Latch takes your privacy very seriously. We created this Privacy Policy (“Privacy Policy”) to explain our treatment of the personally identifiable information (“PII”) we collect when you use or access our products and services. It includes information about how PII is used and shared and about your choices regarding your PII. Please read this Privacy Policy carefully. When you use the Hardware and/or the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.
The Mobile Apps provided by Latch are intended for use in the United States in connection with the Latch System. You hereby acknowledge and agree that you may only use the Mobile Apps, the Latch System and any other Services provided by Latch within the United States, even if you are able to download the Mobile Apps outside of the United States.
Definitions
Scope
This Privacy Policy covers:
This Privacy Policy does not cover information collected by individuals or entities who provide third party websites, services or applications (“Third Party Services”) or to individuals that we do not manage or employ, even if you access, encounter or interact with them through the Services (e.g. if you click on links to those Third Party Services on the Site or Apps). While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we are not responsible for the privacy policies or practices of Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies.
Uses of Information
We use information, including PII to:
Types of Information Collected
We receive information about you from various sources, including:
The type of information Latch collects from you depends on the type of user you are. For more information about user types, please review the Terms. However, most categories of information are collected across all user types, so it is important to read through all the categories of information below, in case they apply to you.
Account and Setup Information: When you create an Account, you will provide information that could be PII or that could otherwise identify you or your location. The exact categories of information you provide will depend on the type of Account but almost all Accounts will generally require you to provide the following:
If you are a User, you may also need to provide information about your insurance policy status and carrier.
If you are an Owner, you may also need to provide your tax ID number and information about the lease term for each unit equipped with Hardware.
This information is used to provide you with the Services, and may be shared with other users or our business partners to provide you with the Services. For example, if you are a User or Owner granting access to a Guest, some of your Account profile information, such as your name and the address of the Hardware’s location, may be shared with the Guest so that the Guest can correctly identify the location to which you are granting them access.
Guest Information: Guests can use a Guest Code to access a location without registering for an Account, but Guests who do register will provide much of the same Account and Setup Information as other registered users. Additionally, a User or Owner granting access to a Guest may enter information about the Guest, such as:
Additionally, the Hardware may capture and store video and/or photographic images of Guests and other individuals (collectively, “Images”) who interact with the Hardware. For example, certain Hardware may take a picture of a Guest or record a video clip when he or she enters a Guest Code or uses their Device to unlock the Hardware.
Guest information is shared with the applicable Hardware’s User and Owner. More information about the sharing of Guest information is provided in the “Information Shared With Other Users” section below.
By using the Services in any manner, a Guest hereby expressly consents to the collection, storage, use and disclosure of their information, which may include PII, in accordance with this Privacy Policy. If you are a Guest and do not consent to any of the foregoing, you must not use or access the Services, including any Hardware.
If you are a User or Owner, please ensure that you have a Guest’s consent to the collection, use, storage, and disclosure of their information, including their Images, in accordance with this Privacy Policy before (i) providing such information to the Services or (ii) inviting such Guest to use the Services, including by granting them access through a Guest Code. By inviting a Guest to use the Services or providing a Guest with a Guest Code through the Services, you represent and warrant that you have all necessary consent to share such Guest’s information, including their PII, with Latch for use in accordance with this Privacy Policy.
Device and Application Information: We may collect some Device-specific information when you access the Services using a Device, such as when a Device interacts with Hardware (e.g. when it unlocks or syncs with a Latch electronic physical access control product). Device information may include:
We use Device information for Service support, maintenance and diagnostics, such as to troubleshoot issues with your Hardware or the Apps when you request support. We may share Device information with providers of Third Party Services in connection with such support.
Location Information: When you use certain features of the Services, such as the Apps, we may receive, store and process information about your location, including general information (e.g., IP address or zip code) and more specific information (e.g., GPS-based functionality on Devices used to access the Services). If you do not want your Device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your Device. Please note that if you disable such functions, certain parts of the Services may not work.
Other Information Collected in Providing the Services: We collect information relating to the setup, general performance, and operation of our Services, including the Apps and the Hardware, including:
We use this information to operate, monitor, maintain and improve the Services, and to allow you to operate, monitor and maintain your Account and your Hardware (if applicable).
Usage of Service Providers: The Services may include integrations with Third Party Services (for example, a cleaning or delivery service to which you grant access). If you use these Third Party Service through our Services, we may collect and store information about your use of the integrated services. We use this information to improve our Services and may share the information with the Third Party Service providers to help them improve their products and services. Please note that we do not control these Third Party Service providers and cannot take responsibility for the content, privacy policies or practices of those Third Party Services.
Purchase and Financial Information: If you purchase one of our Services or otherwise make a purchase through the Services, we may request information that is necessary to process and complete the transaction, including:
We do not collect financial information, such as your payment method (valid credit card number, type, expiration date or other financial information); that information is collected and stored by our third party payment processing company (the “Payment Processor”), and use and storage of that information is governed by the Payment Processor’s applicable terms of service and privacy policy.
We may from time to time request and receive some of your financial information from our Payment Processor for the following purposes:
We use and disclose information collected in connection with your transactions to process and facilitate your order (or return, if applicable), which may require disclosure to our third party business partners.
Information Collected Using Cookies: Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit.
We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services. Our cookies do not, by themselves, contain PII, and we do not combine the general information collected through cookies with other PII to tell us who you are. We do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account.
Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.
This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.
Information Collected From Web Beacons: We may deliver a file (known as a “web beacon”) from an ad network to you through the Services to increase the effectiveness of ad delivery. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.
Non-PII: We may automatically collect and use information about the way users (both registered and unregistered) interact with the Services. Some of this information is derived from PII, but we anonymize or aggregate it so that it does not identify the individual from whom it was derived (resulting in “Non-PII”). Non-PII is not personally identifiable and cannot be tied back to the user from which it was obtained.
Non-PII enables us (and third parties we authorize) to figure out how and how often users engage with different parts of the Services so that we can analyze and improve them. We use Non-PII for:
We may share Non-PII with our partners, service providers and other persons with whom we conduct business so that our partners can understand how and how often people use our Services and our partners’ services. These third parties may also share with us non-private, aggregated or other Non-PII about you that they have independently developed or acquired.
Email, Text, and Push Notification Communications: We may communicate with you via email, SMS, MMS or other text message (“Text Message”) or using push notifications. We may collect information regarding such communications, such as by receiving confirmation when you open an email, read a Text Message or receive a push notification. We use this information to improve our Services, including our customer service.
Information About Your Contacts: For features in the Services that access your Device contact list, we will only store information for contacts who register with the Services or who you add as Guests. We will only access and store such information with your express consent.
Information About Minors: Our Services are not directed to children under 13 years old and we do not knowingly collect PII from children under 13. If we learn that we have collected PII of or from a child under 13 years old, we will take steps to delete such information from our systems as soon as possible.
Other Ways Information is Shared
In addition to the purposes set forth above, we may share your information for the following purposes:
Information Shared With Other Users: In connection with certain features of the Services, Latch may share some information about users with other users who have sufficient access privileges. The following are ways in which Latch may share information about you with other users:
Unless expressly stated herein or expressly consented to by you, Latch does not share your PII with any other users.
Facilitating Transactions: We may use your information in order to facilitate your transactions on the Services (for example, if you purchase any Hardware). In some cases, we employ and contract with people and other entities to perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share PII with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use PII or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of PII with our Agents.
Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Additionally, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your PII as set forth in this policy.
Building Transfers: The Owner (e.g., the property owner) of the Hardware may choose to sell the property to a third party. If this type of sale occurs, your user information (including any PII that is a part of such user information) may be transferred to the buyer of the property, who will become the new Owner. You acknowledge that such transfers may occur, and that a new Owner may continue to use your user information (including PII) as set forth in this policy.
Our Protection and the Protection of Others: We reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary for the following purposes:
This may include exchanging information with other companies and organizations for fraud protection and spam/malware prevention.
Marketing: We may use your information to send you news about our services, products or promotions. We may also serve advertisements, and also allow third parties to serve advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include ad servers, ad agencies, ad technology vendors and research firms.
Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on anonymized information inferred from information provided to us by a user (including PII such as gender or age), Services usage patterns of particular users, or a user’s activity on Third Party Services.
We do not provide PII to any ad networks for use that is not related to the Services. We will give you the ability to opt out of marketing-related e-mails by logging in and changing your Account settings or by clicking on a link in each such e-mail.
With Your Consent: Except as set forth in this Privacy Policy, you will be notified when your PII may be shared with third parties, and will be able to prevent the sharing of this information.
Information Security
We seek to protect your Account information to ensure that it is kept private, and we use generally accepted industry-standard techniques to protect the PII submitted to us. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of any information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information. It is your responsibility to prevent unauthorized access to your Account and information by selecting and protecting your Account password appropriately, and limiting access to your Devices, including by signing off after you have finished accessing the Services.
Access to Information
If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings. Please note that Guests without an Account cannot access or edit any information.
California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: P.O. Box 2048, New York NY 10159.
Account Deletion
You can delete your Account by emailing support@latch.com or using functionality made available through the Apps. After termination, we may retain your information on our servers in accordance with our internal data retention policy.
Choices Regarding Information
Privacy Policy Changes
We may amend this Privacy Policy from time to time. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. If you use the Services after changes have been posted, you agree to be bound by the changes.
Latch Contact Information
If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to contact@latch.com, and we will try to resolve your concerns.
An Additional Note Regarding Data Processing
Your PII may be collected, processed and stored by Latch or our service providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your PII, in some of these countries may not be equivalent to those in your country. If you are using the Services in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, you consent to the transfer of your personal data to the United States and other countries where Latch and its service providers operates.
Headings
The section and paragraph headings in this Privacy Policy are for convenience only and shall not affect its interpretation. Any use of “including”, “for example” or “such as” in this Privacy Policy shall be read as being followed by “without limitation” where appropriate.
Effective Date: September 12, 2018
