PKinno takes your privacy very seriously. We created this Privacy Policy (“Privacy Policy”) to explain our treatment of personally identifiable information (“PII”) we collect when you use or access our products and services. It includes information about how PII is used and shared and about your choices regarding your PII. Please read this Privacy Policy carefully. When you use the Hardware and/or the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy. All other capitalized terms not defined in this Privacy Policy shall have the meaning set forth to such terms in the Terms of Service.

The Mobile Apps provided by PKinno are intended for use only in connection with the PKinno System. You hereby acknowledge and agree that you may only use the Mobile Apps, the System and any other Services provided by PKinno within the United States, even if you are able to download the Mobile Apps outside of the United States.

 

I.    Scope

This Privacy Policy covers:

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• PII collected when you, your Users use or access the Services.

• PII that our business partners share with us or that we share with our business partners.

 

This Privacy Policy does not cover information collected by individuals or entities who provide third party websites, services or applications (“Third Party Services”) or to individuals that we do not manage or employ, even if you access, encounter or interact with them through the Services (e.g. if you click on links to those Third Party Services on the Site or Apps). While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we are not responsible for the privacy policies or practices of Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies.

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II.    Uses of Information

 

We use information, including PII to:

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• Personalize, improve and operate our business and the Services

• Better understand your needs and interests

• Fulfill requests you may make related to the Services, including the processing and facilitation of transactions you conduct on the Services

• Provide Service announcements

• Provide you with further information and offers from us or third parties

• Comply with our legal obligations, resolve disputes with users, enforce our agreements

• Protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity

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III.    Types of Information Collected

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a.    We receive information about you from various sources, including:

 

• If you register for the Services, through your user account on the Services (your “Account”)

• Your use of the Services generally

• Third party websites and services, such as any integrated service providers or third party social media services you use in connection with the Services

 

The type of information PKinno collects from you depends on the type of user you are and your Access Levels. For more information about user types, please review the Terms. However, most categories of information are collected across all user types, so it is important to read through all the categories of information below, in case they apply to you.

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b.    Account and Setup Information: When you create an Account, you will provide information that could be PII or that could otherwise identify you or your location. The exact categories of information you provide will depend on the type of Account but almost all Accounts will generally require you to provide the following:​

• Name

• Password

• Email address

• Profile

 

This information is used to provide you with the Services, and may be shared with other users or our business partners to provide you with the Services. For example, if you are a Manager or Owner granting access to a User, some of your Account profile information, such as your name and the the Hardware’s location, may be shared with the User so that the User can correctly identify the location to which you are granting them access.



User information is shared with the applicable Hardware’s Manager and Owner. More information about the sharing of User information is provided in the “Information Shared With Other Users” section below.

By using the Services in any manner, a User hereby expressly consents to the collection, storage, use and disclosure of their information, which may include PII, in accordance with this Privacy Policy. If you are a User and do not consent to any of the foregoing, you must not use or access the Services, including any Hardware.

If you are a Manager or Owner, please ensure that you have a User’s consent to the collection, use, storage, and disclosure of their information, including their Images, in accordance with this Privacy Policy before (i) providing such information to the Services or (ii) inviting such User to use the Services, including by granting them access through a Code. By inviting a User to use the Services or providing a User with a Code through the Services, you represent and warrant that you have all necessary consent to share such User’s information, including their PII, with PKinno for use in accordance with this Privacy Policy.

 

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c.    Device and Application Information: We may collect some Device-specific information when you access the Services using a Device, such as when a Device interacts with Hardware (e.g. when it unlocks or syncs with a PKinno electronic physical access control product). Device information may include:​

• Unique device identifiers

• Network information such as Your internet service provider

• Hardware model

• Information about the ways in which the Device interacts with our services

• Operating systems of user devices

• Date and time of access

 

We use Device information for Service support, maintenance and diagnostics, such as to troubleshoot issues with your Hardware or the Apps when you request support. We may share Device information with providers of Third Party Services in connection with such support.

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d.    Location Information: When you use certain features of the Services, such as the Apps, we may receive, store and process information about your location, including general information (e.g., IP address or zip code) and more specific information (e.g., GPS-based functionality on Devices used to access the Services). If you do not want your Device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your Device. Please note that if you disable such functions, certain parts of the Services may not work.

 

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e.    Other Information Collected in Providing the Services: We collect information relating to the setup, general performance, and operation of our Services, including the Apps and the Hardware, including:​

• Device status

• Access logs

• Frequency of use of internal and external services

• Frequency of Code creation and use

• Data for fulfillment of legal and regulatory requirements

 

We use this information to operate, monitor, maintain and improve the Services, and to allow you to operate, monitor and maintain your Account and your Hardware (if applicable).

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f.    Usage of Service Providers: The Services may include integrations with Third Party Services (for example, a cleaning or delivery service to which you grant access). If you use these Third Party Service through our Services, we may collect and store information about your use of the integrated services. We use this information to improve our Services and may share the information with the Third Party Service providers to help them improve their products and services. Often this requires that the third-party providers have access to your IP addresses, because without the IP addresses they would not be able to send the content to your browsers. Please note that we do not control these Third Party Service providers and cannot take responsibility for the content, privacy policies or practices of those Third Party Services.

 

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g.    Purchase and Financial Information: We may in the future allow you to purchase one of our Services or otherwise make a purchase through the Services. If you make such purchase, we may request information that is necessary to process and complete the transaction, including:​

• Name

• Email address

• Billing and shipping addresses

• Credit card information

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We do not collect financial information, such as your payment method (valid credit card number, type, expiration date or other financial information); that information is collected and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy.

We may in the future request and receive some of your financial information from our Payment Processor for the following purposes:​

• Completing transactions you have initiated through the Services

• Enrolling you in discount, rebate, and other programs in which you elect to participate

• Protecting against or identifying possible fraudulent transactions

• Otherwise as needed to manage our business

 

We use and disclose information collected in connection with your transactions to process and facilitate your order (or return, if applicable), which may require disclosure to our third party business partners.​

 

 

h.    Information Collected Using Cookies: Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit.

We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services. Our cookies do not, by themselves, contain PII, and we do not combine the general information collected through cookies with other PII to tell us who you are. We do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.
 

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i.    Non-PII: We may automatically collect and use information about the way users (both registered and unregistered) interact with the Services. Some of this information is derived from PII, but we anonymize or aggregate it so that it does not identify the individual from whom it was derived (resulting in “Non-PII”). Non-PII is not personally identifiable and cannot be tied back to the user from which it was obtained.

Non-PII enables us (and third parties we authorize) to figure out how and how often users engage with different parts of the Services so that we can analyze and improve them. We use Non-PII for:​

• Industry analysis

• Marketing and advertising

• Facilitating collection of data concerning your interaction with the Services (e.g., what links you have clicked on)

• Fighting spam/malware

• Other business purposes (e.g., by reporting on trends in the usage of hardware and our Sites or Services)

 

We may share Non-PII with our partners, service providers and other persons with whom we conduct business so that our partners can understand how and how often people use our Services and our partners’ services. These third parties may also share with us non-private, aggregated or other Non-PII about you that they have independently developed or acquired.

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j.    Email, Text, and Push Notification Communications: We may communicate with you via Notifications. We may collect information regarding such communications, such as by receiving confirmation when you open an email, read a Text Message or receive a push notification. We use this information to improve our Services, including our customer service.

 

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k.    Information About Your Contacts: For features in the Services that access your Device contact list, we will only store information for contacts who register with the Services or who you add as Users. We will only access and store such information with your express consent.

 

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l.    Information About Minors: Our Services are not directed to children under 13 years old and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of or from a child under 13 years old, we will take steps to delete such information from our systems as soon as possible.

Other Ways Information is Shared

In addition to the purposes set forth above, we may share your information for the following purposes:

 

a.    Information Shared With Other Users: In connection with certain features of the Services, PKinno may share some information about users with other users who have sufficient access privileges. The following are ways in which PKinno may share information about you with other users:

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• When a Manager or Owner grants access to a User, the User may receive the Manager’s or Owner’s name and the the Hardware location (which may be PII of the Owner or User). This information allows the User to identify the location to which the User or Owner is granting access.

• When a User accesses Hardware, the Hardware’s Manager and Owner may receive information about the User and the access event, such as the User’s name, an Image of the User (as collected by the Hardware) and the time of access.

• Users and Owners may also receive aggregate and/or anonymized information about Users and Codes, such as frequency of Code generation, frequency and time of Code use, and total number of Users who have accessed a particular Hardware. Owners will also receive information identifying the Hardware and the User controlling such Hardware.

• PKinno may share aggregate, anonymized and/or statistical data about a user’s use of the Services. This information may be derived from PII but does not include PII or Images.

 

Unless expressly stated herein or expressly consented to by you, PKinno does not share your PII with any other users.

 

b.    Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Additionally, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your PII as set forth in this policy.

 

c.    Our Protection and the Protection of Others: We reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary for the following purposes:​

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• Satisfy any applicable law, rule, regulation, legal process or governmental request

• Enforce this Privacy Policy and the Terms, including investigation of potential violations hereof

• Detect, prevent, or otherwise address fraud, security or technical issues

• Respond to user support requests

• Protect our rights, property or safety, and those of our users and the public

 

This may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

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d.    Marketing: We may use your information to send you news about our services, products or promotions. We may also serve advertisements, and also allow third parties to serve advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include ad servers, ad agencies, ad technology vendors and research firms.

Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on anonymized information inferred from information provided to us by a user (including PII such as gender or age), Services usage patterns of particular users, or a user’s activity on Third Party Services.

We do not provide PII to any ad networks for use that is not related to the Services. We will give you the ability to opt out of marketing-related e-mails by logging in and changing your Account settings or by clicking on a link in each such e-mail.

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e.    With Your Consent: Except as set forth in this Privacy Policy, you will be notified when your PII may be shared with third parties, and will be able to prevent the sharing of this information.

Information Security

We seek to protect your Account information to ensure that it is kept private, and we use generally accepted industry-standard techniques to protect the PII submitted to us. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of any information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. It is your responsibility to prevent unauthorized access to your Account and information by selecting and protecting your Account password appropriately, and limiting access to your Devices, including by signing off after you have finished accessing the Services.

Access to Information

If you have a registered Account, you can access information associated with your Account by logging into the Services. Please note that Users without an Account cannot access or edit any information.

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a.    California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: [mailing address and email].

Account Deletion

You can delete your Account by emailing support@reagle.freshdesk.com. After termination, we may retain your information on our servers in accordance with our internal data retention policy.

Choices Regarding Information

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• You may use some features of the Services without registering, thereby limiting the type of information that we collect.

• You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.

• You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us for audit and archival purposes.

• Registered Account holders can access and manage their access levels, and edit certain information submitted to the Company during registration.

 

Privacy Policy Changes

We may amend this Privacy Policy from time to time. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. If you use the Services after changes have been posted, you agree to be bound by the changes.

PKinno Contact Information

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@reagle.freshdesk.com, and we will try to resolve your concerns.

An Additional Note Regarding Data Processing

Your PII may be collected, processed and stored by PKinno or our service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your PII, in some of these countries may not be equivalent to those in your country. If you are using the Services in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, you consent to the transfer of your personal data to the United States and other countries where PKinno and its service providers operates.

Headings

The section and paragraph headings in this Privacy Policy are for convenience only and shall not affect its interpretation. Any use of “including”, “for example” or “such as” in this Privacy Policy shall be read as being followed by “without limitation” where appropriate.

Effective Date: 2019/3/1