iLOQ NFC MOBILE ACCESS

PRIVACY POLICY 2017

1. Introduction

This iLOQ NFC mobile access privacy policy (“Policy”) describes how data of the users is collected, used and disclosed when the users use iLOQ Oy’s (“iLOQ”, “we”, “our”, “us”) iLOQ NFC mobile application (“App”).

The App is offered and intended for the use of an authorized user (“User”, “you”, “your”) as a mobile key for opening locks and accessing certain premises or equipment managed by an enterprise customer of iLOQ locking services (“Enterprise”). The App will provide an access to designated properties managed by the Enterprise upon and subject to the Enterprise having registered the User and the respective access rights in the iLOQ locking service (“iLOQ Service”).

This Policy together with the iLOQ NFC Mobile Application EULA governs the use of the App by you. If you do not agree to the terms of this Policy, do not use the App and delete the App from your device.

2. Role of iLOQ

The Enterprise is the data controller in relation to any of your personal data processed and collected in relation to the iLOQ Service and the App. The Enterprise is responsible for obtaining your consent or having other legal basis for processing and using your personal data in relation to the iLOQ Service or the App, as well as for all other obligations under the applicable laws attributable to the controller of personal data. We are not responsible for the personal data the Enterprise collects and processes or how they process such personal data. The Enterprise may have their own privacy policies governing their processing of personal data, which you should review.

iLOQ acts as a data processor for the Enterprise. We only process your personal data in order to provide the iLOQ Services to the Enterprise under and in accordance with the respective service agreement. In order for you to be able to use the App, we may process information on you such as your name and other credentials. Still, such processing is done on behalf of and based on the information provided by the Enterprise for the iLOQ Services.

You acknowledge and are aware, that your use of the App has been requested by the Enterprise, wherefore the Enterprise may receive and use your personal data in relation to the App or iLOQ Services either directly from you or from our systems.

3. Data Collected

We will, inter alia, collect the following personal data on you through the App:

1. Serial number of the SIM-card of your mobile device

2. IMEI-code of your mobile device

3. Log data (e.g. what lock has been attempted to be opened by the App, when it has happened and what was the outcome)

4. Technical data related to the opening functionalities, performance and other general functions of the lock

5. Other equivalent information related to your use of the App or iLOQ Services via the App

In addition, the Enterprise you belong to may upload and process other personal data on you (such as name and contact details) in the iLOQ Service the Enterprise uses to enable you to use the App. However, such processing and types of data collected is at the Enterprises discretion and is separate from the data collected via the App.

Simply downloading the App from the app store used by your device does not cause any of your personal data to be collected and stored to our systems. Your personal data will only be collected (in accordance with what is stated in this Policy) once your device where the App was installed is registered as a mobile key. However, please note that app stores do collect your personal data when you download apps from them. Such data collection is governed by the privacy policies and use terms of the app stores, and you should refer to them when it comes to the app stores’ collection of your personal data.

4. Why Data is Processed

Primarily we will process your personal data to provide you the App and allow you to use the iLOQ Services through the App, fulfill your other requests related to the App or iLOQ Services or as otherwise may be necessary for the performance of the App or iLOQ Services. We may also process and use your personal data to ensure the functionality and security of the App or iLOQ Services, to provide the Enterprises necessary information for them to identify you, and to prevent and detect fraud and other misuses.

We may process and use your personal data to communicate with you, for example, to provide information relating to the App or iLOQ Services you are using or to contact you for customer satisfaction queries.

We may process and use your personal data to develop the App, iLOQ Services or other products and services we provide. However, we mostly use anonymized, aggregate and statistical information in the development of our products and services, and not data directly identifiable to you.

5. Disclosures of Data

We may disclose and transfer your personal data to our affiliates, as well as to third parties who process personal data on our behalf for the provision of the App or the iLOQ Services, such as technical service providers and our subcontractors.

We may also disclose or transfer personal data if we decide to sell, buy or otherwise reorganize our business, or where such disclosures are necessary to defend iLOQ’s legitimate interests e.g. in legal proceedings or to verify or enforce compliance with the our policies.

We store and process the personal data mainly within the EU and European Economic Area (“EEA”). However, some of the personal data may be transferred and processed also outside the EEA, including in situations where our server facilities are located outside the EEA.

All disclosures and transfers of personal data are performed in accordance with the applicable data protection laws. We will ensure that sufficient security measures are applied where personal data is disclosed or transferred (e.g. through data transfer agreements).

6. App Security

iLOQ has implemented necessary measures to ensure that all personal data collected and processed through the App kept confidential and secured. We always implement appropriate technical and organizational security measures to prevent and minimize risks related to processing personal data. These security measures include, where appropriate, use of firewalls, access rights management systems (both manually and electronically), personnel training, secure server facilities and encryption.

7. Your Rights

You have certain rights under the applicable data protection laws, such as the right to access the information held about you and have any inaccuracies corrected. If you wish to make use of such rights, you should primarily contact the Enterprise who is the data controller of your personal data.

8. Contact Details

For the purpose of this Policy and as stated above, the Enterprise is the data controller of your personal data and you should primarily contact the Enterprise if you have questions on the processing of your personal data.

However, if you have questions on how we process your personal data on behalf of the Enterprise, you may contact us at the contact details available in the App or the iLOQ website at www.iloq.com.

9. Changes to the Policy

We may amend this Policy from time to time. We will use reasonable efforts to notify our Users before such change through the App. By continuing to use the App or iLOQ Services after such notification, you expressly acknowledge and agree to the changes.