iLOQ S50
PRIVACY POLICY 2024
1. Introduction
This iLOQ S50 privacy policy (“Policy”) describes how data of the
users is collected, used and disclosed when the users use iLOQ Oy’s (“iLOQ”,
“we”, “our”, “us”) iLOQ S50 mobile application (“App”).
The App is offered and intended for the use of an authorized user (“User”,
“you”, “your”) as a mobile key for opening locks and accessing certain premises
or equipment managed by an enterprise customer of iLOQ locking services (“Enterprise”).
The App will provide an access to designated properties managed by the
Enterprise upon and subject to the Enterprise having registered the User and
the respective access rights in the iLOQ locking service (“iLOQ Service”).
This Policy together with the iLOQ S50 Mobile Application
End User License Agreement (EULA) governs the use of the
App by you. If you do not agree to the terms of this Policy, do not use the App
and delete the App from your device.
2. Role of iLOQ
The Enterprise is the data controller in relation to any of your personal
data processed and collected in relation to the iLOQ Service and the App. The
Enterprise is responsible for obtaining your consent or having other legal
basis for processing and using your personal data in relation to the iLOQ
Service or the App, as well as for all other obligations under the applicable
laws attributable to the controller of personal data. We are not responsible
for the personal data the Enterprise collects and processes or how they process
such personal data. The Enterprise may have their own privacy policies
governing their processing of personal data, which you should review.
iLOQ acts as a data processor for the Enterprise. We only process your
personal data in order to provide the iLOQ Services to the Enterprise under and
in accordance with the respective service agreement. In order for you to be
able to use the App, we may process information on you such as your name and
other credentials. Still, such processing is done on behalf of and based on the
information provided by the Enterprise for the iLOQ Services.
You acknowledge and are aware, that your use of the App has been requested
by the Enterprise, wherefore the Enterprise may receive and use your personal
data in relation to the App or iLOQ Services either directly from you or from
our systems.
3. Data Collected
We will, inter alia, collect the following personal data on you
through the App:
1. Log data (e.g. what lock has been attempted to be opened by the App, when
it has happened and what was the outcome)
2. Technical data related to the opening functionalities, performance and
other general functions of the lock
3. Your IP address in the mobile device using the App
4. Location data of your mobile device using the App if you have not
opted out from the collection of such data
5. Other equivalent information related to your use of the App or iLOQ
Services via the App
In addition, the Enterprise you belong to may upload and process other
personal data on you (such as name and contact details) in the iLOQ Service the
Enterprise uses to enable you to use the App. However, such processing and
types of data collected is at the Enterprises discretion and is separate from
the data collected via the App.
Simply downloading the App from the app store used by your device does not
cause any of your personal data to be collected and stored to our systems. Your
personal data will only be collected (in accordance with what is stated in this
Policy) once your device where the App was installed is registered as a mobile
key. However, please note that app stores do collect your personal data when
you download apps from them. Such data collection is governed by the privacy
policies and use terms of the app stores, and you should refer to them when it
comes to the app stores’ collection of your personal data.
4. Purpose of data
processing
Primarily we will process your personal data to provide you the App and
allow you to use the iLOQ Services through the App, fulfill your other requests
related to the App or iLOQ Services or as otherwise may be necessary for the
performance of the App or iLOQ Services. We may also process and use your
personal data to ensure the functionality and security of the App or iLOQ
Services, to provide the Enterprises necessary information for them to identify
you, and to prevent and detect fraud and other misuses.
We may process and use your personal data to communicate with you or
the Enterprise, for example, to provide information relating to the App or iLOQ
Services you are using or to contact you or the Enterprise for
customer satisfaction queries.
We may process and use your personal data to develop the App, iLOQ Services
or other products and services we provide. However, we mostly use anonymized,
aggregate and statistical information in the development of our products and
services, and not data directly identifiable to you.
5. Data transfer
We may disclose and transfer your personal data to our affiliates, as well
as to third parties who process personal data on our behalf for the provision
of the App or the iLOQ Services, such as technical service providers and our
subcontractors.
We may also disclose or transfer personal data if we decide to sell, buy or
otherwise reorganize our business, or where such disclosures are necessary to
defend iLOQ’s legitimate interests e.g. in legal proceedings or to
verify or enforce compliance with applicable laws, regulations
and our policies.
We store and process the personal data mainly within the EU and European
Economic Area (“EEA”). However, some of the personal data may be transferred
and processed also outside the EEA, including in situations where our server
facilities are located outside the EEA.
All disclosures and transfers of personal data are performed in accordance
with the applicable data protection laws. We will ensure that sufficient
security measures are applied where personal data is disclosed or transferred
(e.g. through data transfer agreements).
6. App Security
iLOQ has implemented necessary measures to ensure that all personal data
collected and processed through the App are kept confidential and
secured. We always implement appropriate technical and organizational security
measures to prevent and minimize risks related to processing personal data.
These security measures include, where appropriate, use of firewalls, access
rights management systems (both manually and electronically), personnel
training, secure server facilities and encryption.
7. Your Rights
You have certain rights under the applicable data protection laws, such as
the right to access, right to rectification and right to erasure of your
personal data. In addition, you can request to restrict or to object processing
your personal data as well as you have right to data portability. You can also withdraw a given consent at any
time. If you wish to exercise such rights, you should primarily
contact the Enterprise who is the data controller of your personal data. You are
always entitled to contact the relevant data protection authority if you need
to lodge a complaint.
8. Contact Details
For the purpose of this Policy and as stated above, the Enterprise is the
data controller of your personal data and you should primarily contact the
Enterprise if you have questions on the processing of your personal data.
However, if you have questions on how we process your personal data on
behalf of the Enterprise, you may contact us at the contact details available
in the App or the iLOQ website at www.iloq.com. iLOQ Oy is located in Oulu, Finland.
9. Changes to the Policy
We may amend this Policy from time to time. We will
use reasonable efforts to notify our Users before such change through the App.
By continuing to use the App or iLOQ Services after such notification, you
expressly acknowledge and agree to the changes.