Product Privacy Notice

Marcon International, Inc. doing business as KEYper Systems (“We”, “Us”, or “Our”) are committed to protecting and respecting your privacy. The practices of our processing of your personal data when using this KEYper service and/or submitting feedback to us are described herein. This Privacy Notice sets out the basis on which we will process the personal data we collect from you, or that you provide to us.

We act as a Service Provider and/or Data Processor which may receive and process information on behalf of our business customer which is the Data Controller for their own business purposes. The business customer should have its own separate Privacy Notice, which you should read to understand their views and practices. Data submitted through, or received from, the service is owned and controlled by the business customer.

In some limited instances we may be the entity responsible for the processing and act as Data Controller. We only collect the minimal information (as set out below) necessary for our legitimate interests:

Ensure reliability and quality of the service, correct faults if needed; and
Identify aspects of the service which could be improved
Protect against, identify, and prevent fraud and other unlawful activity

Where practical, we anonymize or statistically aggregate the information we collect. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

The Data Controller for the data described in this Privacy Notice is Marcon International LLC t/a KEYper Systems 5679 Harrisburg Industrial Park Dr, Harrisburg, NC 28075, USA.

Personal Information we collect from you

When using the KEYper service, we will collect and process the following data about you:

When you are logged in, your unique user identifier, which is linked to your portal login.
Your browser “user-agent”, which may include information on the web browser you are using and your operating system.
Features you interact with while using the service
Errors or exceptions that occur during your session.

With your consent we may also collect:

Analytics data, relying on cookie technologies regarding usage of our services
Crash data that contains a short log of events that occurred in the run up to a crash

For clarity, we do not collect data you submit to the service, or receive from it, as part of our monitoring activities. Only the act of submitting or receiving is recorded. For example, we may record that you entered information in a particular form field, but not the information itself, or, we may record that you ran a particular report, but not the resulting details of the report.

When you submit feedback, we will collect and process the following data about you:

The information you submit in the feedback form or via email.
The URL of the page you were on when you submitted the feedback.
The web browser you used to submit the feedback.
The user account you submitted the feedback from.

In more detail, we have collected the following categories of personal information from consumers within the last twelve (12) months where a ‘YES’ is indicated in the relevant category. Note the business customer could be processing additional categories for which we are not the responsible organization.

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e))	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	NO
C. Protected classification characteristics under California or federal law	Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	NO
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	NO
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data	Physical location or movements.	NO
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information	Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C. F. R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	NO

Sharing Personal Information

ASSA ABLOY Global Solutions takes your privacy seriously and does not monetize your personal information. Certain states such as California and Nevada define the “sale” of data broadly, including the sharing of data with third parties. Under CCPA using cookie related technologies to collect usage analytics from our end users may be defined as a “sale”. The following section describe the “sharing, disclosing, selling of personal information.

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers

Category F: Internet or other similar network activity

Uses made of the information

We use information held about you in the following ways:

Information we collect about you. We will use this information:
- to administer the service and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
- to improve the service to ensure that content is presented in the most effective manner for you and for your computer.
- as part of our efforts to keep the service safe and
Feedback you give to us. We will use this information:
- to improve the goods or
- to investigate and correct
- to provide you with information regarding relevant improvements (for example, we may notify you if a change you suggested is made).

We hold this data under “legitimate interests”.

Retention of your information

Information we collect about you. We keep this information for a maximum of 90 days, with exception of analytics that we keep for 1 year.
Feedback you give to us. We will keep this information for a maximum of 1

Disclosure of your information

We may transfer your personal data for the purposes set out above, to other companies within the ASSA ABLOY group.
To third party business partners who provide services connected to the purposes defined above.
Analytics providers who supply us with services for collecting and analyzing feedback and usage information.
Our customers, channel partners or their agents for which you have engaged in a business contract.

We will disclose your personal information to third parties:

In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or
If we are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of us, our customers, or others.

Some recipients may be in countries outside the EU/European Economic Area (EEA). When transferring personal data to countries outside the EU/EEA we use standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your personal data. These standard contractual clauses, as well as information on countries approved by the European Commission can be found here.

With regards to the United States, certain states such as California and Nevada define the “sale” of data broadly, including the sharing of data with third parties. Under CCPA using cookie related technologies to collect usage analytics from end users may be defined as a “sale”. In the preceding twelve (12) months, we have not sold any personal information.

The following section describe the “sharing, disclosing, selling of personal information. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A: Identifiers
Category F: Internet or other similar network activity

We take measures to protect all personal data transferred to a third party, or to other countries, in accordance with applicable data protection laws and as stated above which includes a data processing agreement where required.

Where we store your personal data

We take your safety and security very seriously and we are committed to protecting your personal information. All information you provide to us is stored on secure servers.

Where we have given you (or where you have chosen) a password that enables you to access certain parts of our service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

Your rights

Data protection legislation gives you the right to access, rectify or erase information held about you. Your right of access can be exercised in accordance with the data protection legislation. You can exercise these rights at any time by emailing us at support@keypersystems.com.

We do not discriminate when exercising your privacy rights by denying use of our services or provide a different level or quality of Services. We will provide you with a copy of any personal data undergoing processing free of charge. Where processing of your personal data is based on consent, you can withdraw consent at any time.

You have the right:

to ask us not to process your personal data where it is processed based on legitimate interests if there are no compelling reasons for that

to ask for the information we hold about you to be rectified if it is inaccurate or
to ask for data to be erased provided that the personal data is no longer necessary for the purposes for which it was collected, you withdraw consent (if the legal basis for processing is consent), you exercise your right to object, set out below, and there is no overriding legitimate ground for processing, the data is unlawfully processed or the data needs to be erased to comply with a legal obligation.
to ask for the processing of that information to be restricted if the accuracy of that data is contested, the processing is unlawful, the personal data is no longer necessary for the purposes for which it was collected, or you exercise your right to object (pending verification of whether there are legitimate grounds for processing); and
to ask for data portability if the processing is carried out by automated means and the legal basis for processing is consent or contract.

Complaints

If you have a complaint regarding our processing of your personal information you are entitled to report this to the applicable Supervisory Authority or Attorney General in your Member State.

Links

This portal may, from time to time, contain links to and from external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Changes to our Privacy Notice

Any changes we make to our Privacy Notice in the future will be posted on this page. Please check back here to see any updates or changes to our Privacy Notice.

Contact

If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights, you may contact us via email

at support@keypersystems.com.