Effective Date: July 11, 2019.
- Scope and Consent
- Information We Collect
- Uses and Retention of Information
- Your Choices
- Disclosure of Information to Third Parties
- Information You Share on the Site
- Communication Preferences and Marketing (opt-out)
- Tracking Technologies (Cookies)
- Accessing, Reviewing, and Changing your Personal Information
- Notice to California Residents
- EU Data Subject Rights
- Links to Third Party Sites
- Children's Privacy
- International Transfer of Information
- Notification Regarding Updates
- How to Contact Us
1. Scope and Consent
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).
(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
(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.
(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.
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.
(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.
(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.
7. Communication Preferences and Marketing (Opt-out)
We do not sell or rent your personal information to third parties for their marketing purposes without your consent. 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.
- 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
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 1-800-464-2088 or e-mailing us your request to email@example.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 1-800-464-2088 or e-mailing us your request to firstname.lastname@example.org. 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.
You also have the right to lodge a complaint with a supervisory authority.
12. 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.
13. 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.
14. 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.
15. Notification Regarding Updates
16. Contact Us
If your questions are not answered online, you may email us at email@example.com or write to us at:
© 2020 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.