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Master Lock Company LLC Privacy Policy

Effective Date: October 27, 2022.

Welcome! Thank you for visiting a Master Lock Company offering. To help inform you, we provide this notice explaining our online information practices and the choices you can make about the collection and use of information you submit or we collect through our website and our other related mobile websites, services, tools, mobile applications and other applications to which this Privacy Policy is linked (collectively, the "Site"). The Site is owned and operated by Master Lock Company LLC ("Master Lock," "us," "our").

Contents

  1. Scope and Consent
  2. Information We Collect
  3. Uses and Retention of Information
  4. Your Choices
  5. Disclosure of Information to Third Parties
  6. Information You Share on the Site
  7. Communication Preferences and Marketing (opt-out)
  8. Tracking Technologies (Cookies)
  9. Accessing, Reviewing, and Changing your Personal Information
  10. Notice to California Residents
  11. EU Data Subject Rights
  12. Notice to Canadian Residents
  13. Links to Third Party Sites
  14. Children's Privacy
  15. International Transfer of Information
  16. Notification Regarding Updates
  17. How to Contact Us

Privacy Policy

2. Information We Collect

(a) Registration and Account Information: You can browse the Site without telling us who you are or revealing any personal information about yourself. If you choose to register for an account with us, we require you to create a username and password, you choose to give us your personal information and are not anonymous to us. When you register an account, create a profile, purchase products, or otherwise engage with our Site, you may provide personal information such as name, physical address, email address, phone number, mobile telephone number, payment information (processed through a third-party payment processor), zip codes, and other relevant information. Personal information is only associated with your account/profile when you sign in as a registered user. We also collect information relating to the business you represent and demographic information such as domain information, zip codes and areas of interest.

(b) Information to respond to your requests: You may give us your personal information so we can respond to your requests, send you newsletters and other communications you request. Details of how you can opt-out of receiving any commercial communications from us are detailed in the section headed "Your Choices" below.

(c) Information From Other Sources: The information we collect may be combined with information from outside records that we have acquired in accordance with the law and/or your permission. For example, we may obtain information about you from events we attend together and through partnerships with third parties.

(d) Mobile Information: If you access the Site through a mobile device we may collect additional information from you (e.g. your unique device identifier or a mobile number).

(e) Technical Usage Information: When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Sites ("usage information"). We use tracking technologies, such as (including pixel tags, cookies, flash cookies, clear GIFs, embedded scripts, Javascript, local storage and e-tags/cache browsers) to collect usage information. During some visits we may use software tools to measure and collect session information, including page response times, download errors, time spent on certain pages and page interaction information.

(f) Location Information: As a feature of one or more of our connected products, we collect location information on the precise location of the device you use to connect to the product at the time of use. This may include information about your device's location derived from your device gps, Bluetooth identifiers, and WiFi signal. We provide this information to you in reports and audit trails, as you request.

3. Uses and Retention

(a) We collect information about you for our legitimate business interests, in order to better understand your interests, and improve your experience of using the Site. To learn more about how we use tracking technologies and cookies, see Section 8 of this Privacy Policy.

(b) We collect information about you to provide, maintain, and improve the Site and our products. In some cases, if you do not provide the information to us, it will prevent us from being able to provide services you request or otherwise inhibit our ability to operate the Site.

(c) Operate Our Site: We use the information collected to (i) respond to your requests or orders; (ii) provide customer service (e.g., to resolve disputes, address feedback, or fix problems with your account/profile or the Site); (iii) personalize your experience by providing content on the Site, including targeted advertising/communications, that we believe may be of the most interest to you; (iv) improve the Site; and (v) give you information about your account.

(d) Analyze and Aggregate Non-Personal Information: We use aggregate information about our users and non-personal information to analyze Site and user behavior and prepare aggregated reports.

(e) Prevent Fraud: We use information from the Site to prevent, detect, and investigate fraud, security breaches, and potentially prohibited or illegal activities, and enforce the Terms of Use applicable to the Master Lock product or Site you are using.

(f) Communicate With You: We use your information to contact you to maintain the Site, your account, or to comply with your stated communication preferences, or to provide other services requested by you, as described at the time when we collect the information from you, or to contact you for other purposes authorized by law.

(g) Marketing Analysis: We may use the information (including personal data) to understand how users use the Site and our products and to improve our Site and products.

(h) Data Retention: Your information will be retained by us for as long as needed for us to comply with our contractual obligations, and other business purposes, including global legal obligations to retain data.

4. Your Choices

You can control how and when you want to receive commercial notifications from Master Lock on the Site or by following instructions within the notices. If you have consented to our collection of your personal data or explicitly consented to our collection of special/sensitive categories of personal data your consent can be withdrawn at any time. For more information about how to opt-out of marketing communications go to Section 7 (Communication Preferences and Marketing (Opt-out)), and for information about how to change or update your personal information, or to withdraw your consent, go to Section 9 (Accessing, Reviewing, and Changing Your Personal Information). For more information about the rights of European Economic Area (EEA) residents go to Section 11 (Residents of the European Economic Area and Switzerland).

Mobile Push Notifications/Alerts
With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device when you use certain of our products and services. You can deactivate promotional messages at any time by changing the notification settings on your mobile device or contacting us at the email provided below at Section 16.

Device Content on the Mobile Application
With your consent, certain of our products and services with mobile applications may access information on your mobile device such as your SMS and email functionality. You can always withdraw such access by not allowing our products to access the SMS and email functionality for a specific task or, if for multiple tasks, going into your device settings and removing the application's access to that information. Please note that if you enable access and then remove that access, this could affect the availability and functionality of the product or service and of certain features of the mobile application.

5. Disclosure

Information collected on the Site may be shared with:

(a) The Fortune Brands Home & Security, Inc. Corporate Family: We may share the information we collect about you with the Fortune Brands corporate family and its and our affiliates and subsidiaries, as well as with third-party suppliers and service providers. The information may be disclosed (i) to provide joint content and our services (e.g., registration, transactions, analytics and customer support); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; (iii) to guide decisions about Fortune Brands Home & Security or third-party's business, assets, operations, rights, products, sites, applications, services, tools, and communications and (iv) processing and storage of information.

(b) Service Providers and Other Third Parties We may disclose your information to service providers under contract who help with our business operations (such as, but not limited to, fraud investigations, bill collection, payment processing, shipment; recruitment, employment, research, and site analytics and operations). We may also share your information with third parties to defend against legal claims; to investigate, prevent, or act against illegal activities, suspected fraud, situations involving potential threats to safety, or violations of Master Lock terms of use; to protect our operations, assets, and intellectual property; to allow us to pursue appropriate legal remedies or limit damages; to pursue any reorganization, merger, sale, joint venture, assignment, transfer of assets, or other disposition of all or any portion of our business, assets, or stock; or as otherwise required by law.

(c) Other Entities with your Consent Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

(d) Legal and Law Enforcement Law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Master Lock user to legal liability. In such events, we will only disclose information relevant and necessary to the investigation or inquiry.

(e) Change of Control - New Owners Other business entities, should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will make reasonable efforts to request that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information would be used contrary to this Policy, you will receive prior notice.

(f) Ad Networks On the Site, we may work with third parties to serve advertisement, provide us with data collection, reporting, ad response measurement and site analytics and assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit or set their own tracking technologies/cookies. The use of these technologies by these third parties is subject to their own privacy policies and is not covered by this Privacy Policy. They might also obtain information about other applications that you have downloaded to your mobile device, the mobile websites you visit and other information about you or your device in order to analyze and serve anonymous targeted advertising on the Site and elsewhere. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices or, for EU users, http://www.youronlinechoices.eu/ or for Canadian users: https://youradchoices.ca/.

(g) Companies In The Mobile Industry If you access the Site through a mobile device, we may also share your information with carriers, operating systems and platforms.

(h) Violation of Terms We may disclose information about you if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of Master Lock or others.

6. Information You Share on the Site

If you post information or content, such as by posting photos, commenting on a blog, or participating in online forums or communities, or when you interact with our Site through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites' privacy policies and terms of use to learn more about their privacy practices, which we do not control.

7. Communication Preferences and Marketing (Opt-out)

We may combine your information with information we collect from other companies and use it to improve and personalize the Site. If you do not wish to receive marketing communications from us, you can indicate your communications preference within the direct communication from us or through your account/profile settings. You may not opt-out of administrative emails (for example, emails about your transactions or policy changes) for your registered account.

8. Tracking Technologies (Cookies)

When you visit the Site, we and our business partners may use tracking technologies to enhance your online experience or customize our offerings.

A few additional important things you should know about our use of tracking technologies (cookies):

  • We offer certain features that are available only through the use of tracking technologies.
  • We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
  • If you are a registered user and you specifically request that our Site remembers your login information, you are allowing us to place a permanent cookie onto your computer.
  • You may encounter tracking technologies/cookies from our third-party service providers, that we have allowed on our site that assist us with various aspects of our web site operations and services, such as Google Analytics; for more information about Google Analytics, see: https://policies.google.com/technologies/cookies.
  • You also may encounter tracking technologies from third parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page created by another user, there may be a cookie placed by that web page).

9. Accessing, Reviewing, and Changing Your Personal Information

Registered members can review and change personal information at any time by accessing their accounts on the Site. You should promptly update your personal information if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with the law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise if your account or membership is terminated or suspended, we may maintain some information to prevent re-registration. If you do not have an account with us, you can email us at the email provided below at Section 16 with questions.

10. Notice to California Residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to disclose the following information with respect to our collection, use, and disclosure of personal data, as these terms are defined by the CCPA.

  • Categories of Personal Data Collected: In the preceding 12 months, we may have collected one or more of the following categories of personal data: identifiers, characteristics of protected classifications under California or U.S. law, commercial information, internet and electronic network activity, geolocation data, audio and visual information, inferences drawn about your preferences, and other categories of personal data that relates to or is reasonably capable of being associated with you.
  • Business or Commercial Purpose for Collecting and Using Data: We may collect personal data for one or more of the following business purposes: to provide, maintain and improve our product services; to monitor and analyze trends, usage and activity related to our products; to detect, investigate and prevent fraudulent transactions and other illegal activities as well as protect the rights and property of Us and others; facilitate contests, sweepstakes and promotions and process and deliver entries and rewards; product warranty support; product service and functionality support; product registration; to complete product order requests; to respond to product inquiries; to respond to requests about product information or where and how to have products installed; to respond to product complaints; legal defenses; and, sales related purposes.
  • Categories of Sources of Personal Data: We may have collected personal data from you from one or more of the sources described here: mobile applications which you downloaded onto your phone; our connected products; customer requests made by you, for example on-line, through customer service or by mail; social media; emails received from you; shipping companies; product distributors and installers; and third party marketing related companies.
  • Categories of Personal Data Disclosed: In the preceding 12 months, we may have disclosed the following categories of personal data for business or commercial purposes: identifiers, internet and electronic network activity information, commercial information, audio and visual information, and demographic information.
  • Categories of Third Parties With Whom We Share Personal Data: We may share your personal data with one or more of the third parties described here: between and among companies which are under common ownership with Us; vendors, service providers and consultants that perform services on our behalf; companies which store and process data on our behalf; companies which perform data analytics for us; companies which help service and install our products; companies which help deliver and track our products that are ordered, replaced or repaired; companies which provide information to you about where to find or have installed our products and services; law firms; companies which send to you information about products on our behalf; and, companies which you request Us to share your Personal Data with.

Your Consumer Rights

California consumers have the right to request access to their personal data, additional details about our information practices and deletion of their personal data, subject to certain exceptions. California consumers also have the right to opt out of sales of personal data, if a company is selling their data. We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf; however, we will need proof that the agent is authorized by you and will need to confirm your identity. We will not discriminate against you if you choose to exercise your rights under the CCPA. Note, however, for your protection, we will be unable to fulfill some of the requests summarized below if we or a third party verification service we employ is unable to verify your identity.

Right to Know: You may request access to the specific pieces of personal data we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal data we have collected about you, the sources of such collection, the categories of personal data we share for a business or commercial purpose, and the categories of third parties with whom we share your personal data. You may make these requests by visiting this page or calling 1-800-308-9244 or e-mailing us your request to customerservice@mlock.com. We will verify your request by using a third party identity verification service. Please note that, for your safety, we cannot fulfill certain requests if we cannot verify your identity.

Deletion: You may request that we delete the personal data we have collected about you. Please note that we may retain certain information as required or permitted by applicable law. You may make these requests by calling 1-800-308-9244 or e-mailing us your request to customerservice@mlock.com. We will verify your request by using a third party identity verification service. Please note that, for your safety, we cannot fulfill certain requests if we cannot verify your identity.

11. Residents of the European Economic Area and Switzerland

Legal Basis for Processing
If you are in the EEA or Switzerland, when we process personal data about you, we do so in accordance with the following lawful bases:

  • We need to use personal data about you to perform our responsibilities under our contract with you. For example, we may use your payment information to process payments, through a third-party payment processor, for providing the products or services you have requested as well as your contact information as present in your user profile in order to properly bill you and associate products and services with your account. In addition, we may also process information about your device in order to provide you with software updates and provide you with product support.
  • We have your consent to do so. For example, with your consent we will send you commercial emails relating to our products and services.
  • We have a legitimate interest in processing personal data about you. For example, we may process personal data about you to provide, secure, and improve our Site as well as to improve our products and services.
  • We need to process personal data about you in accordance with legal obligations we have. For example, we may need to retain some personal data about you to prove that we comply with applicable law such as retaining sales information about your transactions with us and certain emails you may send us as evidence of our compliance with your requests, if applicable.

Data Subject Rights
If you are a resident of the European Economic Area (EEA), you have the right to: (a) request access to your personal data and rectification of inaccurate personal data; (b) erasure of your personal data; (c) request restrictions on the processing of your personal data; (d) object to processing your personal data; and/or (e) the right to data portability.

For information about how to get access to personal data and for exercising your rights, please refer to the Contact section of this Privacy Policy.

You also have the right to lodge a complaint with a supervisory authority.

12. Notice to Canadian Residents

If you are a resident of Canada, these additional terms apply to our collection, use and disclosure of personal information. Any reference in this Privacy Policy to “personal data” should be understood to refer to “personal information” under applicable Canadian privacy laws.

Consent: By submitting personal data to Master Lock, or our service providers and agents, you consent to the collection use, disclosure, and transfer of your personal data for the purposes described in this this Privacy Policy or as communicated to you at the relevant time, and as permitted or required by law.

Access and Correction: Upon your written request, and subject to certain exceptions provided by law, we will inform you of the existence, use, and disclosure of your personal data and give you access to that information. We may charge a minimal fee for providing such access to you. If you are able to establish that the information is not accurate or complete, we may take reasonable steps to delete and/or correct the information so that it is accurate, complete, and up-to-date. You may make these requests by calling 1-800-308-9244 or e-mailing us your request to customerservice@mlock.com. We may verify your request by using a third party identity verification service. Any such information will only be used for the purpose of confirming your identity and will not be retained by Master Lock. Please note that, for your safety and to protect your privacy, we cannot fulfill certain requests if we cannot verify your identity. Further, please make any privacy related requests or inquiries by calling 1-800-308-9244 or e-mailing us your request to customerservice@mlock.com.

Canada’s Anti Spam Law (“CASL”)
We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.

13. Third Parties

Our Site may contain links to other third party websites. We are not responsible for the privacy practices or the content of these third party sites.

14. Children's Privacy

The Site is a general audience site and it is not intended for children under the age of 13. We do not knowingly collect personal information via our websites, applications, services, or tools from users in this age group.

15. International Transfer

As we operate internationally, and many of our computer systems are currently based in the U.S. Your personal information may be processed in the U.S. and elsewhere where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. You understand that the U.S. government may obtain access to the personal data you submit if necessary for investigative purposes. We use adequate means to transfer data under applicable laws.

If you are in the EEA, we provide adequate protection for the transfer of personal data to countries outside of the EEA, including through a series of intercompany agreements based on the Standard Contractual Clauses authorized under EU law. You are entitled to obtain a copy of these agreements by contacting us using the contact information below.

16. Notification Regarding Updates

From time to time, we may update this Privacy Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the Site. You should check the Site frequently for updates. We will also notify you of any material changes in the way that we collect or use your personal data.

17. Contact Us

If your questions are not answered online, you may email us at masterlock@mlock.com or write to us at:

Master Lock Company LLC World Headquarters Attn: Customer Care
6744 S Howell Avenue Oak Creek, WI 53154 Phone: 1-800-308-9244

© 2024 Master Lock Company LLC. All rights reserved.

For customers or users in the EEA, the data controller for purposes of your personal data is Master Lock Company LLC. For end users of the Vault Enterprise product or end users of Master Lock customers, the data controller would be the Vault Enterprise customer or your employer.