This Privacy Notice was last updated: October 11, 2022
HID provides this Privacy Notice to demonstrate our commitment to privacy. This Privacy Notice applies to your use of the [HID Mobile Access] (“Application”) on a mobile device.
You should bear in mind that your use of the Application is at the request of an HID customer (“HID Customer”). The HID Customer may also collect and use your personal data independently of us. This Privacy Notice does not apply to any personal data you provide directly to the HID Customer.
Changes to the Privacy Notice
This Privacy Notice may be updated from time to time for any reason. You are advised to consult the Privacy Notice regularly for changes via the Application. By continuing to use the Application after such notification, you are expressly acknowledging and accepting the changes.
What information does the Application obtain and how is it used?
When you install and use the Application we collect:
Technical Information about the Device and Application
- Device manufacturer and model
- Hardware capabilities, such as Bluetooth and NFC support
- Operating system version
- Identifier and version information for the app
- Unique push notification identifier
- Unique application identifier
Usage Information and Analytics
- Application state, events and usage statistics
- Reader interaction logs (including reader identifiers and technical reader information)
- Error logs
- Country and city based on IP address lookups
This information is used to:
- 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
- Provide you with software updates and support
- Improve and develop new products and services
- Communicate with you about the services
- Fulfill our legal and administrative obligations
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 the data will only be used in accordance with this Privacy Notice.
Does the Application collect precise real time location information of the device?
No. Enabling Location Services in the device is voluntary. We do not collect precise real time location information of the device.
These services are used by the device to optimize the App’s ability to communicate with readers over BLE communication protocol. The App accesses but does not store your device’s location data to determine your current location in conjunction with presenting a Mobile ID to a reader.
Do third parties see and/or have access to information obtained by the Application?
Yes. We will share your information with third parties only in the ways that are described in this privacy notice.
We may share the data we collect about you:
- as required by law, such as to comply with a subpoena, or similar legal process.
- when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- with our trusted service providers who work on our behalf – such service providers do not have an independent use of the information we disclose to them and have agreed to adhere to rules and standards substantially similar to those set forth in this Privacy Notice.
- if HID is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information; or
- to enable HID to address fraud or technical issues
What are my opt-out rights?
Opt-out of information collection by uninstalling the Application – You can stop collection and access of information by the Application by uninstalling the Application. You may use the standard uninstall processes available in your mobile device or via the mobile application marketplace or network.
Managing Your Information
Requests to manage your information should be directed to the HID Customer who is controller of your data.
We do not use the Application to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at: [email protected]. We will delete such information from our files within a reasonable time.
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our application. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
USERS IN THE EUROPEAN UNION
If you’re a user in the European Union, you should know that HID is the processor of your personal information, which means that we are providing a service to an HID Customer. 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, 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 provided 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 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.
HID may process personal information related to individuals in the European Union (EU) and may transfer that information from the EU through data processing agreements based on the EU Standard Contractual Clauses. We are committed to ensuring your information is protected and apply safeguards in accordance with applicable law. Data collected in the EU and European Economic Area (the “EEA”), may be stored, processed, or transferred outside of the EEA.
If you’re based in the EU, you can file a complaint with the supervisory authority in your Member State. For example, if you’re based in Ireland, you can file a complaint with the Data Protection Commission.
HID Global Corporation
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Austin, TX 78753