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/.
6.1 The Tapkey platform uses the support tool Intercom of Intercom, Inc. (INTERCOM, INC., 55 2nd St, 4th Fl., San Francisco, CA 94105 USA). In this respect, it collects certain person-related data and passes on the information at regular intervals.
6.2 The following person-related data will be collected in this respect and will be transferred after registration on the platform: Mailing Address, Phone number (if entered)
6.3 Tapkey transfers this person-related data to improve its services and to work on your support questions faster and more efficiently, personalized via chat or e-mail. In order to learn more about our user base, Intercom collects publicly available data, such as the company of a user, job title, website, social network handle, and addresses. Tapkey also uses Intercom for the analysis and assessment of the website usage (e.g. duration or role of the user). It is our goal to give individual assistance for the use of the website and to optimize the website with respect to usability.
6.4 To prevent the transfer of person-related data to intercom, Inc. after registration, please send an e-mail to email@example.com. After receipt and processing of such an e-mail, the data will only be transferred to Intercom, Inc. as anonymized data, your support questions will be treated anonymously, and any analysis of your user profile will be conducted only on the basis of anonymized data.
6.5 Intercom, Inc. has joined the EU-US “Privacy Shield”-Agreement, meant to increase the level of data protection concerning companies not incorporated in the EU. More information for the data protection rules of Intercom, Inc. can be found here https://docs.intercom.io/privacy/. The Terms of Service can be found here https://docs.intercom.io/terms/.
8 Your Consent