1. In General
1.1 The collection, administration and use of personal details by Tapkey complies with applicable data protection laws by ensuring that each user is able to decide herself, which personal details shall be made accessible to other users.
2. Categories of personally identifiable information collected by Tapkey
2.1. Tapkey collects information from users upon registration on its website and in connection with the use of any of Tapkey’s applications, including particularly the Online Shop. The person-related information collected by Tapkey falls in the following categories:
- first and last name;
- home or other physical address, including street name and name of city or town;
- email address; date of birth;
- payment details, especially creditcard information (credit card number, expiration date, CVV) and billing address (“Payment Information”);
- Hardware Identification Number of Tapkey hardware;
- access events and other events on Tapkey locking system (e.g. which user has opened or closed which Tapkey locking system);
- log data and error reports from apps and other Tapkey products;
- owner data: which user is the owner of which Tapkey locking system;
- authorization data and respective relationships between users: which user is authorized to open or close which Tapkey locking product;
- mobile devices: which user signs in from which mobile device (including the unique ID of the respective mobile device);
- and Key Fobs: which user uses which key fob.
2.2. Person-related data shall be saved and used by Tapkey in particular in order to offer new applications to the user, to improve such applications, or the Tapkey platform, respectively and conform them to the users’ needs.
3. Use and sharing of personally identifiable and non-personally identifiable information with third parties
3.1. By registering, the user explicitly agrees that Tapkey shall have the right to use all automatically collected person-related information, in accordance with the privacy settings of such user, for purposes of the Tapkey platform. Tapkey does not pass on person-related information (see Section 2, above) to third parties, except as required by law or with the consent of the user implements all reasonable measures to prevent the unauthorized access by third parties to saved details.
3.2. External Identity Provider. The registration and use of the user’s Tapkey-IDs is effectuated by a partner of Tapkey located outside of the European Union, currently in the USA. Additionally, Tapkey uses a procedure for the “delegation of authentication”, currently it is Google-ID. For the login, the Tapkey platform uses the Auth0 software component (see https://auth0.com/terms/ or https://auth0.com/privacy/ for more information) which requires the transfer of the user’s email address and password.
The user expressly consents that her/his data will be disclosed to the external identity providers named under section 3.2, whose servers are located in the USA or another non-EU country.
3.3. Hosting. For the storage of the user’s directly or indirectly person-related data, Tapkey currently uses the program Windows Azure Cloud (EU data room). The user expressly consents to his data being transferred to and stored by the aforementioned hosting provider. See https://azure.microsoft.com/de-de/support/legal/ for more information about Azure Cloud.
3.4. In-App Advertising. The user explicitly consents to the storage and use of person-related information for purposes of in-app advertising by Tapkey or its partners.
3.5. Payment Information. To make payments in the online shop or via in-app payments, the user has to enter the Payment Information. Payments are carried out via Recurly, Inc., a partner of Tapkey located outside of the European Union, at the moment in the USA. For the purpose of handling of payments, Tapkey transmits the Payment Information to Recurly. The user explicitly consents to the transmission of Payment Information to and usage by the aforementioned partner, with regards to the above named purpose.
4.1. Several areas of the Tapkey platform website use ‘cookies’ ─ small text files that are placed on the user’s computer, smartphone and/or stored by the browser. They are used by Tapkey to provide a more user-friendly, effective and secure service. Cookies also enable Tapkey to identify a user’s browser and offer services to such user. Cookies do not contain any personally identifiable information.
4.2 The user can disable the installation of cookies by entering the corresponding settings in his/her browser software. However, in this case the user may jeopardize his/her use the complete range of functions of the Tapkey platform to its full extent.
5. Google Analytics
5.1. The Tapkey platform uses Google Analytics, a web analysis service by Google Inc. (“Google”). Google Analytics uses ‘cookies’ (see Section 4, above). The information about your visit of the visit or app collected by the cookies, including your IP address, is usually transferred to a Google server in the USA and saved there. To the extent that the Tapkey platform has activated IP anonymization, Google first abbreviates your IP address within member states of the European Union or in other signatory states of the Agreement on the European Economic Area. Only in exceptional cases, will the full IP address be transferred to a Google server in the USA and abbreviated there. Google will use the information collected on behalf of the website operator to evaluate your use of the Tapkey platform, to compile reports about your activities within the Tapkey platform, and to provide further services to Tapkey related to use of the Tapkey platform and Internet use. Google will under no circumstances associate the IP address transmitted by your browser within the operations of Google Analytics with other Google data.
5.2. Accessing from the website, the user can prevent the data related to your use of the Tapkey platform, including your IP address, generated by the cookies from being recorded by Google and Google’s processing of this data by downloading and installing the browser plugin from the following link: https://tools.google.com/dlpage/gaoptout?hl=en/.
6. Google Ads
Tapkey uses the tool Google Ads Conversion to advertise Tapkey’s product offering on websites owned and operated by 3rd parties. Based on those tools we are able to measure the success and efficiency of certain ad campaigns. This in turn allows us to consider your personal interest for presenting advertisements and to optimize our online presence for an optimal user experience. Online ads are delivered by Google via Google’s AdServer infrastructure. Therefore, Ad Server Cookies are used to measure the efficiency of presented ad campaigns (displaying and interaction). If a user clicks on a displayed ad, Google stores a cookie on your device. Those cookies can not be leveraged to personally identify you, and the cookies will expire after a certain time period (usually 30 days). a Cookie can store several pieces of information, e.g. last timestamp of presenting an ad, counting of impressions or a unique Cookie ID as well as optional opt-out settings (performed by the user). We do not receive any personal information about you from Google (furthermore we can not identity you personally), we solely are provided with a set of statistical information that helps us to optimize our ad campaigns ongoingly.
8.1. Tapkey uses Zendesk, a product of the company Zendesk Inc, 410 Townsend St, San Francisco CA, 94107, USA (“Zendesk”), to process support requests, customer enquiries and for the help center (https://support.tapkey.com and https://tapkeyb2b.zendesk.com/).
8.2. The data required for this is transferred to a Zendesk server and stored there. The following person-related data will be collected and transmitted: name, email address and phone number.
8.3. Zendesk has certified compliance with the EU-U.S. Privacy Shield Frameworks. Its certifications can be viewed on the website of The International Trade Administration (ITA), U.S. Department of Commerce at https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG.
9.1 Tapkey uses CleverReach, a product of the company CleverReach GmbH & Co. KG, Schafjueckenweg 2, 26180 Rastede, Germany (“Cleverreach”) to send newsletters and analyse the behavior of newsletter recipients such as their open and click rate. For more information on how data is analyzed by CleverReach, please visit: https://www.cleverreach.com/en/features/reporting-tracking.
9.2. In order to sign up for the Tapkey newsletter, a user has to submit and verify his/her email address (double opt-in). This data is transmitted to CleverReach and stored on its servers.
9.3. A user may revoke his/her consent any time by unsubscribing from the newsletter. For this purpose, we provide a link in every newsletter we send. The user’s data will then be deleted from CleverReach’s servers. The revocation does not affect the legality of the data processing that has already been carried out. For further information, please refer to the data privacy statement of CleverReach at: https://www.cleverreach.com/en/privacy-policy.
11. Your consent