HID Mobile Access Application Privacy Notice

This Privacy Notice was last updated: October 8, 2018

This Privacy Notice forms a part of the HID Mobile Access License and User Agreement (the “Agreement”) and is part of the agreement between You and HID Global Corporation, an ASSA ABLOY group company, and its subsidiaries and affiliates (“HID” or “We” or “Us” or “Our”) for the Licensed Materials and Services (both as defined in the Mobile Access License and User Agreement) (the “Agreement”)). Capitalized terms in this Privacy Notice have the meaning given to them in the Agreement.

We respect Your right to privacy and are committed to following applicable data protection rules to safeguard Your rights. We want to make sure that 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.

We collect some information about You so that We can provide You with the Licensed Materials and Services. This Privacy notice describes the information We collect about You (“Data”) and how that Data is treated and for what purposes We may share the Data and how You can contact Us about Your Data.

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 Our existing clients (an “Enterprise”), the Enterprise may also receive and use some or all of the Data, either directly from You or from Our systems.

The Enterprise will be collecting and/or using the 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 the 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 Data, including, but not limited to the HID Secure Identity Services Portal or the HID Origo Management Portal (“Portal Sites”). We will use data that we receive through either Portal from the Enterprise to provide the Services and as set forth in separate Portal Sites Privacy Notices. Such Data that we receive from the Enterprise through the Portal Sites 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 and HID may notify individuals of such changes through contact information that HID has for such individuals prior to the change becoming effective. If HID amends the Notice, the new Notice will apply to Personal Data previously collected by HID only insofar as the rights of the individual affected are not reduced.

THE DATA WE COLLECT ABOUT YOU

When you download and use the HID Mobile Access app (“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 the Data will only be used in accordance with this Privacy Notice.

HOW IS YOUR PERSONAL DATA COLLECTED?

We 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.
  • 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

We collect Your 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 Data on the need of Your Data in order to provide You with the Licensed Material and Services, as stated above. To the extent that Your 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 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 the 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 Data on Our and/or HID Global Corporation’s behalf, in accordance with the purposes in Section above.

To the extent that Your 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 Data in compliance with applicable data protection regulation and this Privacy notice.

We do not sell or trade the Data or collect or use it for direct marketing purposes.

If applicable, 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 to whom We may assign or transfer Our rights or duties under this agreement or under any other agreement We may have with or concerning You;
  4. Persons in connection with any 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
  5. Third parties, if so required to comply with mandatory law or requirements or to address fraud or technical issues.

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

We 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 Data may therefore take place in countries other than Your home country. 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 the Data as the country where You are located and may provide You with fewer legal rights in relation to the 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 will take 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 authorizes access to certain authorized personnel.

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

DATA RETENTION

We will retain the 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.

The Data will be deleted or anonymized if:

  1. The purpose of collection and use of Data has been achieved (as described above)
  2. The business for the Licensed Materials or Services concerned is discontinued (if earlier than achievement of the purpose as stated above)
  3. In relation to Data used only for purposes not directly related to providing the Licensed Material or Services to You (as further described under the Section above), if You request that Your Data is deleted by contacting Us (for contact information please see Section “Contact Us” below).

Anonymous information used purely for statistical purposes may be stored for a longer period than set out above.

CHILDREN’S PRIVACY

The Licensed Materials or Services are not directed to children under the age of 18, and We do not knowingly collect Data from children under 18.

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]