Privacy Policy and Declaration
of Consent to Use of Data

This Privacy Policy shows you which data we record when you visit and use the www.kleverkey.com site and any websites owned or operated by Swissprime Technologies AG (the “Site” or collectively, the “Sites”), and when you use any of KleverKey products, services or applications (such as our mobile application, for ease of read collectively called “the Services”), how this data is used, under what circumstances it is disclosed to third parties and how you can revoke your consent to the usage of your data.

Swissprime Technologies AG takes great care to ensure that all legal requirements are fulfilled in accordance with the high standards of the Swiss Federal Law on Data Protection (Bundesgesetzes über den Datenschutz (DSG), Verordnung zum Bundesgesetz über den Datenschutz (VDSG), Fernmeldegesetzes (FMG) and other).

Changes to Privacy Policy

We may at any time modify or amend this Privacy Policy from time to time. So, we will notify you by email or other messaging systems (sent to the addresses specified in your account), otherwise through the Service or by means of posting an updated version of this Privacy Policy on the Site. We encourage you to periodically review this page for the latest information on our privacy practices. Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service. In all of the above cases, your continued use of the Service after any notice or posted modified Privacy Policy indicates acceptance of the modified Privacy Policy.

Your use of our Service indicates your agreement to this Privacy Policy. If you do not agree to any part of this Privacy Policy, then you should stop accessing the Service.

1. Personal Data

1.1 Collection of Your Personal Data

Service Account Set Up: In order to use KleverKey, you must download our mobile application and set up an account. During this process, we will ask you for your first and last name, email, password and your mobile phone number. You can use the same data to login the KleverKey Website.

Mobile Phone Information: When you download the App, we get information about you mobile phone such as the brand and model and your phones name (i.g. myName iPhone 6 Plus), the OS Version you use, the language settings and a token that enables us to send push notifications to your mobile phone. This information is provided to us by the App Store resp. Google Play Store. Please consult the respective Privacy Policies of Apple on https://www.apple.com/privacy/ and of Google on http://www.google.com/intl/de_ch/policies/privacy/ to learn more.

Purchase Information: If you purchase KleverKey cloud plans from our Site, we request that you provide your name, email address, billing address, resident country, VAT-Number (if any), credit card information and any other information necessary to complete the transaction. Your name, email address and billing address will be stored.

Swissprime Technologies AG does not store your credit card information. Our credit card processing service provider (www.stripe.com) will treat your data according to the required standards and store full payment card information from you when an order is placed. For further information, please refer to https://stripe.com/us/terms.

Please note, that by purchasing a KleverKey Plan you consent to the transfer of your personal data including your credit card information to Stripe Inc., which is situated in California, US. While Stripe Inc. is certified under the Swiss Safe Harbour Treaty, at the time of issue of this Privacy Policy the recently dissolved Privacy Shield Treaty between the EU resp. Switzerland and the US is just about to be put into practice, but is not established yet. Hence, for the time being, there is no guaranty that the US – Government will not access your data at Stripe Inc.

You may at any time refuse to provide this data; however, this may limit our ability to provide the Services to you.

Device and Application Operation: We record information relating to the setup, general performance, and operation of our Service, your application and your KleverKey Devices (“Device”, “Devices”), including Device status, logs of those who use the Device (phone numbers), the guests that you invite and the type of access you have granted to them (one-time or permanent access etc.). We also record those people who have invited you as a guest, to use their devices. We store this data along with your Personal Data and other information about your use of our Service. We use this information to allow you (and us) to operate and monitor your Devices and our Service.

If your Device is equipped accordingly, we are able to provide you with data on the temperature, air humidity, location and other physical data from where the Device is situated. Furthermore, the battery status of your Device is registered. Please note, that such physical data is not connected to a person, i.e. the Swiss Federal Law on Data Protection does not apply to it.

As Device owner, you can access your account anytime and inspect the use of your Devices by yourself and by all the guests you have invited.

As a guest, you are able to inspect your own usage of the Device.

Webhook Services: Upon your own discretion, you may enable webhooks to get notifications about the events related to your Devices. For example, you can setup messages whenever one of your Devices is operated via the Service. If you opt for webhook-services, you consent to the transfer of your Personal Data to the respective Service Provider (e.g. IFTTT or others). Please note, that such service provider may be situated abroad, which means that you consent to the transfer of your data outside Switzerland.

1.2 Purpose of Collection

Your Personal Data is used

to provide, administer and improve our Services
to fulfill requests you may make
to personalize your experience
to provide Service announcements
to provide you with further information and offers from KleverKey or Swissprime Technologies
to administer promotional activities and
to comply with our legal obligations.

2. Website Visitors and App-Use

2.1 Data we collect via the Website and/or via Use of the App

Cookies: Like many websites, we collect certain information through the use of “cookies,” which are small text files that are saved by your browser when you access our Services. We (and our third-party analytics providers, such as Google Analytics) may use both session cookies and persistent cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Services. We may also use cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services. Unlike persistent cookies, session cookies are deleted when you log off from the Services and close your browser.

Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. Please note, however, that if you don’t accept cookies, you may not be able to access all portions or features of the Services.

The function ”Remember Login” only works if you enable your browser to accept permanent cookies. By doing so, you consent to such use of cookies in general and to the collection of personal data which can be reused the next time you activate the website.

Log-Data: Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both account holders and non-account holders. Log Data may include information such as a user’s Internet Protocol (IP) address, location, device and browser type, operating system, the pages or features of our Services to which a user browsed and the time spent on those pages or features, frequency with which the Services are used by a user, search terms, the features and links on our Services that a user clicked on or used, and other statistics. We use this information to administer the Services and we analyze this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our users’ needs and preferences.

Google Analytics: We too make use of Google Analytics in order to get clues about the traffic on and the usage of our Service, in order to optimize it. In order to do so, the Google Analytics Service sends a cookie to your device, where it provides information about your browser and operating system, the sites you have visited before (Referrer URL), date and time of your visit and more and transfers this information to Google’s servers in the US where it is stored. We only transfer masked IP-addresses, i.e. anonymized data. Hence, neither Google Analytics nor we are able to identify anybody by this data. Furthermore, Google Analytics only provides aggregated and anonymized data. In no event, IP-addresses are associated with other personal data. Hence, a private allocation of the data is not possible.

Please find further information in the Google Analytics Privacy Policy here https://support.google.com/analytics/answer/6004245?hl=de .

If you do not consent with the analysis of your data, click here to find out how to disable Google Analytics https://tools.google.com/dlpage/gaoptout?hl=de.

2.2 Purpose of Collection

The purpose of these data collections is to enable us to better understand your needs and interests, and to improving our services.

By using the Service, you consent to such use of your data.

3. Guest Access

As part of our Services, you may give others (“guests”) a permanent or a limited permission to access your Device – e.g. to unlock your Device. You are responsible for all uses of your account, so be careful to secure this information and only give access to people you trust.

In connection with the guest invitation process, we will ask for access to your contact list. We will only access such information with your express consent. We will only store information of contacts that you add as guests.

Additionally, your Personal Data, mobile phone and Service information may be shared with the guests, such as your name and Device location, and the status of the Device (locked, unlocked etc). As every guest will have to register for our services and download the App, we will also collect Personal Data about the guests that you invite in order to allow them to have access to your Device and Service. All such information (including their Service usage information) is subject to, and will be used and disclosed as set forth in, this Privacy Policy.

Guests should be aware that the person(s) providing access to a specific Device will be able to get information about the guest’s usage of the Device and our Service and may revoke or limit access rights in their discretion without notice.

All guests expressly consent to such use and disclosure as a user of the Service. If you are a guest and do not consent to such use, you should not consent to using the Service.

4. Third Party Data Collection

Social Media Links There are social media-links or –buttons on our website, such as Facebook, Twitter, and others.

These links or buttons are deactivated by default Once activated, these links or buttons provide information such as your IP-address, the URL of the sites visited before (Referrer URL) and report it to the Social Media Provider. They may also make a direct connection to your respective social media account.

By activating the links or buttons, you consent to this data transfer. For further information, please visit the Privacy Policies of the Social Media Provider in question.

For Facebook: https://www.facebook.com/about/privacy/

For Twitter: https://twitter.com/privacy

If you don’t consent with this, do not activate the links or buttons.

5. Newsletter and Other Information

As you will submit your email address via our Services we may use this information to send you news about KleverKey-related services, products or promotions. To do so, we may work with one or more service providers to administer these messages. Swissprime Technologies AG will secure, that such Service Providers will regard all the legal requirements when treating your data.In no case your email addresses will be shared with spammers or any other third parties.

You have the ability to opt out of marketing-related e-mails by logging in and changing your account settings or by clicking on the “unsubscribe link” in each such e-mail. In some of our communications, we use tracking means, such as a “click-through URL” linked to content on the Site. We track this data to help us measure the effectiveness of our customer communications.

You herewith consent to the use of your data for newsletter services.

6. Disclosure to Third Parties

We do not disclose your Personal Data to other organizations except if we decide to work with such organizations in order to be able to provide the Services to you. These third parties may have access to your Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Swissprime Technologies AG will secure, that the Data is save at all times and that the legal requirements according to this Privacy Policy are respected.

If you invite a guest to access your Device, then we will share certain elements of your information with them (name, Device location etc.) in order for them to understand the invitation and access the device. We will also similarly share their information with you. Swissprime Technologies AG may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets.

Swissprime Technologies AG may sell data to third parties only if irrevocably anonymized prior to the transfer of such data.

7. Links to Other Sites and Services

The Services may contain links to other websites or services. The fact that we link to a website or service is not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services. Other websites and services follow different rules regarding the use or disclosure of the potentially personal data you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit and services that you use.

8. Changing or Deleting Your Information

All KleverKey users may review, update, correct or delete their Personal Data in their registration profile by logging into their account and changing the “user settings” associated with their account. Removing your information may limit our ability to provide the Services to you. If you completely delete all such information, your account will be deactivated and you may lose access to the Service and your use of the KleverKey devices. You may also contact us at support@my-lock.com if you have questions or concerns. We’ll take steps to modify or delete your information as soon as is practical, but some information may remain in archived/backup copies for our records or as otherwise required by law.

9. Right to Information and Revoke of Consent

You can at any time request information about the storage of your data. If you wish to get this information, please contact us in writing and include a proof of identity.

Swissprime Technologies AG
Moosacherstrasse 14
8804 Au ZH
Switzerland
hello@swissprime-tech.com

You can at any time resign from your consent to the collection and storage of your data by stopping the usage of the Service and by deleting your account.

Please note, that we may be obliged by law to keep all or parts of the data related with a deleted account for some more time in the future, but we will not disclose any of such data to anybody, unless forced so by law, by a court order or a compulsory demand of a public authority.

10. Place and Duration of Storage of Data

Our servers are located in Germany. We use the latest technologies to securely store the user data. It is not possible for anyone outside our organization to access the data. All communication between your mobile device and the Device as well as the mobile device and the cloud itself is encrypted.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

We retain the data for as long as needed to provide you Services, subject to this Privacy Policy. Swissprime Technologies AG may be forced to retain and use the data as necessary to comply with legal obligations.

11. International Transfer

Important for non-German-Residents: If your live outside Germany, by using the Service, your data will be transferred to Germany and possibly other countries.

The Data Protection Laws of Germany and the EU provide adequate protection.

Effective: July, 2017