Privacy Notice Supplement for Residents of Certain U.S. States
Effective Date: March 8, 2024
If you reside in California, Colorado, Connecticut, Utah, Vermont, or Virginia, this page applies to you and supplements Latch’s Privacy Notice.
California
Latch complies with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA) and applicable regulations (collectively referred to as “CCPA”) and California’s “Shine the Light” law (Civil Code §§ 1798.83-1798.84). Under Shine the Light law, California residents may request certain information regarding our disclosure of Personal Information to affiliates and other third parties for direct marketing purposes. Please see our Privacy Notice for details regarding how we disclose Personal Information. To make a request, please contact us at support@latch.com.
With respect to the CCPA, depending on the legal relationships in place, Latch may act as a “business” or as a “service provider.” As described below, Latch fulfills its CCPA obligations in accordance with its role in each particular instance.
Commercial California Customers
PLEASE READ IF YOU ARE A RESIDENT IN A MULTI-FAMILY BUILDING.
With respect to California customers who purchased Latch for use in the multi-family properties they own or manage and who themselves are subject to the CCPA as “businesses,” Latch acts as a “service provider.”
If you are a resident of a multi-family building in California and your property manager or building owner is a “business” that purchased Latch’s Products and Services for use in their building, the CCPA requires you to direct your privacy requests to your property manager or building owner, which they will address pursuant to their privacy notices. To comply with the CCPA and its contractual obligations, Latch will not be able to fulfill your privacy requests directly. If you submit a consumer request to us directly, we will forward it to your property manager or building owner, as appropriate, for handling and to provide us with any instructions or requests for assistance.
Individual California Customers
With respect to California residents who purchased our Products and Services for use in their single-family homes, Latch acts as a “business.”
If you fall in this category of users, consistent with the CCPA, you can exercise your consumer rights by submitting a verifiable consumer request directly to Latch by emailing support@latch.com, calling our toll-free number 1-877-890-2221 (operates on East Coast business hours), or contacting Customer Support through the Latch App.
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Right to Know You can make a request to know up to twice a year, free of charge |
You have the right to request that we disclose to you: (1) the categories and/or specific pieces of Personal Information we have collected about you, (2) the categories of sources for that Personal Information, (3) the purposes for which we used that information, (4) the categories of third parties to which we disclosed the information, and (5) the categories of information that we sold or disclosed to third parties. For more information on how and what Personal Information we collect, use, and disclose, please review our Privacy Notice. |
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Right to Access |
You have the right to request that we provide you with copies of your Personal Information in a portable format. |
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Right to Delete |
You have the right to request that we delete Personal Information we collected from or about you, subject to certain exceptions. For instance, we may deny your deletion request if we require your Personal Information to complete the transaction for which we collected the Personal Information; detect bugs or errors; detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; enable solely internal uses that are reasonably aligned with consumer expectations; comply with a legal obligation; or make other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it. For more information on how long we retain Personal Information, please review our Privacy Notice. |
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Right to Limit Use and Disclosure of Sensitive Personal Information |
You have the right to request that we limit the use of your sensitive Personal Information (e.g., your precise geolocation data) to specific purposes, such as providing you with the services you requested. We only process sensitive Personal Information for the purposes disclosed in the Privacy Notice. For instance, to help ensure safety and security and reduce spam calls, we use your precise geolocation data only when you are using Latch Virtual Intercom and only for the purposes of confirming that you are located at the building when you are calling a resident of that building. We do not use any biometric information. |
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Right to Correct |
You have the right to request that we correct inaccuracies in your Personal Information that we hold. |
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Right to Opt-Out of Sale or Sharing |
You have the right to request that we stop selling or sharing your personal information (“opt-out”). We do not sell personal information to third parties; we are not data brokers, and we do not put personal information on the open market. We may allow third parties to collect personal information through tracking technologies on our website. You may submit your request to opt out of your Personal Information being shared through tracking technologies by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of our website. |
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Right to Non-Discrimination |
You have the right to not be discriminated or retaliated against for the exercising of your rights under the CCPA. We will not discriminate or retaliate against you for exercising your privacy rights, including we will not deny you products or services, charge you different prices for products or services, or provide you a different level or quality of products or services. |
Consistent with the CCPA and to protect the privacy of your Personal Information, we will verify your identity and fulfill your request within forty-five (45) days of its receipt. If we require additional time to fulfill your request, we will notify you within those forty-five (45) days and explain the reasons for the additional time. We will deliver our response to the email address associated with your Latch account.
Certain Other U.S. States
The state privacy laws of the states of Colorado, Connecticut, Utah, Vermont, or Virginia do not directly apply to Latch. Latch complies with these laws only to the extent its commercial customers (i.e., property managers or building owners) are subject to these laws. Under these laws, where Latch’s commercial customer is a “data controller” with respect to Personal Information, Latch would serve as the customer’s “data processor.”
Commercial Customers in Colorado, Connecticut, Utah, Vermont, or Virginia
PLEASE READ IF YOU ARE A RESIDENT IN A MULTI-FAMILY BUILDING.
With respect to Colorado, Connecticut, Utah, Vermont, or Virginia customers who purchased Latch for use in the multi-family properties they own or manage and who themselves are subject to the relevant privacy laws as “data controllers,” Latch acts as a “data processor.”
If you are a resident of a multi-family building in Colorado, Connecticut, Utah, Vermont, or Virginia and your property manager or building owner is a “data controller” that purchased Latch’s Products and Services for use in their building, the privacy laws of these states require you to direct your privacy requests to your property manager or building owner, which they will address pursuant to their privacy notices. To comply with its contractual obligations, Latch will not be able to fulfill your privacy requests directly. If you submit a consumer request to us directly, we will forward it to your property manager or building owner, as appropriate, for handling and to provide us with any instructions or requests for assistance.
Individual Colorado, Connecticut, Utah, Vermont, or Virginia Customers
Latch is not in scope for the application of state privacy laws of the states of Colorado, Connecticut, Utah, Vermont, or Virginia and, therefore, does not comply with these laws, except in its capacity as a data processor to commercial customers in these states who themselves are in scope for compliance with these laws.
If you have any questions about this Privacy Notice Supplement, you may contact us by email at support@latch.com.