Privacy Notice

Latch Systems, Inc. and its affiliates (“Latch,” “we,” “our” or “us”) respects your privacy and is committed to protecting your Personal Information. “Personal Information,” also known as “personally identifiable information,” “personal data,” or “PII,” is information that directly identifies you or is capable of being reasonably associated with you and may include, where applicable, your name, physical address, email, telephone number, Latch username and password, and other information, as specified below.

This Privacy Notice (“Notice”) describes our data privacy practices with respect to your use of any of our products, devices, software, technology, features, services, and applications (“our Products and Services”), as well as the use of Latch websites, unless a separate privacy notice applies. Our Products and Services are intended for use in the United States of America and Canada only.

This Notice does not govern the practices of third parties, such as our partners and third-party service providers, except to the extent we provide them with Personal Information. Any information you provide directly to a third party, even if you access their website or services through ours, will be governed by the third party’s privacy policy and terms of use, and not this Notice. Please review such third party policies and terms of use.

By using our Products and Services, you agree to our Terms of Service and consent to the collection of your Personal Information that we will process in accordance with this Notice. If you do not agree to our Terms of Service and do not wish for your Personal Information to be processed as described in this Notice, please discontinue use of the Products and Services, and uninstall our downloads and applications.

TABLE OF CONTENTS

1. COLLECTION OF PERSONAL INFORMATION
1.1 Personal Information You Choose to Give Us
1.2 Personal Information We Obtain from Your Property Manager or Homeowner
1.4 Personal Information We Obtain Through Your Use of Our Products and Services
1.5 Personal Information We Obtain from Third Parties
2. USE OF PERSONAL INFORMATION
3. SHARING OF INFORMATION WITH THIRD PARTIES
3.1 Non-Personal Information
3.2 Personal Information
Other Latch users and building visitors
Third parties providing services on our behalf
Property transfers
Affiliated or subsidiary companies
Direct marketing
Legal requirements and law enforcement
Sweepstakes and promotions
Corporate change
4. DATA RETENTION
4.1 General Data Retention
4.2 New York City Data Retention
5. SECURITY
6. EXERCISING CONTROL OVER YOUR PERSONAL INFORMATION
6.1 Data Storage Transfer
6.2 Your Privacy Rights
Residents of certain U.S. states
Canadian residents
EU residents
Children
7. COOKIES
8. PRIVACY POLICY CHANGES
9. QUESTIONS

    1. COLLECTION OF PERSONAL INFORMATION

    When you use our Products and Services, we collect certain Personal Information about you. We collect your Personal Information in a number of ways, including directly from you when you choose to give it to us, from your property manager or building owner, from your use of our Products and Services, and from third parties.

    1.1 Personal Information You Choose to Give Us

    We may collect Personal Information when you use certain aspects of our Products and Services, such as set up or use your Latch account, access spaces, share access with others, communicate with us, or make comments. We may ask you to provide certain Personal Information at various places and times and through various mechanisms on the Products and Services. This may include, for example, when you fill out and submit forms, including when you purchase our Products and Services online, when you initiate payments to us or third parties through our Products and Services, when you participate in promotions, or when you post information to an interactive chat feature. We may also collect Personal Information when you subscribe for email communications from us or when you email or call us, including when you call our Customer Support, where we record and monitor all service calls for quality assurance and training purposes.

    1.2 Personal Information We Obtain from Your Property Manager or Homeowner

    When you reside in or visit a multi-family building, you should know that our Products and Services are purchased and installed by our customers, who are multi-family property managers or building owners (for ease of reference, collectively, “property managers”), and that we collect your Personal Information for the purposes of providing property managers with our Products and Services. We also provide you with our Products and Services, but only to the extent that your property manager has enabled us to do so. 

    If you are a resident in a multi-family building, we will receive from your property manager your Personal Information to allow us to set up your Latch account, so that you can begin accessing spaces equipped with Latch access devices. This may include your full name, physical address, email address, phone number, and your lease and move-in/move-out dates. 

    Your property manager will transfer your Personal Information to us pursuant to their privacy policy and, where applicable, with your consent. Once we receive your Personal Information from your property manager, we will further process and share it, as needed to provide our Products and Services and in accordance with this Notice.

    When you reside in or visit a single-family home, the single-family homeowner who purchased and installed our Products and Services in the home may provide us with your Personal Information to allow us to set up your Latch account. This may include your full name, the physical address of the property where you reside or that you will visit (depending if you share a residence with the homeowner or visiting the home), email address, phone number, and your visit dates, if you are a visitor.

    Homeowners are responsible for obtaining consent from any individual whose Personal Information they share with Latch.

    1.4 Personal Information We Obtain Through Your Use of Our Products and Services

    When you access or use our Products and Services, we collect certain information about your activities. This includes your door access history (including images and videos, where applicable) at private and common doors when you use our access and security devices, including Latch readers, locks, cameras, and intercoms; your geolocation when you use our Virtual Intercom; details about your usage of our smart home devices (for example, temperature and humidity monitors, water leak detectors, connected power and light switches, motion detectors); your history of communications with us (for example, when you contact our Customer Support); your payment history (e.g., when you purchase products through our website); and your use of our website. This information includes both Personal Information and non-Personal Information that relates to your usage of our Products and Services. 

    When you use Latch from your phone, computer, or other personal device, we also automatically collect device-specific information such as unique device identifiers, network information, IP address, hardware model, operating system, the ways in which your personal device interacts with Latch, and device status. When you visit our websites, we also track your usage information, including your location data, what links you clicked on, your IP address, and certain other available information.

    We do not rely on your geolocation to provide our services, except when you use the Virtual Intercom. If you use Latch Virtual Intercom, for security purposes, we will request you to allow us to access your location to verify that you are physically near the building before you can contact building residents using the Virtual Intercom. Furthermore, because Latch relies on Bluetooth functionality, some smartphone operating systems, such as Android, require you to enable location services in order to use the Bluetooth functionality of the Latch App. However, even in such instances, Latch does not purposefully collect your geolocation (other than for the use of Virtual Intercom, as described below). If we become aware of instances where we have inadvertently collected your geolocation from our service partners, we take steps to prevent it from occurring in the future and to remove it from our datasets. We do not track your location. To better understand how your personal device manufacturer uses your location information, we recommend familiarizing yourself with their privacy policies and terms of service.

    Access History

    Your access history consists of access information (or access events, or access logs) captured by our access devices when you initiate an unlock. Access events are sometimes accompanied by photos. At private doors, for example, some of our access devices may capture an image when an incorrect doorcode is entered. This is done for security purposes, so that you can see who attempted an incorrect code at your door. At common doors in multi-family buildings, for building security purposes, our readers may capture images of all unlocks.

    At a residence in a multi-family building, such as an apartment, the access history and corresponding photo (if any) collected from a Latch access device remain private to each person whose account is set up with resident permissions to that residence. That means that you will be able to see your resident access history at your unit, but not access histories of other individuals who are also set up as residents at your unit. Additionally, when you view your unit’s access history, you will also be able to see access events by any non-resident accounts, such as your guests and property managers. 

    Importantly, to protect resident privacy, we do not share your access history at your door with your property management. If you are set up as a resident at your apartment, your property management will not be able to see when you enter your apartment. Your property management will be able to see when you enter any common door in the building. Your property management also will be able to see when any non-resident account holder (such as your guests, any property management team member, or another third party) enters your private unit. Property managers have this visibility into access events in order to help ensure safety and security of their buildings.

    The restrictions on sharing your access information described above are designed to protect private unit access information of multi-family building residents from being viewed and used by multi-family building owners and property managers. These restrictions do not apply to individuals who purchased our Products and Services for the use in their single-family homes. If you are a single-family homeowner, resident, or guest, your access information is viewable in accordance with the choices made by the Latch account holder who granted or modified your access.

    1.5 Personal Information We Obtain from Third Parties

    In jurisdictions that allow it, for our lead generation and marketing purposes, we may purchase contact information of potential commercial customers. We never knowingly purchase contact information of residents of multi-family buildings for marketing purposes. You may always unsubscribe from our marketing emails through an unsubscribe link.

    2. USE OF PERSONAL INFORMATION

    We may use your Personal Information for the following purposes: 

    • To provide you with products, services, or functionality;
    • To monitor the safety and security of a building that is under our property management;
    • To analyze how you use and interact with our Products and Services;
    • To maintain and improve our Products and Services;
    • To develop new products and services; 
    • To communicate with you regarding your use of our Products and Services;
    • To respond to your questions or other requests; 
    • Process payments;
    • To conduct and administer customer or user surveys, contests, or promotions; 
    • To perform necessary operations to maintain our Products and Services, including to troubleshoot software bugs and operational problems; 
    • To prevent fraud, criminal activity, or misuses of our Products and Services, and to ensure the security of our IT systems, architecture, and networks; 
    • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties; 
    • To fulfill our legitimate business purposes; 
    • To fulfill any other purpose for which you provide your Personal Information; 
    • To fulfill other purposes disclosed at the time you provide your Personal Information; 
    • As otherwise required or permitted by applicable law; and 
    • For any other purpose with your consent.

    3. SHARING OF INFORMATION WITH THIRD PARTIES

    3.1 Non-Personal Information 

    We may share non-personal information, such as usage information, aggregated user statistics, and other non-Personal Information with third parties without restriction as permitted by applicable law. Latch may convert your Personal Information to non-Personal Information, including without limitation through hashing it or substituting a unique identifier for the Personal Information and we may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. 

    3.2 Personal Information

    We may share your Personal Information as set forth in this Notice, in any manner in which you expressly consent via the Product or Service, or in the circumstances described below. When we share your Personal Information with any third party, we do so pursuant to appropriate contractual arrangements designed to protect the privacy and security of your Personal Information.

    Other Latch users and building visitors

    When you choose to share access to a private or common space, we may disclose your name, address, and contact information to the individual you invited into the space so that they know who has given them access and where your space is. 

    If your building has a Latch Intercom at the front door, depending on the settings your property manager chose, your full name may display on the Intercom’s directory to enable visitors such as delivery personnel to call you in order to gain access to the building. If you would prefer to change how your name is displayed (including using an alias), you can change your Intercom display name from the Settings menu in the Latch App. If you are not able to change how your name appears in the Intercom directory, please contact your property manager for help. If you’re a building visitor, video footage of you may be shared with the resident or the property’s security team in order to help them identify you when you call them using the Intercom.

    If you purchased a Latch Intercom for your use at a single-family home, you will be able to choose the display set up and what information the Intercom directory provides to visitors.

    Third parties providing services on our behalf

    Latch works with its Service Providers and Partners to provide services such as data hosting services, payment services, smart home device integrations, and customer support and chat applications. We have data protection terms in place with every third party we engage for the provision of such services. When you input Personal Information on our website or the Latch App, you may be providing that information to such a third party. For instance, we retain third-party payment processors to process any payments you make to or through Latch. When you input your payment card information on our website, these third-party operators collect your payment card information via their sites in order to complete payment transactions. Where Personal Information you provide is being collected by the third party, its processing is not governed by this Notice. You should carefully review the privacy policy and terms for any third-party providers.

    Latch also uses product and services installation partners to install its products and enable services in buildings. We may share your Personal Information and other information with third parties who perform installation or other services on our behalf or on behalf of a property manager. 

    Property transfers

    If the building to which your Latch account is registered is transferred to new management or sold to new ownership, we will share your Personal Information with the new property manager or building owner. We do this to ensure the continued operation of a property with minimal disruption to your ability to unlock doors and share access.

    Affiliated or subsidiary companies

    We may share your Personal Information with our affiliated or subsidiary companies who require access to Personal Information for legitimate business purposes related to your purchase or use of our Products and Services, to process any request or inquiry, or for their marketing purposes. 

    Direct marketing

    We may share your Personal Information with our marketing vendors to market our Products and Services to you, including to advertise features, offers, promotions, sweepstakes, news, and events. We do not share your Personal Information with third parties for their own direct marketing purposes

    Legal requirements and law enforcement

    We may disclose Personal Information and other information when we believe in good faith that the law requires it; when we receive an enforceable request from governmental authorities conducting an audit or investigation; pursuant to a court order, subpoena, or discovery request in litigation; to verify or enforce compliance with our Terms of Service, terms of sale, or other agreements or policies governing the Products or Services and applicable laws, rules, and regulations; or whenever we believe disclosure is necessary to limit our legal liability or to protect or enforce the rights, interests, or safety of the Products or Services, their users or other third parties. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful.

    Sweepstakes and promotions

    If you choose to enter a sweepstakes, contest or other promotion, your Personal Information may be disclosed to co-sponsors and other third parties in connection with the administration of such promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law, such as on a winners list. Also, by entering a promotion, you are agreeing to the official rules that govern that promotion, which may include consent to additional or differing data practices from those contained in this Notice, and which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the promotion to use your name, voice and/or likeness in advertising or marketing associated with the promotion.

    Corporate change

    We reserve the right to disclose and transfer your Personal Information and other information in connection with negotiations of any proposed or actual corporate merger, consolidation, restructuring, financing, sale of substantially all assets, or other corporate change. 

    4. DATA RETENTION

    Generally, we keep your access device usage information in personal format, including access logs and any corresponding images, for a period of time described in this section to enable us to provide services to our customers, for our legitimate business interests, and to comply with the law. 

    In some jurisdictions, and as a Latch App user, you may request deletion of your account before the retention time periods described in this section expire. Before you make an account deletion request, please confirm with the appropriate property manager or Latch account holder that you do not have any active access at any door. If you have active access, your account cannot be deleted. Latch does not grant or revoke your access at any door; rather this is done by your property manager or the Latch account holder who invited you into the property. Please contact them to close your account (revoke your access) before you request account deletion.

    Furthermore, in its capacity as a service provider to multi-family building property managers, Latch does not have the right to make data and account deletion decisions on behalf of property managers. If you are a resident in a multi-family building, you should submit your deletion request to your property manager. You may also submit it through the Latch App by using the appropriate link or by emailing support@latch.com. If we receive your request directly, we will forward it to your property manager and request their permission to delete your data and/or account before the expiration of the applicable retention period described below. To comply with the law and our contractual obligations, we will not be able to delete any of your data or your account unless the property manager approves the deletion.

    If you are an owner, resident, or guest at a single-family residence, you may request account deletion directly from us 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.

    Any deletion request and our regular retention periods described below are subject to exceptions, as permitted by law, including to investigate security incidents; protect against malicious, deceptive, or fraudulent, or illegal activity; debug or improve our Products and Services; and defend or assert legal claims.

    4.1 General Data Retention 

    For users located anywhere except New York City, we retain user authentication data (or user access event logs, including timestamps showing when a user unlocked a Latch access device), for 2 years from the date of collection. After that time period, we delete or anonymize authentication data. 

    4.2 New York City Data Retention 

    We comply with the New York City Tenant Data Privacy Act (TDPA) with respect to data of residents of multi-family buildings located in New York City. Specifically, beginning on July 31, 2021, we delete or anonymize user authentication data (or user access event logs, including timestamps showing when a user unlocked a Latch access device) 90 days from the date of collection. We also delete or anonymize reference data, such as user credentials that are compared to authentication credentials to unlock a Latch device, 90 days after you permanently vacate your building. 

    5. SECURITY

    While we take reasonable steps to secure your Personal Information, no data transmission over the Internet can be guaranteed to be completely secure. Likewise, no storage or processing of your Personal Information on the Products or Services or on other servers or databases to which the information may be transferred can be guaranteed to be completely secure. Please consider this prior to submitting your Personal Information to us via the Products or Service.

    We use reasonable security measures to safeguard your Personal Information. These security measures may result in the collection, recording, and analysis of online activity or communications through our Products and Services. If you do not consent to these conditions, you must discontinue your use of the Products and Services.

    6. EXERCISING CONTROL OVER YOUR PERSONAL INFORMATION

    In general, you may browse the website without providing Personal Information. However, if you choose not to provide certain information through the website, we may not be able to provide certain services or process certain of your requests, and you may not be able to access all of the features that we make available online.

    6.1 Data Storage Transfer

    In order to provide our Products and Service to you, we may store and process your Personal Information in any country where we have facilities or in which we engage third-party service providers. As a result, your Personal Information may be transferred to countries outside of your country of residence, which may have different data protection rules than in your country. While such Personal Information is outside of your country, it is still governed by this Notice as well as the laws of the country in which it is located. Consequently, it will be subject to disclosure to the governments, courts, law enforcement, and regulatory agencies of such other countries as required under their laws. 

    6.2 Your Privacy Rights

    Residents of certain U.S. states

    Depending on the laws in your state, you may have certain privacy rights under applicable data privacy law with respect to your personal information. You can view our supplemental notice regarding the rights of residents of certain U.S. states here.

    Canadian residents

    Canadian users are entitled to be informed of the existence, use, and disclosure of their Personal Information, be given access to their Personal Information, and be able to correct inaccurate Personal Information. As a Canadian resident, you may submit a request relating to your Personal Information, including to receive a copy of your Personal Information, by contacting us at support@latch.com. We will respond to your request within 30 days. If we need additional time, we will notify you and explain the reasons for the additional time.

    EU residents

    Latch provides services exclusively within the United States and Canada, and does not sell products or provide services in any other markets, including in the European Union (“EU”), any EU-Member State, or any state belonging to the European Economic Area (“EEA”) and/or the United Kingdom (“UK”). Latch does not market its Products and Services to individuals in Europe, including EU, EEA, and the UK.

    Children

    The Service is intended only for adults over the age of eighteen (18) and is not directed to children younger than age eighteen (18). Latch also does not knowingly collect Personal Information from children under the age of thirteen (13) and will delete any information if later determined to be from a person younger than age thirteen (13) as required by applicable law.

    7. COOKIES

    Latch websites use cookies in order to improve user experience. For information on how Latch processes Personal Information collected in connection with our websites, please see our Cookie Policy.

    8. PRIVACY POLICY CHANGES

    This Notice may change prospectively from time to time effective upon posting of the updated notice on our website or Services. Your continued use of the Products and Services after we make changes is deemed to be acknowledgement of those changes, so please review this Notice periodically for updates. To the extent any provision of this Notice is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

    9. QUESTIONS