PRIVACY POLICY

PRIVACY POLICY

BACKGROUND

This Privacy Policy forms a part of the FLEXIPASS Mobile Access License and User Agreement and is part of the agreement between You and FLEXIPASS Keyless Mobile Access SRLS (together with other relevant companies within the FLEXIPASS Keyless Mobile Access SRLS group, collectively or individually (“We”, “Us” or “Our”)) for the Licensed Materials and Services (both as defined in the FLEXIPASS Mobile Access License and User Agreement) (the “Agreement”). Capitalised terms in this Privacy Policy have the meaning given to them in the Agreement.

We respect Your right to privacy and are committed to following applicable data protection rules to safeguard Your rights. We want to make sure that You understand the type of information We collect about You, how it is used and how we protect it. You can withdraw Your consent at any time by contacting Us, see Section 6.

We need to collect some information about You so that We can provide You with the Licensed Materials and Services. This Privacy Policy describes the information We collect about You (“Data”) and how that Data is treated and for what purposes We may share the Data and how You can contact Us about Your Data. By using the Licensed Materials and Services, You consent to Our use of the Data as set out below.

A. The Data We May Collect

B. Why We Collect the Data

C. Who may We disclose Data to?

D. Period of Retention and Use

1. Transfer

2. Precautions

3. Children

4. Changes

5. Your rights to Access and Correct the Data

6. Contacts

ENTERPRISE

You should also bear in mind that, as Your use of the Licensed Materials and Services has been requested by a company that is one of Our existing customers (an “Enterprise”), the Data will be collected by the Enterprise and then provided to us.

The Enterprise will be collecting and transferring the Data to Us. You agree that We are not responsible for the Enterprise’s methods of collecting, storing and/or using Data about You.

A. THE DATA WE MAY COLLECT

We may collect the following Data:

1. Your name and email address, and other data which the Enterprise uses to identify You when making it possible for You to use the Service;

2. Information about when You check in and out from which Enterprise;

3. Technical data and related information about the Device being used for the Services, including unique push ID, operating system, application software and peripherals; and

4. information related to the use and performance of the Licensed Materials and Services.

If We need to collect additional information or access certain parts of Your Device, We will first ask for Your consent and the Data will only be used in accordance with this Privacy Policy.

B. WHY WE COLLECT THE DATA

We collect Your Data to:

1. License the Licensed Materials or Services to You and to enable us to provide You with the Licensed Materials and Services and any associated products or services;

2. Provide you with software updates and support, improve and develop new products and services, and maintain and manage Our websites and other related services;

3. Communicate with You about the Services;

4. Fulfill Our legal and administrative obligations (such as making tax returns/payments);

5. Enforce this Privacy Policy and the FLEXIPASS Mobile Access License and User Agreement; and

6. Protect the rights, property or safety of Us, Our customers or others.

We do not sell or trade the Data or collect or use it for advertising purposes

C. WHO MAY WE DISCLOSE DATA TO?

We may share the Data with other companies in the FLEXIPASS Keyless Mobile Access SRLS group, as well as certain trusted business partners and third party service providers to enable them to perform functions of the Services and to process Data on Our behalf, in accordance with the purposes in Section B above.

We will take reasonable steps to ensure that the Data will only be used for the purposes described in this Privacy Policy and in accordance with applicable law, even if We do transfer or disclose Data to other companies within FLEXIPASS Keyless Mobile Access SRLS or to Our suppliers or subcontractors (for an overview of the entities that regularly receive the Data, see Section 6 below).

If applicable, Data may also be transferred to:

1. Local or foreign regulators, governments and law enforcement authorities, including tax collection agencies and stock or other exchanges;

2. Local and foreign courts, tribunals, arbitrators or other judicial committees;

3. Persons to whom We may assign or transfer Our rights or duties under this agreement or under any other agreement We may have with or concerning You;

4. Persons in connection with any sale, merger, acquisition, disposal, reorganization or similar change of Our business (including any potential or actual purchaser of that business and that purchaser's advisors);

5. Third parties, if so required to comply with mandatory law or requirements; and

6. Address fraud or technical issues.

 D. PERIOD OF RETENTION AND USE

We will retain the Data for as long as is necessary for the relevant activity or services described above or for as long as we are lawfully required to do so.

The Data will be destroyed if:

1. The purpose of collection and use of Data has been achieved;

2. The business for the Licensed Materials or Services concerned is discontinued; or

3. You withdraw your consent to the collection of Data by contacting Us (for contact information please see Section 6 below).

1. Transfer

We may share Your information with other companies in our group or with our trusted subcontractors in order to provide the Services and for the purposes set out in this Privacy Policy. Processing of Data may therefore take place in countries other than Your home country. Data collected in the European Economic Area (the “EEA”), may be stored, processed or transferred outside of the EEA, as described in this Privacy Policy. The destination country may not offer the same level of protection of the Data as the country where You are located and may only provide you with fewer legal rights in relation to the Data. However, We will only process the Data as described in this Privacy Policy and use Our efforts to handle the Data securely and in accordance with applicable data protection rules. You expressly consent to Your information being used as set out herein.

2. Precautions

We protect Your Data using commercially reasonable safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, we cannot guarantee security, either on or off the Internet. You are responsible for protecting the Device against unauthorized access and use, and any transmission of Data will be at Your own risk.

3. Children

The Licensed Materials or Services are not directed to children under the age of 18, and We do not knowingly collect personal information from children under 18.

4. Changes

We may amend this Privacy Policy from time to time. We will use reasonable efforts to notify You before such change, through the Service. By continuing to use the Licensed Materials or Services after such notification, You are expressly acknowledging and accepting the changes.

5. Your rights to Access and Correct the Data

You have the right to access the information We hold about You and have any inaccuracies corrected. The accuracy of the information We hold about You is important to Us. If any of the information We hold about You is inaccurate or out of date, please let Us know by emailing Us (for contact information please see Section 6 below). We will respond within a reasonable period of time upon verification of Your identity.

6. Contacts

For the purpose of European data protection laws, the data controller is FLEXIPASS Keyless Mobile Access SRLS.

If You have any questions about how We use the Data, You can contact us at support@flexipass.tech. If You have any questions about how the Enterprise uses the Data, please refer to the privacy policy provided to You by the Enterprise for its contact details.

For an overview of the entities that regularly receive the Data, see below:

Name and Contact: FLEXIPASS Keyless Mobile Access SRLS
Role: Data Controller
Location: Italy
Purpose of Collection, Use or Transfer: To license the Licensed Materials or Services to You and to enable Us to provide You with the Licensed Materials and Services and any associated products or services, provide You with software updates and support, improve and develop new products and services, and maintain and manage websites and other related services, communicate with You about the Services, fulfill Our legal and administrative obligations (such as tax returns/payments), enforce this Privacy Policy and the FLEXIPASS Mobile Access License and User Agreement, protect the rights, property or safety of Our customers or others
Nature of Data: See Data described in paragraph A, above  
Period of Retention: See description in D above

Name and Contact: ASSA ABLOY AB
Role: Data Controller
Location: Sweden
Purpose of Collection, Use or Transfer: To license the Licensed Materials or Services to You and to enable Us to provide You with the Licensed Materials and Services and any associated products or services, provide You with software updates and support, improve and develop new products and services, and maintain and manage websites and other related services, communicate with You about the Services, fulfill Our legal and administrative obligations (such as tax returns/payments), enforce this Privacy Policy and the FLEXIPASS Mobile Access License and User Agreement, protect the rights, property or safety of Our customers or others
Nature of Data: See Data described in paragraph A, above  
Period of Retention: See description in D above

Name and Contact: HID Global Corporation (an ASSA ABLOY group company)
Role: Data Processor
Location: U.S.A. 
Purpose of Collection, Use or Transfer: To initiate or revoke Services, provide updates, support, improvement and development of new products and services, maintenance of related services, carry out mandatory obligations
Nature of Data: See Data described in paragraph A, above
Period of Retention: See description in D above

Name and Contact: The Enterprise

Role: Data Collector and Data Processor

Purpose of Collection, Use or Transfer: See the privacy policy provided by the Enterprise

Nature of Data: See Data described in paragraph C, above 

Period of Retention: See the privacy policy provided by the Enterprise