Milre Connected Product Privacy Policy
EFFECTIVE DATE: April 20, 2020
This Milre Connected Product Privacy Notice (the “Notice”) is brought to you by Milre Systek CO., LTD. (collectively, “Milre”, "we", "our" or "us").
You are being presented with this Notice because you wish to use a Milre connected product (“Connected Product”) with a Milre App (“App”) and cloud service that enables certain features and functions such as the Milre Smart.
Collectively, the features and functions provided by Milre and the App are referred to in this Notice as the “Services".
In this Notice we describe how we collect, use, hold and disclose information that we obtain through your use of the Services and the integration of your Connected Product with the App and/or Third Parties (as applicable). Milre is not responsible nor does Milre control the practices of Third Parties. Additional documentation regarding Third Party privacy practices can be found at their respective websites.
By using the Services, you agree that your information will be handled as described in this Notice. Your use of our Services, and any dispute over privacy, is subject to this Notice and our Terms of Use, which are incorporated by reference into this Notice and include applicable limitations on damages and the resolution of disputes.
What Information Do We Collect About You and Why?
We collect information about you directly from you and from third parties, as well as automatically through your use of our Services.
Information We Collect Directly From You. When you create an account to use the Services, you must provide us with your name, phone number, and address (e.g., property address) and other information that we may request.
Information We Collect Automatically. We automatically collect information about your use of our Services, including: Internet Protocol (IP) address.
App and Third-Party Integrations. We collect the information described in the “Third-Party Integrations” section below.
How We Use Your Information
We use your information, including your personal data, for the following purposes:
1. The performance of our agreement with you and to enable you to use the Services and to provide the Services to you. In order to do so, we use your information:
o To allow you to register, program, configure, schedule and use your Lock.
o To allow you to share access to your Lock and your Services account with others.
o To deliver our Services to you, to communicate with you about your use of our Services, to respond to your queries or complaints, and for other customer service purposes.
o To inform you of the status of our Services, including but not limited to temporary loss of or degraded performance of the Service or products that you use.
2. The legitimate interests of Milre.?For this reason, we use your information, including your personal data, for the following purposes:
o To tailor the content and information that we may send or display to you and personalized help and instructions, and to otherwise personalize your experiences while using the Services.
o For marketing and promotional purposes. We may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information (including those offered by third parties) we think may interest you.
o To better understand how users access and use our Services, both on an aggregated and individualized basis, to improve our Services, respond to user desires and preferences, and for other research and analytical purposes.
o To comply with our legal obligations and assist government and law enforcement agencies or regulators, and to protect our rights and interests as well as the rights and interests of our users and other third parties.
How We Share Your Information
We may share your information, including personal data, as follows:
* Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal data will be subject to this Notice.
* Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf. These third parties may be located outside of your home country and thus your information may be accessible to law enforcement or regulatory authorities according to the applicable laws of such foreign jurisdictions (see the section "International Transfers" below for more details of those countries in which (or to which) we may use, disclose, process, transfer or store your personal data).
* Business Transfers. If we are acquired by or merged with another company, if we transfer some or all of our assets to another company, or as part of an asset sale, a sale of business or a bankruptcy proceeding, we may transfer the information we have collected about you to the other company.
* In Response to Legal Process. We may disclose the information we collect from you where we are required or authorized by law to do so, and to comply with any judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
* To Protect Us and Others. We may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use or this Notice.
* Aggregate and De-Identified Information. We may share and disclose aggregate, de-identified or anonymized information about you or derived from your use of the Services with third parties for purposes of helping us review use of our Services and improve our Services and marketing, advertising, research, analytical or similar purposes.
* You have consented. We may disclose the information we collect from you where you have expressly consented to the disclosure or the consent may reasonably be inferred from the circumstances.
* Third Party Integrations. We share certain information with Tuya. in order to provide the services. All information obtained by the Third Party is subject to use by the Third Party’s policies, including their privacy notice. Milre is not responsible nor does Milre control the practices of any Third Party.
International Transfers and Offshore Storage of Personal Data
We may use, disclose, process, transfer or store information, including personal data, outside the country in which it was collected, such as to the United States and other countries, which may not guarantee the same level of protection for personal data as the country in which you reside.
Additionally, there are situations when personal data is transmitted to third-party service providers (in South Korea and/or other countries, including countries in which Milre operates or as offices) to provide services for Milre, such as payment processing and web hosting and other services required by law. Milre uses third-party service providers to process personal data for service-related and administrative purposes. Such service providers are located in the United States and other locations where Milre does business. When Milre retains another company to perform a function of this nature, such third party will be required to protect the personal data and will not be authorized to use the personal data for any other purpose.
The countries that we may use, disclose, process, transfer or store your information in are likely to be the United States, China, Taiwan, and Singapore.
Your Rights
You provide your personal data to us voluntarily. Depending on your jurisdiction, you may have the right, at any time, to learn whether Milre process personal data about you, to request information as to your personal data being processed, to access personal data that Milre holds about you; to learn the purpose of the processing and to check whether the data is being processed in accordance with the original purpose, to request that we restrict the use of your personal data or stop using or disclosing your personal data; to request that we update, amend, or delete your personal data; to know the third parties whom your personal data has been transferred, request third parties to be informed of any rectification, update, deletion, object to the occurrence of any result that is to your detriment by means of analysis of personal data exclusively through automated systems, request portability of your personal data or compensation for damages due to unlawful processing of your personal data and to withdraw any previously given consent with regard to your personal data; using the contact information below. You may make such requests by submitting an email to Brad.Mun@allegion.com. Once we receive your request, we will verify it. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. Allegion will respond to your requests within fifteen (15) days of receiving the request, unless you are notified otherwise by us in writing. There is no charge for requesting access to your personal data but we may ask you to meet reasonable costs in providing you with access, for example photocopying or postage costs. There are some circumstances in which we are not required to give you access to your personal data. We will take all reasonable steps to ensure that the personal data we hold about you remains accurate, up to date and complete.
Third-party Analytics
We may work with service providers (including Amazon Web Services Pinpoint) who conduct analytics to help us track and understand how customers use the Services. Amazon Web Services Pinpoint is an analytics service provided by Amazon that help us analyze how users use the Services. The information generated about your use of the Services will be transmitted to and stored by Amazon on servers in South Korea. For more information about Amazon’s privacy practices, please see https://aws.amazon.com/pinpoint/data-privacy-compliance-faq/.
Security
We have implemented measures designed to protect the information we collect from damage, misuse, interference, loss, alteration, destruction, unauthorized or accidental use, modification,disclosure, access or processing, and other unlawful forms of processing data. However, please be aware no data security measures can guarantee 100% security. While we monitor and maintain the security of the Services, we do not guarantee that the Services or any products or services is impervious to attack or that any use of the Services or any products or services will be uninterrupted or secure. In addition, information that you transmit over the Internet, including through email or SMS message, is not secured by us and is inherently vulnerable to attack or interception.
Storage of Personal Data
We store your information in electronic and physical formats. Your data remains stored by us in the Services. After you delete your Services account, we may continue to use and store your information in accordance with our record retention policies and this Notice. As a general matter, we do not retain personal data for longer than is required or appropriate for the purposes for which it was collected, unless a longer or shorter period is necessary for our legal obligations, or customs of the industry, or to defend a legal claim, or to comply with legal, accounting, regulatory or reporting requirements, and consistent with applicable law.
What Choices Do I Have Regarding Use of My Personal Data?
We may send periodic promotional emails and other communications to you with offers and announcements we think may interest you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Further, you may opt-out of promotional communications by sending an e-mail to Brad.Mun@allegion.com. Please note that it may take up to 10 business days for us to process opt-out requests regarding promotional emails and longer for other types of requests. If you opt-out of receiving promotional communications from us, we may still send you communications about your account or any products or services you have requested or receive from us.
No One Under 18
Our Services are not designed for anyone under 18. If we discover that a person under 18 has provided us with personal data, we will delete such information from our systems.
Do Not Track Disclosure
Currently, our systems do not recognize browser “do-not-track” requests. You may disable certain tracking (e.g., by disabling cookies). To learn more about do-not-track signals, please see https://allaboutdnt.com/.
Additional Information for Residents of Certain Jurisdictions
Depending on your jurisdiction, you may have some or all of the following rights with regard to our processing of your personal data, except to the extent such rights are limited by law:
Right to access, correct and delete your personal data: Milre will use reasonable measures designed to ensure that all personal data is correct. You also have a responsibility to ensure that changes in personal circumstances (for example, change of address, bank account, etc.) are notified to Milre so that we can ensure that your personal data is up-to-date.
You have the right to request access to any of your personal data that Milre may hold and to request correction of any inaccurate personal data relating to you. You furthermore have the right to request deletion of personal data we hold about you.
Right to withdraw consent: In the event your personal data is processed on the basis of your consent, you have the right to withdraw consent at any time by sending an email to Brad.Mun@allegion.com, specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.
Data portability: To the extent that we use your personal data on the basis of consent for the performance of a contract and that personal data is processed by automatic means, you have the right to receive all such personal data that you have provided to Milre in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.
Right to restrict personal data use: You have the right to restrict our use of your personal data where (i) you contest the accuracy of the personal data; (ii) the use is unlawful but you do not want us to erase the personal data; (iii) we no longer need the personal data for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims; or (iv) you have objected to our personal data use justified on our legitimate interests pending verification as to whether Milre has indeed compelling interests to continue the relevant personal data use.
Lodge a complaint: You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the collection and use of your personal data violates this Notice or applicable law.
You may revoke the consent that, as the case may be, you granted us for the handling of your personal data. However, it is important that you keep in mind that not in all the cases we will be able to answer your request or immediately conclude the use thereof as it is possible that due to some legal obligation we will be required to continue handling your personal data. To revoke your consent you must send your request to the following email address: Brad.Mun@allegion.com.
Changes to this Notice
This Notice is current as of the Effective Date set forth above. We may change this Notice from time to time, so please be sure to check back periodically. We will post any changes to this Notice within the Services. You can obtain a copy of our current Notice by contacting us. If we make any changes to this Notice that materially affect our practices with regard to the personal data we have previously collected from you, we will endeavor to provide you with notice by highlighting the change in the Services or by emailing your email address of record.
Contact Us
Please contact us at Milre Systek Co., LTD. at (email: Brad.Mun@allegion.com) if you have any questions or concerns about this Policy, the personal data we have about you, require assistance in managing your choices, or have other questions, comments or complaints regarding our privacy practices.