iLOQ NFC MOBILE ACCESS
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.
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.
We will, inter alia, collect
the following personal data on you through the App:
number of the SIM-card of your mobile device
of your mobile device
Log data (e.g.
what lock has been attempted to be opened by the App, when it has happened and
what was the outcome)
related to the opening functionalities, performance and other general functions
of the lock
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.
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.
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).
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.
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.
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.
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.