Privacy Policy for WAFERLOCK Products & Services

LAST UPDATED [July 24, 2021]
This policy governs the products, software, applications and services (collectively “the Services”) manufactured or operated by WAFERLOCK CORP.

1. Information We Collect

In the course of using the Services, you may provide and we may collect certain personal data and other information, including:

• Information you provide when you register through our mobile application or purchase any products or services, which may include your name, phone number, email address, postal addresses, credit card or other billing information and any feedback.
• Information to authenticate or otherwise verify your account, such as IP address, mobile device identifiers, account user-identifiers, and photographs.
• Information associated with use of our smart lock products such as device status, logs of those who lock/unlock the devices, the guests that you invite, and those people who may invite you as a guest, to use the device and application. We may store this data along with your personal data and other information about your use of our Service.
• Information about the guests that you invite in order to allow them to have access to your smart lock and Service. Guests should be aware that the person(s) providing access to a specific device may be able to see information about the guest’s usage of the device or our Service, and may revoke or limit access rights in their discretion without notice. We will only store information for contacts that you add as guests.
• If you choose to login/connect your WAFERLOCK products to each other, through our mobile application, or to third party applications, we may collect information about your use of those other products.Please note that when you consent to connect these products, you are also consenting to these product manufacturers collecting additional personal data and other information about your use of the WAFERLOCK products which are subject to these products privacy policies.

WAFERLOCK products are not authorized for use by minors under 16, and we do not knowingly collect personal data from persons under the age of 16.

2. How We Use and Store Information

We use information collected through the Services for the following purposes:

• To manage and administer your user account
• To fulfill your orders, which may including retaining your billing information for subscriptions or other purchases
• To respond to any customer support requests you may make
• To provide, administer and improve our applications, content or support services
• To better understand your needs and interests
• To personalize your user experience
• To provide product, service or other communications
• To conduct market research
• To provide you with further information and offers from WAFERLOCK or complimentary products or services
• To administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by WAFERLOCK.
• To comply with our legal obligations, resolve disputes with users, enforce our agreements and to protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity.

Location, Device and Application Operation

We use collected information from our products to allow you (and us) to operate and monitor your devices and our Service. If you enable the Geofence-Unlock feature, the application will request your consent in order to track your location in order to determine when your application nears WAFERLOCK devices that you have permission to access (e.g. when you are near home). Location information will only be stored on your device, and not on our servers.

Guest Access

As part of our Services, you may give others (“guests”) permission levels to access your WAFERLOCK lock – e.g. to unlock and lock your door (and possibly even to pass this access along to others). Needless to say, you must be careful of the guests that you invite and the access that you give them. You are responsible for all uses of your account, so be careful to secure this information and only give access to people you trust. Additionally, certain portions of your personal data, device and Service information may be shared with the people that you invite, such as your name and lock location, and the status of the lock (e.g. locked or unlocked). We may also collect personal (as required to use the Service as set forth in this Privacy Policy) about the guests that you invite in order to allow them to have access to your WAFERLOCK 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. All guests must be informed and 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 stop using the Service. Guests should be aware that the person(s) providing access to a specific device may be able to see information about the guest’s usage of the device and our Service and may revoke or limit access rights in their discretion without notice. Guests should also be aware that their personal data and usage information may be shared with third-party service providers as set forth in this Privacy Policy, including those service providers selected by the person(s) that invited you to use their lock (see “Your Third Party Service Providers” below).

For registered users from the UK or European Union/EEA, the legal basis for this data processing is:

• Performance as necessary to support a contract, including administering your account, enabling functionality of the Services, providing customer support, tracking device operability, and notifying you of account or specific functions of the Service.
• Our legitimate interest to process the data, including to protect the security or integrity of the Services, to carry out statistical or other analysis about the Services, to understand and improve upon the Services, to send you marketing or other communications about relevant products or services which may be of interest, to measure the performance of our mobile application and communications efforts, and to conduct market research.
• With your consent, such as when you enable an account integration with any of the WAFERLOCK services.
• If we are required to collect, store, use or otherwise share information in compliance with a legal obligation.

Information Retention

We may store collected information for as long as necessary to fulfil the purpose for which the data has been collected, and in accordance with our internal record retention schedule. Lock activity is stored alongside your account information for the duration of your account being active. We will delete your personal data when the information is no longer necessary to process a request, at your request, or to manage your account or our client relationship. We may store any aggregate or anonymous information indefinitely.

Information Security

The security of your information is important to us. We follow generally-accepted industry standards to protect the submitted to us through our devices, mobile applications and the Services, both during transmission and once we receive it. We also apply rigorous independent security testing to our devices and the Services. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security.

3. When We May Share Information

We may share or transfer collected information for any of the previously described purposes in these instances.

• To third party service providers who provide billing services, mobile application functionality, facilitate communications, enable customer support and other services connected to the Services, but only to the extent necessary to support our products or provide these services. See below for additional information.
• With your consent, such as with guest invitations or if you choose to connect our products to work in conjunction with third party products or services.Please note that when you consent to these transfers, any shared data will then be subject to the privacy policies of those third parties.
• When required by law
• To a buyer or a potential future buyer of our business.
• We may choose to aggregate or anonymize your information and share it with partners or others for market research or other business purposes.

Additional Information About Our Service Providers. We may employ third party companies and individuals to administer and provide the Services on our behalf, (including, without limitation, bill and credit card payment processing, maintenance, administration, support, hosting and database management services). These third parties may have access to your information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. Your Third Party Services. If you access our Service through a third-party (e.g. connecting your WAFERLOCK device or Service to your home security system), or otherwise use a third party service provider in connection with the Service, or request or authorize us to give access or data to a third-party service provider (e.g. a delivery service, property management or rental service, or other service that you may use) we may provide information (about you and your guests) and other information about the Service, the WAFERLOCK device and their usage to such third-parties. You should only use trusted service providers, and give your authorization and information to trusted recipients. We encourage you to read the privacy policies and service terms of the third-party services that you use, as their privacy policies and terms govern their usage of the information that you provide them. While we make reasonable efforts to protect your information while it is under our control, we have no obligation with respect to the functionality of such third-party services or the use of such information under control of these third parties.
We do not share or sell the Personal Identifying Information that you provide us with other organizations without your express consent. Under this Privacy Policy you and your guests hereby consent to sharing under the following circumstances:
Information Shared with Guests or Other Users. If you invite a guest to access your device, then we may share certain elements of your information with them (name, lock location, picture, etc.) in order for them to understand the invite and access the device. We may also similarly share their information with you.

4. Exercising Your Choices or Rights

Communications

If you are a registered user, you may change your phone number or email address, and update your preferences within the mobile application in order to manage your product-specific communications. We also give you the ability to unsubscribe from marketing-related emails by clicking on a link in each such e-mail.

Mobile Data

If you access the Service through a mobile device and you do not want your mobile device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your mobile device. See your mobile device manufacturer’s instructions for further details. Of course, if you do this, Service functionality (such as the Geofence-Unlock feature described immediately above) may not work.

Changing or Deleting Your Information

If you are a registered user, you may review, update, correct or delete the information in your registration profile by logging into your account through the mobile application and changing the “user preferences” associated with their account. Removing your information may limit our ability to communicate or 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 device. You may also contact us if you have additional questions or need additional assistance. 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.
Product owners are always responsible for the photos, videos and other personal data captured of their guests, and WAFERLOCK provides no remediation for guests to remove photos, videos or other personal data from our systems unless expressly authorized by the registered account of the product owner.

For visitors from the UK or European Union/EEA, your personal data rights are:

• Request a copy of your personal data from our records;
• Ask that we correct or erase your personal data (though this may mean that we cannot process requests, or that your account expires);
• Ask us to stop processing your personal data (for example as regards the use of the data to improve our product), or restrict how we process it (for example if you deem the data to be incorrect);
• Request the personal data used to provide you with information you requested, or manage your account or our relationship in a machine-readable format, which you are entitled to transfer to another data controller; and
• Withdraw your consent to us processing your data for marketing purposes at any time.

You have the ability to access, modify, download or delete your personal data through the mobile application. In addition, lock owners may request deletion of activity logs, including guest information, unless such information is required to be maintained in order to fulfill an existing legally required purpose. If you are a guest or visitor to a home where you engaged with one of our products and wish to exercise your data subject rights regarding your personal data; then please contact the product owner directly. WAFERLOCK can only fulfill guest data subject requests when expressly authorized by our product owners. We may not accept a request to modify or erase your personal data where we cannot verify your personal data, where we require it to comply with a legal obligation or in relation to a legal claim. For additional information about how to requests to exercise your rights, please see the Contact Us reference below.

5. Changes to This Policy

This Privacy Policy may be updated from time to time to reflect changes to our information practices. All other updates will be made through WAFERLOCK website 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 the date indicated in our posting of the new terms. In all of the above cases, your continued use of the website after any notice or posted modified Privacy Policy indicates acceptance of the modified Privacy Policy.

6. Contact Us

If you have additional privacy-related questions, please contact us at support.app@waferlock.com or by mail at:
WAFERLOCK Corporation
No. 16, Ke-Yuan 2nd Rd.
Central Taiwan Science Park
Taichung City, Taiwan