Privacy Policy and Declaration to Use of Data

This Privacy Policy shows you which personal 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 personal 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), Ordinance to the Swiss Federal Law on Data Protection (VDSG), Federal Telecommunications Act (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 appropriate electronic 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.

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 and further personal data such as pictures (optional) to provide the service and correspond to the corresponding security requirements. You can use the same data to login the KleverKey Website.

Mobile Phone Information: When you download the App and during registration process (Service Account set-up), we get information about your mobile phone such as the brand and model and your phone’s 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.

Purchase Information: If you purchase KleverKey service plans from our Site, we request that you provide your name, email address, billing address, resident country and address, VAT-Number (if any), company name, credit card information and any other information necessary to complete the transaction. Your name, company 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 agree to the transfer of your personal data including your credit card information to Stripe Payment Services Europe Ltd. Which may transfer data to Stripe Inc., which is situated in California, US. While Stripe Inc. is certified under the US-Swiss Privacy Shield.

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

Device and Application Operation: We record personal data as listed below relating to the setup, general performance operation and improvement of our Service, your application and your KleverKey Devices (“Device”, “Devices”), including Device status, IP address, logs of those who use the Device (phone numbers), the name, email address, phone number, IP address of your 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 such as telephone number, status of usage, time stamps, usage via corresponding interfaces, battery or GPS location (optional) etc.. 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 can 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.

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.

Every user can inspect his/her own usage of the Device.

Webhook Services and KleverKey API: Upon your own discretion, you may enable webhooks to get notifications about the events related to your Devices.  A webhook (also called a web callback or HTTP push API) is a way for an app to provide other applications with real-time information. A webhook delivers data to other applications as it happens, meaning you get data immediately.

You may also connect third party tools by using KleverKey API.

For example, you can setup messages whenever one of your Devices is operated via the Service. If you opt for webhook-services or are using KleverKey API, you consent to the transfer of your Personal Data to the respective Service Provider (e.g. IFTTT or others).

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 have 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 do not 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.

The following cookies are used on our website my.kleverkey.com:

Cookie Name Purpose
ASPXAUTH Authentication cookie
ARRAffinity Keep visitor’s session
RequestVerificationToken Anti-request forgery
stripe_mid Process stripe payments

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 (subscriber) and non-account holders. Log Data may include personal data such as a user’s Internet Protocol (IP) address, location, device and browser type, operating system of the Device, the pages or functionalities 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 analyse this information to improve and enhance the Services by expanding their features and functionality and tailoring them to our users’ needs and preferences.

Google Firebase: We make use of Google Firebase to measure your usage of the App to improve the Service.

We only transfer masked personal data, i.e. anonymized data. Hence, neither Google Analytics nor we can identify anybody by this data. Furthermore, Google Analytics only provides aggregated and anonymized data.

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

Google Analytics: We too make use of Google Analytics on our website www.kleverkey.com in order to get data about the traffic on and the usage of our website 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. Hence, neither Google Analytics nor we are able to identify anybody by this data. Furthermore, Google Analytics only provides aggregated and anonymized data.

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

If you do not want your data to be analysed, 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 the data collections as defined is to enable us to better understand your needs and interests, and to improve our Services.

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.

We will only access such information with your express consent. We will only store information of contacts that you add as guests.

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

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 and products. 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.

Promotions will only be sent to you if you have subscribed and agreed to it (opt-in).

You have the ability to opt out of marketing-related e-mails 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 for the exchange of quality assurance with provider of key solutions or 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.

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 tell us to 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@kleverkey.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 withdraw 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 Your data. All communication between your mobile device and the Device as well as the mobile device and the cloud itself is encrypted for sensitive data.

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, make accessible to authorities or use your personal data as far as necessary to comply with legal obligations.

11. Applicable law and place of jurisdiction

This Privacy Policy shall be ruled exclusively by the material laws of Switzerland, under exclusion of the United Nations Convention on Contracts for the International Sale Goods, 11 April 1980 (Vienna Convention) and the Federal Code on Private International Law.

Exclusive venue are the courts at the registered office of Swissprime Technologies AG, Switzerland.

May 2018