Privacy Policy
This Policy (the "Policy") explains the way of treatment of the information which is provided or collected in the websites on which this Policy is posted. In addition, the Policy also explains the information which is provided or collected in the course of using the applications of KeyWe which exist in the websites or platforms of other companies.
KeyWe is the controller of the information provided or collected in the websites on which this Policy is posted and in the course of using the applications of KeyWe which exist in the websites or platforms of other companies.
Through this Policy, KeyWe regards personal information of the users as important and inform them of the purpose and method of KeyWe 's using the personal information provided by the users and the measures taken by KeyWe for protection of those personal information.
This Policy will be effective on the ___th day of ____, 2020 and, in case of modification thereof, KeyWe will make public notice of it through posting it on the bulletin board of KeyWe's website or individual notice through sending mails, fax or e-mails).
1. Information to be collected and method of collection
(1) Personal information items to be collected
Personal information items to be collected by KeyWe are as follows:
• Information provided by the users
KeyWe may collect the information directly provided by the users.
|
Title of service |
Items to be collected(examples) |
|
Internet membership service |
∘
Name, email
address, ID, telephone number, address, national information, encoded
identification information (CI), identification information of overlapped
membership (DI)
|
|
Online payment service |
∘
Name, address,
telephone number, and email address |
|
Social network service |
∘
Name, email
address, ID, telephone number, address, national information, address list
(acquaintance)
|
• Information collected while the users use services
Besides of information directly provided by the users, KeyWe may collect
information in the course that the users use the service provided by KeyWe.
|
Lists |
Items to be collected(examples) |
|
Equipment information |
∘ Equipment identifier, operation system, hardware version, equipment set-up, type and set-up of browser, use information of website or application and telephone number |
|
Log information |
∘ IP address, log data, use time, search word input by users, internet protocol address, cookie and web beacon |
|
Location information |
∘ Information of device location including specific geographical location detected through GPS , Bluetooth or Wifi (limited to the region permissible under the laws) |
|
Other information |
∘ Preference, advertisement environment, visited pages regarding service use of users |
•
Collection through Location, Device and Application Operation
- KeyWe uses collected information from KeyWe's products to allow users (and
KeyWe) to operate and monitor user's devices and KeyWe Services. If users
enable Smart Features, the KeyWe application will request user's consent in
order to track user's location and to determine when user's application nears
KeyWe devices that users have permission to access.
-
Information about the guests that users
invite in order to allow guests to have access to user's smart lock and
Services. Guests should be aware that the person(s) providing access to a
specific device may be able to see information about the guest's usage of the device
or KeyWe's Service and may revoke or limit access rights in their discretion
without notice. In connection with the guest invitation process, KeyWe may ask
for access to user's contact list. KeyWe will only store information for
contacts that users add as guests.
- Information associated with use of KeyWe smart lock products such as device
status, logs of those who lock/unlock the devices, the guests that users
invite, and those people who may invite users as a guest, to use the device and
application. KeyWe may store this data along with user's personal data and
other information about user's use of KeyWe Service.
•
Guest Access
-
As part of KeyWe Services, users may give
others ('guests') permission levels to access user's KeyWe lock – e.g. to
unlock and lock user's door (and possibly even to pass this access along to
others). Needless to say, users must be careful of the guests that users invite
and the access that users give them. Users are responsible for all uses of
their account, so they must be careful to secure this information and only give
access to people users trust. Additionally,
certain portions of users personal data, device and Service information may be
shared with the people that users invite, such as user's name and lock
location, and the status of the lock (e.g. locked or unlocked). KeyWe may also
collect personal (as required to use the Service as set forth in this Privacy
Policy) about the guests that users invite in order to allow them to have
access to user's KeyWe device and Service. All such information (including
user's Service usage information) is subject to and will be used and disclosed
as set forth in, this Privacy Policy. All guests must be informed and expressly
consent to such use and disclosure as a user of the Service. If you are a guest
and do not consent to such use, you should stop using the Service. Guests
should be aware that the person(s) providing access to a specific device may be
able to see information about the guest's usage of the device and KeyWe Service
and may revoke or limit access rights in their discretion without notice.
Guests should also be aware that their personal data and usage information may
be shared with third-party service providers as set forth in this Privacy
Policy, including those service providers selected by the person(s) that
invited you to use their lock (see 'Your Third Party Service Providers' below).
(2) Method of collection
KeyWe collects the information of users in a way of the followings:
• webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information
• provided by partner companies
2. Use of collected information
KeyWe uses the collected information of users for the following purposes:
• Member management and identification
• To detect and deter unauthorized or fraudulent use of or abuse of the Service
• Performance of contract, service fee payment and service fee settlement regarding provision of services demanded by the users
• Improvement of existing services and development of new
services
• Making notice of function of company sites or applications or matters on
policy change
• To help you connect with other users you already know and, with your permission, allow other users to connect with you
• To make statistics on member's service usage, to provide services and place advertisements based on statistical characteristics
• To provide information on promotional events as well as opportunity to participate • To comply with applicable laws or legal obligation
• Use of information with prior consent of the users (for example, utilization of marketing advertisement)
KeyWe agrees that it will obtain a consent from the users, if KeyWe desires to use the information other than those expressly stated in this Policy.
[Option to select 'Lawful Processing of Personal Information under GDPR' in Appendix <1> of Personal Privacy Policy]
3. Disclosure of collected information
Except for the following cases,KeyWe will not disclose personal information with a 3rd party:
• whenKeyWe
disclosing
the information with its affiliates, partners and service providers;
- WhenKeyWe's
affiliates,
partners and service providers carry out services such as bill payment,
execution of orders, products delivery and dispute resolution (including
disputes on payment and delivery) for and on behalf of
KeyWe
• when the users consent to disclose in advance;
- when the user selects to be provided by the information
of products and services of certain companies by sharing his or her personal
information with those companies
- when the user selects to allow his or her personal
information to be shared with the sites or platform of other companies such as
social networking sites
- other cases where the user gives prior consent for
sharing his or her personal information
• when disclosure is required by the laws:
- if required to be disclosed by the laws and regulations;
or
- if required to be disclosed by the investigative
agencies for detecting crimes in accordance with the procedure and method as
prescribed in the laws and regulations
4. Cookies, Beacons and Similar Technologies
KeyWe may collect collective and impersonal information through 'cookies' or 'web beacons'.
Cookies are very small text files to be sent to the browser of the users by the server used for operation of the websites of KeyWe and will be stored in hard-disks of the users' computer.
Web beacon is a small quantity of code which exists on the websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of email.
These functions are used for evaluating, improving services and setting-up users' experiences so that much improved services can be provided by KeyWe to the users
The items of cookies to be collected by KeyWe and the purpose of such collection are as follows:
|
Category |
Reasons for using cookies and additional information |
|
strictly necessary cookies |
This cookie is a kind of indispensable cookie for the users to use the functions of website of KeyWe . Unless the users allow this cookie, the services such as shopping cart or electronic bill payment cannot be provided. This cookie does not collect any information which may be used for marketing or memorizing the sites visited by the users (Examples of necessary cookies)
∘
Memorize the information entered in an order form while searching other pages
during web browser session
|
|
performance cookies |
This cookie collects information how the users use the website of KeyWe such as the information of the pages which are visited by the users most. This data helps KeyWe to optimize its website so that the users can search that website more comfortably. This cookie does not collect any information who are the users. Any and all the information collected by this cookie will be processed collectively and the anonymity will be guaranteed. (Examples of performance cookies)
∘
Web
analysis: provide statistical data on the ways of using website
|
|
functionality cookies |
This cookie is used for memorizing the set-ups so that KeyWe provides services and improves visit of users. Any information collected by this cookie do not identify the users individually. (Examples of functionality cookies)
∘
Memorize set-ups applied such as layout, text size, basic set-up and colors |
|
targeting cookies or advertising cookies |
This cookie is connected with the services provided by a 3rd party such as the buttons of 'good' and 'share'. The 3rd party provides these services by recognizing that the users visits the website of KeyWe. (Examples of targeting cookies or advertising cookies)
∘
carry out PR to the users as targets in other websites by connecting through
social networks and these networks use the information of users' visit
|
The users have an option for cookie installation. So, they may either allow all cookies by setting option in web browser, make each cookie checked whenever it is saved, or refuses all cookies to be saved: Provided that, if the user rejects the installation of cookies, it may be difficult for that user to use the parts of services provided by KeyWe.
5. User's right
The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by KeyWe:
• exercise right to access to personal information;
• make corrections or deletion;
• make temporary suspension of treatment of personal information; or
• request the withdrawal of their consent provided before
If, in order to exercise the above rights, you, as an user, use the menu of 'amendment of member information of webpage or contact KeyWe by sending a document or e-mails, or using telephone to KeyWe(or person in charge of management of personal information or a deputy), KeyWe will take measures without delay: Provided that KeyWe may reject
the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
[Option to select 'User's right when applying GDPR' in Appendix <2>of Personal Privacy Policy]
6. Security
KeyWe regard the security of personal information of uses as very important. KeyWe constructs the following security measures to protect the users' personal information from any unauthorized access, release, use or modification
• Encryption of personal information
- Transmit users' personal information by using encrypted
communication zone
- Store important information such as passwords after
encrypting it
• Countermeasures against hacking
- Install a system in the zone the external access to which is
controlled so as to prevent leakage or damage of users' personal information by
hacking or computer virus
• Establish and execute internal management plan
• Install and operate access control system
• Take measures to prevent forging or alteration of access record
7. Protection of personal information of children
In principle, KeyWe does not collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The website, products and services of KeyWe are the ones to be provided to ordinary people, in principle. The website or application of KeyWe has function to do age limit so that children cannot use it and KeyWe does not intentionally collect any personal information from children through that function.
(Additional procedure for collecting personal information from children) However, if KeyWe collects any personal information from children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction for the services for unavoidable reason, KeyWe will go through the additional procedure of the followings for protecting that personal information of children:• verify, to the extent that efforts are reasonably made, whether they are children of the age at which consent from their guardian is required and the consenting person is an authorized one.
• obtain consent from the parents or guardian of children so as to collect personal information of children or directly send the information of products and services of KeyWe
• give the parents or guardian of children a notice of Company's policy of privacy protection for children including the items, purpose and sharing of personal information collected
• grant to legal representatives of children a right to access to personal information of that children/correction or deletion of personal information/temporary suspension of treatment of personal information/ and request for withdrawal of their consent provided before
• limit the amount of personal information exceeding those necessary for participation in online activities
8. Modification of Privacy Protection Policy
KeyWe has the right to amend or modify this Policy from time to time and, in such case, KeyWe will make a public notice of it through bulletin board of its website (or through individual notice such as written document, fax or e-mail) and obtain consent from the users if required by relevant laws.
9. Others
[Option to select 'data transfer to other countries ' in Appendix <3> of Personal Privacy Policy]
[Option to select 'sites and service of 3rd party' in Appendix <4> of Personal Privacy Policy]
[Option to select 'guidelines for residents in California' in Appendix <5> of Personal Privacy Policy]
[Option to select 'guidelines for residents in Korea' in Appendix <6> of Personal Privacy Policy]
10. Contact information of Company
Please use one of the following methods to contact KeyWe should you have any queries in respect to this policy or wish to update your information:
•Company name :
Address :
Tel.:
E-mail:
(Add the following if designated of data protection officer) KeyWe designates the following Data Protection Officer (DPO) in order to protect personal information of customers and deal with complaints from customers.
DPO of KeyWe
Address:
Tel.:
E-mail:
(Add the following if the controller operating outside of the EU designates its deputy in the EU) KeyWe designates a deputy in the EU in order to protect personal information of customers and deal with complaints from customers.
Deputy of KeyWe Adress:
Tel.:
E-mail:
The latest update date:June ______, 2020.
Appendix of Privacy Protection Policy
<1> Lawful processing of personal information under GDPR
Processing personal information by KeyWe shall be lawful only if and to the extent that at least one of the following applies:
• A user has given consent to the processing of his or her personal information.
• Processing is necessary for the performance of a contract to
which a user is party or in order to take steps at the request of a user prior
to entering into a contract:
-
Member management, identification, etc.
-
Performance of a contract in relation to providing the services required
by users, payment and settlement of fees, etc.
• Processing is necessary for compliance with a legal obligation
to which KeyWe is subject
- Compliance with relevant law, regulations, legal proceedings,
requests by the government
• Processing is necessary in order to protect the vital
interests of users, or other natural persons
- Detection of, prevention of, and response to fraud, abuse,
security risks, and technical issues that may harm users or other natural
persons
• Processing is necessary for the performance of a task carried out in the public interest or in the excise of official authority vested in KeyWe
• Processing is necessary for the purposes of the legitimate interests pursued by KeyWe or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child).
<2>User's right when applying GDPR
The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by KeyWe:
• The right to access to personal information;
The users or their legal representatives may access the
information and check the records of the collection, use and sharing of the
information under the applicable law. • The right to rectification;
- The users or their legal representatives may request to
correct inaccurate or incomplete information.
• The right to erasure;
- The users or their legal representatives may request the
deletion of the information after the achievement of their purpose and the
withdrawal of their consent.
• The right to restriction of processing;
- The users or their legal representatives may make temporary
suspension of treatment of personal information in case of the disputes over
the accuracy of information and the legality of information treatment, or if
necessary to retain the information.
• The right to data portability
- The users or their legal representatives may request to
provide or transfer the information. • The right to object
- The users or their legal representatives may suspend the
treatment of personal information if the information is used for the purpose of
direct marketing, reasonable interests, the exercise of official duties and
authority, and research and statistics.
• The right to automated individual decision-making, including
profiling
- The users or their legal representatives may request to cease
the automated treatment of personal information, including profiling, which has
critical impact or cause legal effect on them.
If, in order to exercise the above rightss, you, as an user, use the menu of 'amendment of member information of webpage or contact KeyWe by sending a document or e-mails, or using telephone to KeyWe ( person in charge of management of personal information or a deputy), KeyWe will take measures without delay: Provided that KeyWe may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
<3> Data transfer to other countries
Considering it engages in global businesses, KeyWe may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, KeyWe takes reasonable measures for protecting those personal information.
(If used in the US, additional security measures may be available) In addition, when the personal information obtained from the European Union or Switzerland is used or disclosed, KeyWe may have to comply with the US-EU Privacy Shield and Swiss-US Privacy Shield, take other measures or obtain consent from users so far as those complies with the regulations of EU so as to use a standardized agreement provision approved by executing organizations of EU or securing proper safe measures.
<4> 3rd party's sites and services
The website, product or service of KeyWe may include the links to the ones of a 3rd party and the privacy protection policy of the site of 3rd party may be different. Thus, it is required for the users to check additionally that policy of a 3rd party site linked to the site of KeyWe.
<5> Guide for users residing in California
If the user resides in California, certain rights may be given. KeyWe prepare preventive measures necessary for protecting personal information of members so that KeyWe can comply with online privacy protection laws of California.
In case of leakage of personal information, an user may request KeyWe to check the leakage. In addition, all the users in the website of KeyWe, can modify their information at any time by using the menu for changing information by connecting their personal account.
Moreover, KeyWe does not trace the visitors of its website nor use any signals for 'tracing prevent'. KeyWe will not collect and provide any personal identification information through ad services without consent of users.
<6> Guide for users residing in Korea
KeyWe guides several additional matters to be disclosed as required by the information network laws and personal information protection laws in the Republic of Korea as follows:
(1) Information collected
The items collected by KeyWe are as follows:
• Examples of required information
|
Title of service |
Items to be collected(examples) |
|
Internet membership service |
∘
Name, email address, ID, telephone number, address, national information,
encoded identification information (CI), identification information of
overlapped membership (DI)
|
|
Online payment service |
∘
Name, address, telephone number, and email address |
|
Social network service
|
∘
Name, email address, ID, telephone number, address, national information,
address list (acquaintance)
|
|
In the course of using services, the information as described below may be created and collected:
∘
Information of devices (equipment/device identifier, operation system,
hardware version, equipment set-up and telephone number)
|
|
• Examples of optional items
The user may reject the collection and use of optional items and, even in case of rejection, there is no limit on use of services
|
Purpose of collection |
Items to be collected(examples) |
|
User analysis |
∘ The reason for membership, occupation, marriage status, wedding anniversary, interest category and SNS account information |
|
Provision of customized ad |
∘ Contents and result of marketing activities and event participation |
|
Delivery of urgent notice |
∘ Information provided by the users regarding execution, maintenance, execution, management of other agreements and event participation |
|
Marketing |
∘ Preference, advertisement environment, visited pages regarding service use of users |
• Additional procedure for collection of sensitive information
If collection of sensitive information is indispensable, KeyWe may collect it by going through lawful procedure in accordance with relevant laws and regulations. The sensitive information which may be collected by KeyWe is as follows:
∘
Thoughts and belief
∘
Membership of and withdrawal from labor
union or political party
∘
Political opinions
∘
Information of health and sexual life
∘
Genetic information obtained from the
result of gene test
∘ Information of criminal record including announcement, exemption and suspension of sentences, care and custody, protective custody, treatment and custody, probation, lapse of suspension of sentence and cancellation of suspension of execution.
(2) Commission for collected personal information
For carrying out services, KeyWe commissions external professional companies (subcontractors) to process personal information as follows. This commissioned works for processing personal information is carried out by each subcontractor and service only if necessary, for providing that service.
In commissioning process of personal information, in order to secure safety of personal information , KeyWe supervises and ensure to expressly state in the agreement with subcontractors so that those subcontractors will safely process personal information by strictly complying with directions regarding personal information protection, keeping personal information secret, not disclosing it to a 3rd party and being liable for accidents and returning or destructing personal information upon termination of the commission or process.
|
Name of subcontractors |
Description of commissioned works (services) |
|
Bunch |
Customer service |
(3) Period for retention and use of personal information
In principle, KeyWe destructs personal information of users without delay when: the purpose of its collection and use has been achieved; the legal or management needs are satisfied; or users request: Provided that, if it is required to retain the information by relevant laws and
regulations, KeyWe will retain member information for certain period as designated by relevant laws and regulations. The information to be retained as required by relevant laws and regulations are as follows:
|
∘Record
regarding
contract or withdrawal of subscription: 5 years (The Act on Consumer
Protection in Electronic Commerce )
|
(4) Procedure and method of destruction of personal information
In principle, KeyWe destructs the information immediately after the purposes of its collection and use have been achieved without delay: Provided that, if any information is to be retained as required by relevant laws and regulations, KeyWe retain it for the period as required by those laws and regulations before destruction and, in such event, the personal information which is stored and managed separately will never be used for other purposes. KeyWe destructs: hard copies of personal information by shredding with a pulverizer or incinerating it; and delete personal information stored in the form of electric file by using technological method making that information not restored.
(5) Technical, managerial and physical measures for protection of personal information
In order to prevent the loss, theft, leakage, alteration or damage of personal information of the users, KeyWe takes technical, managerial and physical measures for securing safety as follows:
|
Items |
Examples |
|
Technical measures |
∘
Utilize security servers for transmitting encryption of personal information
∘
Take measures of encryption for
confidential information |
|
Managerial measures |
∘
Appoint a staff responsible for protecting personal information
|
|
Physical measures |
∘
Establish and operate the procedure for access control for the facilities for
storing personal information
|
(6) Staff responsible for managing personal information
The staff of KeyWe responsible for managing personal information is as follows:
• Name of staff responsible for managing personal information:
Dept. :
Tel. :
Contact :
The latest update date: ______, July 2020.
The following contents and materials were referred to in this guideline.