
  • Location Data. We use GPS technology to determine your current location in conjunction with presenting a Mobile ID to a reader. Additionally, we use Location Services to improve performance in reader detection. Disabling Location Services will provide a lesser user experience. The GPS data collected provides approximate positional information and is deidentified and stored separately from other user information to prevent correlating GPS data with a specific user or device.
  • Unique application numbers. When you install the App, a unique identifier for the application will be generated and sent to Us. Additionally, when the Enterprise enables new features or services, new unique identifiers may be generated and shared with us.

HOW WE USE YOUR PERSONAL DATA

HID collects your personal data to:

  1. License the Licensed Materials or Services to you and to enable Us to provide you with the Licensed Materials and Services and any associated products or services
  2. Provide you with software updates and support
  3. Improve and develop new products and services
  4. Communicate with you about the Services
  5. Fulfill our legal and administrative obligations
  6. Enforce this Privacy Notice and the Mobile Access License and User Agreement;
  7. Protect the rights, property or safety of Us, our customers or others

We base our right to collect your personal data on the need to provide you with the Licensed Material and Services, as stated above. To the extent that your personal data is used to improve and develop new products and services or to maintain and manage our websites and other related services, we base our use of your personal data on our legitimate interest to perform such actions.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

DISCLOSURES OF YOUR PERSONAL DATA

We will share your personal data with other companies in the ASSA ABLOY group, as well as third party service providers to enable them to perform functions of the Services and to process your personal data on our behalf, in accordance with the purposes in Section above.

To the extent that your personal data is disclosed or transferred to third parties as described above, for purposes not directly related to providing you with the Licensed Material or Services, we are responsible for ensuring such third parties’ use of your personal data in compliance with applicable data protection regulation and this Privacy Notice.

We do not sell or trade your personal data or collect or use it for direct marketing purposes. Location information is not disclosed to or otherwise shared with any third party.

If applicable, your personal data may also be transferred to:

  1. Local or foreign regulators, governments and law enforcement authorities, including tax collection agencies and stock or other exchanges;
  2. Local and foreign courts, tribunals, arbitrators or other judicial committees;
  3. Persons in connection with a sale, merger, acquisition, disposal, reorganization or similar change of our business (including any potential or actual purchaser of that business and that purchaser's advisors); and
  4. Third parties as required to comply with mandatory law.

Disclosure Required by Law

HID may cooperate with law enforcement agencies in identifying users who use the Service for illegal activities. Therefore, HID will respond to subpoenas, warrants, or other court orders regarding information concerning any user. HID will, at HID's discretion, disclose information, including personal data, if HID reasonably believes that HID is required to do so by law, that such disclosure is necessary to protect HID from legal liability, or that HID should do so to protect the integrity of the Service.

INTERNATIONAL TRANSFERS

HID will share your information with other companies in our group or with our trusted subcontractors in order to provide the Services and for the purposes set out in this Privacy Notice. Processing of your personal data may therefore take place in countries other than your home country. your personal data collected in the European Union (the “EU”) and European Economic Area (the “EEA”), may be stored, processed or transferred outside of the EEA, as described in this Privacy Notice. The destination country may not offer the same level of protection of your personal data as the country where you are located and may provide you with fewer legal rights in relation to your personal data.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Privacy Shield Certification

HID complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework(s), as applicable, as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland, as applicable, to the United States. HID has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List: https://www.privacyshield.gov/. To view our Privacy Shield Statement refer to the HID Global Privacy Notice page here: https://www.hidglobal.com/about/privacy.

DATA SECURITY

Wherever personal data is within HID or on its behalf, HID takes reasonable steps to protect the personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction. HID trains employees on its Notice guidelines and makes the Notice available to its business partners. In addition, HID and its business partners enter into confidentiality agreements that require that:

  1. Care and precautions be taken to prevent loss, misuse, or disclosure of personal data
  2. Any service providers only use personal data to perform services on behalf of HID. It is important for each Client to protect against unauthorized access to Client's online account password and to Client's account which holds personal data of Client and its Constituents.

In addition, HID takes precautions to protect personal data processed by the Services: HID uses industry-standard security measures, such as firewalls and encryption technology, which are reasonably designed to safeguard the confidentiality of personal data. HID also periodically conducts security reviews and assessments both internally and via third party independent professionals. HID stores personal data on secured servers and only allows access to certain authorized personnel.

We have put in place procedures to deal with suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

DATA RETENTION

HID will retain your personal data for as long as is necessary for the relevant activity or services described above or for as long as we are lawfully required to do so.

Your personal data will be deleted or anonymized if:

  1. The purpose of collection and use of your personal data has been achieved (as described above).
  2. We are instructed to do so by the Enterprise who has requested us to provide the Service.
  3. You make a request that your personal data is deleted by contacting the Enterprise who has requested us to provide the Service and they instruct us to do so.

Anonymous information used for statistical purposes may be stored for a longer period than set out above. Deidentified GPS location data (as stated above) is stored for a maximum of three (3) years.

CHILDREN’S PRIVACY

The Licensed Materials or Services are not directed to children under the age of 13, and we do not knowingly collect personal data from children under 13.

YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. you also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    (a) if you want us to establish the data’s accuracy;
    (b) where our use of the data is unlawful but you do not want us to erase it;
    (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

For more information regarding inquiries to access personal data from HID, please refer to General Data Protection Regulation Personal Data Inquiries.

Contact Us

HID Global Corporation
611 Center Ridge Drive
Austin, TX 78753
[email protected]