Privacy Policy

Effective Date: January 7, 2020

At SentriLock, we appreciate your use of our lockboxes, websites, mobile applications, and our other products and services (collectively known as the “Products and Services”, or each individually, a “Product” or a “Service”). SentriLock respects your privacy and is committed to protecting your information.

This privacy policy covers all Products and Services used by you that are provided by SentriLock, LLC, a Delaware limited liability company.  This Privacy Policy does not apply to any product, service, information, or practices of other companies.  For purposes of the General Data Protection Regulation (“GDPR”) SentriLock may be a “controller” and/or a “processor” of your Personal Information by virtue of your use of the Products and Services.

SentriLock’s contact information is:

SentriLock, LLC

privacy@sentrilock.com

This privacy policy governs your use of the Products and Services whether via personal computers, mobile devices, or otherwise, and also applies to your use of interactive features, widgets, plug-ins, applications, content, downloads and/or other services that we own and control and make available through the mobile or online version of our Products and Services. We encourage you to read this privacy policy to understand the information we collect and how we use and disclose it. It is important that you read and understand the entire Privacy Policy before using the Products and Services. Your use of any Product or Service constitutes your acceptance of the terms contained in this Privacy Policy.  If you are unwilling to consent to our collection and use of your Personal Information as described in this Policy, and to accept the terms in SentriLock’s End User Agreement, you shall not access or use the Products and Services.

  1. Collection and Use of Personal Information

From time to time we collect, retain and utilize Personal Information about you to make the products and services effective and available to other subscribers to the products and services we provide.  The term “Personal Information” means personally identifiable information that we may obtain about you, including but not limited to your name, age, gender, postal address, email address, phone number, brokerage, company, payment or banking information (including related payment verification information), and other information pertinent to our services. We recognize and respect your privacy concerns about this information. We obtain Personal Information in a variety of ways (for example, when you register for our product and service or when you contact us directly by email, from properties you visit, show interest in, from your other transactions or experiences with us, or from other third parties). Also, when you use the Products and Services, we collect information that might or might not identify you for purposes of measuring the use of the Products and Services and improving its content, providing such information to certain independent third-parties to improve your experience with the products and services offered by such third parties, and as otherwise described below.  You hereby consent to the collection, use, transfer, and disclosure of your Personal Information in accordance with this Privacy Policy and any applicable law, rule, or regulation.

  1. Information We Collect or Store as You Access and Use the Products and Services

In addition to any Personal Information or other information that you choose to submit to us via our Products and Services, we and our third-party service providers may use a variety of technologies that automatically (or passively) store or collect certain information whenever you visit or interact with the Products and Services (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, laptop, tablet or mobile phone (a “Device”) whenever you visit or interact with our Products and Services. Usage Information may be non-identifying or may be associated with you. To the extent that we associate Usage Information with your Personal Information, we will treat it as Personal Information.  We will not ask you for, and you shall not provide to us, any Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, criminal convictions or offenses, or any genetic data, data concerning health or data concerning a natural person’s sex life or sexual orientation.  To the extent required by applicable law, rule, or regulation, we will not collect or process information concerning your biometric data and trade union membership unless you provide it to us, and we will use such information for the purpose of identifying you, providing you access to the System or Services, and improving your experience with the System and Services and the products and services offered by certain third parties with which we share the information.

This Usage Information may include:

  • your IP address or other unique identifier (“Device Identifier”). A Device Identifier is a number that is automatically assigned to your Device used to access the Products and Services, and our computers identify your Device by its Device Identifier;
  • your Device functionality (including browser, operating system, hardware, and mobile network information);
  • the URL that referred you to our Products and Services;
  • the areas within our Products and Services that you visit and your activities there, including remembering you and your preferences; your Device location;
  • your Device characteristics; and
  • certain other Device data, including the time of day, among other information.
  1. Collection Methods

3.1 We may use various developed methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies include, without limitation, the following (and subsequent technology and methods later developed):

  • 1.1 Cookies.A cookie is a data file placed on a Device when it is used to visit the Products and Services. Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please be aware that if you disable or remove cookies on your Device, some parts of our Products and Services may not function properly, and that when you revisit our Products and Services your ability to limit cookies is subject to your browser settings and limitations.
  • 1.2 Web Beacons.Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included in our Products and Services pages and messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Products and Services, to monitor how users navigate the Products and Services, to count how many e-mails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
  • 1.3 Embedded Scripts.An embedded script is programming code that is designed to collect information about your interactions with the Products and Services, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site, and is deactivated or deleted thereafter.
  • 1.4 ETag, or entity tag.An ETag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner, ETags are a form of Device Identifier. ETag tracking may generate unique tracking values even where the consumer blocks cookies. We may use Tracking Technologies for a variety of purposes to determine system usage patterns, technical support, analytics and system security.
  • 1.5 Strictly Necessary.We may use cookies or other Tracking Technologies that we consider necessary to allow you to use and access our Products and Services, including cookies required to prevent fraudulent activity, improve security, or allow you to make use of shopping cart functionality.
  • 1.6 Performance Related.We may use cookies or other Tracking Technologies that are useful in order to assess the performance of the Products and Services, including as part of our analytic practices or otherwise to improve the content, products or services offered through the Products and Services.
  • .1.7 Functionality Related.We may use cookies or other Tracking Technologies that are required to offer you enhanced functionality when accessing the Products and Services, including identifying you when you sign in to our Products and Services or keeping track of our specified preferences, including in terms of the presentation of content on our Products and Services.
  • 1.8 Targeting Related.We may use Tracking Technologies to deliver content relevant to your interests on our Products and Services and third party Products and Services based on how you interact with our content. This includes using Tracking Technologies to understand the usefulness to you of the content that have been delivered to you.
  • 3.1.9 Location Data. Certain SentriLock products require the use of location data to operate properly.  If you enable location Products and Services on your mobile device, SentriLock may collect the location of your device, which we use to provide you with location-based information. During use of SentriLock products, your location data will be stored and monitoring may continue for a period of time to ascertain your proximity to one of SentriLock’s products.
  • 3.1.10 Usage logs. We collect information about your use of our Products and Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Products and Services. We also collect information about the computer or mobile device you use to access our Products and Services, such as the hardware model, operating system and version, unique device identifiers, mobile network information, and browsing behavior.
  • 3.1.11 Calls and text messages. Calls between you and SentriLock may be recorded or monitored for quality assurance and customer service purposes. You will be notified at the beginning of a call if it may be recorded or monitored. Your caller ID information will be stored in SentriLock’s system to provide faster customer service and to send you text messages that you opt into.
  • 3.1.12 Social networks. If you use the social networking connection functions offered through the Products and Services, we may access your social network profile information that you have made available to be shared and to use it in accordance with this privacy policy. Please refer to the instructions governing your social network account to manage the information that is shared through your account.

 

3.2 There may be other Tracking Technologies now and later devised and used by us in connection with the Products and Services. Further, third parties may use Tracking Technologies with our Products and Services. We may not control those Tracking Technologies and we are not responsible for them. However, you consent to potentially encountering third-party Tracking Technologies in connection with use of our Products and Services and accept that our statements under this Privacy Policy do not apply to the Tracking Technologies or practices of such third parties. If your web browser sends SentriLock a “do not track” signal or uses another mechanism that provides you with the ability to exercise choice regarding collection of Personal Information, SentriLock will acknowledge the request and make all attempts to cease these tracking uses without impeding necessary functionality of the basic system use.

  1. How SentriLock Uses Your Information; Withdraw

4.1 We may use your Personal Information for the performance of a contract between us, where you have consented to such use, for any purpose identified in this Privacy Policy, or where we have a legitimate interest.  We may share or transfer your Personal Information as directed to do so by you, through implicit transactions such as payments or through more generalized opt-in arrangements. We may share Personal Information with existing or future third-party partners, such as manufacturers of the products with which SentriLock’s services are utilized, and for product support or marketing reasons.  To the extent permitted by applicable law, rule, or regulation, we may also share your Personal Information and other information (e.g. SentriLock Lockbox access data (including access data, time, agent name, agent company, agent broker, and address of access)) with independent third-parties in connection with your use of each such third party’s applications or services.  Your use of our Products and Services, and your use of a tool that allows for your information or Personal Information to be transferred to third parties, constitutes your consent for us to share your Personal Information and other information with such third party (and your “Authorizing Client”, as such term is defined below) to the extent permitted by applicable law, rule, or regulation. We do not control, and (to the maximum extent permitted by applicable law, rule, or regulation) are not responsible for, the privacy and data security practices of these third parties.  For clarity, notwithstanding anything contained herein to the contrary, SentriLock may share information concerning your use of and access and data inputs to the SentriLock application and System, including Hardware access logs, user names, and other identifying and personal information (collectively, the “Shared Data”), with non-affiliated third parties that provide products or services to you or the Authorizing Client (“Vendors”) for the purpose of enhancing the Vendors’ products and services and your use thereof.  SentriLock may generate and send to the Vendors access codes which will allow third parties to operate and open the Hardware in connection with the Vendor’s products or services.  YOU HEREBY ACKNOWLEDGE THAT SENTRILOCK SHALL BE ENTITLED TO SHARE THE SHARED DATA WITH THIRD PARTIES, AND THAT, TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, SENTRILOCK SHALL NOT BE LIABLE TO YOU FOR ANY SUCH SHARING OR ANY USE OR MISUSE OF SUCH DATA OR ACCESS CODES BY SUCH THIRD PARTIES.  Where our ground for collecting and processing your Personal Information is based upon your consent, you have the right to withdraw your consent at any time, by  sending us an email at privacy@sentrilock.com notifying us that you’d like to withdraw your consent.  You can also “unsubscribe” from our emails or other marketing messages by following the prompts at the bottom of each email or message we send your, or if none exist, by emailing privacy@sentrilock.com with such request.  We may collect payment transaction information from you, including credit card information and information related to your chosen payment method (e.g. credit card number, CCV number, credit card expiration date, bank information, account and routing information, billing address, the time and date of the transaction, and the amount of the transaction).  Such information will be used for the purpose of verifying, processing, and facilitating payments for SentriLock’s Products and Services, and the amount and existence of such payments may be shared with third party merchants and the Authorizing Client for such purposes.  In some cases, this information may be necessary to establish and maintain your user account, verify your identity, enable communications with you and your Authorizing Client about the existence and amount of your payments, etc.  For purposes of this Privacy Policy, “Authorizing Client” means the SentriLock customer that has entered into a System Agreement with SentriLock and provided you with access to the System and Services.  We will treat such payment information as Personal Information hereunder.

4.2 We may also transfer Personal Information or Usage Information to third-party vendors who act for us for further processing in accordance with the purposes for which the information was originally collected, or for purposes to which you have subsequently consented. For example, sometimes a third-party vendor may have access to your Personal Information or Usage Information to support our information technology or help obtain, compile and manage the information for us or process payments.

4.3 We may use third-party vendors to perform certain services on behalf of us or the Products and Services, such as hosting the Products and Services, designing and/or operating the Products and Services features, tracking the Products and Services activities and analytics, and enabling us to send you special offers about our products or services and enabling us to perform other administrative services such as processing your payments to us. We may provide these vendors with access to user information, including Device Identifiers and Personal Information, to carry out the services they are performing for you or for us. In such instances, if required by applicable law, we will provide the minimum amount of Personal Information necessary for these third parties to carry out their contractual services.

4.4 We also may use your Personal Information or Usage Information that is subject to this Privacy Policy:

4.4.1 to provide you with information or services or process transactions that you have requested or agreed to receive, such as password resets and granting permissions to others;

4.4.2 to process your registration with the Products and Services, including verifying your information is active and valid;

4.4.3 to improve the Products and Services or our services, to customize your experience on the Products and Services, or to serve you specific content that is relevant to you;

4.4.4 to contact you with regard to your use of the Products and Services and, in our discretion, changes to the Products and Services and/or Products and Services policies;

4.4.5 for internal business purposes and for research purposes; and

4.4.6 for purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy.

4.5 We may access, use, preserve, transfer and disclose your information (including Device Identifiers and Personal Information), including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests, or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the Products and Services Terms of Use or other policies applicable to the Products and Services, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Products and Services or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.

4.6 We may also compile and provide to third parties aggregated information, i.e., compiled information that does not in itself identify you, for research, product development, analytics products and benchmarking purposes.

4.7 SentriLock also works to comply with all local or government regulations relating to the use and disclosure of personally identifiable information based on the country of origin of the information or the locale of the person for which the information is relevant.

  1. How You Can Review Your Personal Information

When you log into SentriLock’s services on our web site, you can view all your Personal Information retained by SentriLock.

  1. How You Limit the Disclosure and Use of Your Personal Information

6.1 There are no controls presently to change sharing of your Personal Information.

6.2 To stop SentriLock’s use of your Personal Information you may write to us and indicate your desire for us to do so along with providing proof of your identity or power of attorney to do so.  Upon such receipt of a valid request, SentriLock will remove your personally identifiable information to the extent possible from its systems; provided, that you acknowledge and agree that SentriLock has no control over or ability to remove your information from the systems of third parties.  This action will impair or completely disable your access to SentriLock’s products and services.  Also, if you have entered into any contact or lease arrangement with SentriLock, removal of your Personal Information and your subsequent inability to use SentriLock’s products and services does not relieve you of your financial obligations under those agreements.

6.3 To Opt Out of receiving any marketing materials you can email us on the following address:  privacy@sentrilock.com.

  1. Our Liability of Third Party Use of Your Personal Information

In the future, should SentriLock offer services that would share your Personal Information to third parties, such sharing would be governed by certain contractual provisions with that third party.  To the maximum extent permitted by applicable law, rule, or regulation, our liability would extend only to discontinuance of sharing such information with the third party upon violation of any data sharing agreements between SentriLock and the third party.

  1. Retention of Data

8.1 SentriLock’s normal data retention period for personally identifiable information is the active use of SentriLock’s products or 36 months once activity ceases. Certain types of information in certain SentriLock products will be retained for greater periods of time where local regulations or laws require it.

8.2 We will retain your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

8.3 SentriLock may maintain anonymized and aggregated information generated from your use of SentriLock’s products and services indefinitely.

  1. Security of Information – right of access

9.1 SentriLock takes commercially reasonable steps to protect the information you share with us from unauthorized use, access, and disclosure, both during transmission and at rest. However, no transmission of information via the Internet nor electronic storage solution can be entirely secure, so please be aware that we cannot guarantee absolute security.

9.2 We strive to maintain the reliability, accuracy, completeness and currency of your Personal Information in our databases and to protect the privacy and security of our databases and the information we collect. Any Personal Information that you provide to us will be stored on our or our third-party provider’s computer network servers located in Columbus, Ohio and in the Google Cloud Platform. We maintain commercially reasonable physical, electronic and procedural safeguards to protect the confidentiality of your Personal Information. The security measures in place for the Products and Services and its servers aim to protect the loss, misuse or alteration of the information you provide to us. If you have any questions or concerns regarding the security of your information, please email us at privacy@sentrilock.com.

9.3 After logging into your account profile on the relevant SentriLock Service, if and to the extent required by applicable law, you have the right to:

(i) access your Personal Information;

(ii) update your Personal Information, or rectify inaccuracies of your Personal Information;

(iii) delete your Personal Information;

(iv) restrict or object to processing of your Personal Information; and

(v) request that we transfer the Personal Information that we have collected to another organization or directly to you, under certain conditions.

If your Personal Information is subject to the GDPR, you have the right under the GDPR to request and obtain from us the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you; where your personal data is not collected from you, any available information as to its source; and to request a copy of your Personal Information undergoing processing.  To do so, please send an email to privacy@sentrilock.com asking for such information.

If permitted by applicable law, rule, or regulation, we may maintain a copy of the original version of your information in our records.

  1. GDPR; Privacy Shield

10.1 Where applicable, SentriLock complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union to the United States.  SentriLock has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

 

10.2 In compliance with the Privacy Shield Principles, SentriLock commits to resolve complaints about our collection or use of your Personal Information.  EU individuals with inquiries or complaints regarding our Privacy Policy should contact Helen Deakin at privacy@sentrilock.com.

 

10.3 SentriLock has further committed to refer unresolved Privacy Shield complaints to PrivacyTrust, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.privacytrust.com/drs/sentrilock for more information or to file a complaint.  The services of PrivacyTrust are provided at no cost to you.

10.4 Finally, as a last resort and in limited situations, EU individuals may seek redress from the Privacy Shield Panel, a binding arbitration mechanism.

10.5 SentriLock commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.

  1. Links to Other Web Products and Services

You should know that while visiting the Products and Services, you can be directed, through links, to other web Products and Services that are beyond our control. SentriLock is not responsible for the privacy practices and policies of such linked web Products and Services.

  1. Maintenance of Accurate Information

We have established procedures to correct inaccurate information in a timely manner. If you have any reason to believe that Personal Information about you that is stored and maintained by us is incorrect, please contact us by email at: privacy@sentrilock.com.

  1. Business Transitions

In the event that SentriLock goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information or Usage Information might be among the assets transferred. You will not be notified in advance of any such change in ownership or control of your Personal Information.

  1. Changes in Privacy Policy

14.1 We reserve the right to change this Policy at any time, so you should review it each time you access the Products and Services. If we change this Policy, we will post on SentriLock’s web site the revised Policy on the Products and Services.

14.2 The Privacy Policy document on SentriLock’s web site is SentriLock’s official disclosure in this matter and no employee or agent of SentriLock may modify SentriLock’s express representations on this matter.

  1. Children’s Privacy

The Products and Services are a general audience website and we do not knowingly collect any Personal Information from children younger than the age of thirteen (13) as required by U.S. law. We will delete any Personal Information collected that we later determine to be from a user younger than the age of thirteen (13). If you are a parent or guardian of a child under the age of thirteen (13) and believe he or she has disclosed Personal Information to us, please contact us at privacy@sentrilock.com.

  1. Transfer of Personal Information to the United States

The Products and Services are developed in the United States and intended for users located worldwide. If you are located outside of the United States, please be aware that information we collect, including Personal Information, may be transferred to, and processed, stored and used in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts or law enforcement in the United States according to laws of the United States. By using the Site or providing us with any information, you consent to the transfer to, and processing, usage, sharing and storage of your information, including Personal Information, in the United States as set forth in this Privacy Policy.

In cases of onward transfer to third parties of Personal Data received pursuant to the EU-U.S. Privacy Shield, SentriLock is potentially liable.

  1. Government and Private Party Information Requests

SentriLock occasionally receives various forms of legal process from government agencies requesting information about SentriLock users and their use of SentriLock products. SentriLock will only comply with such requests if presented with a court order from a court of competent jurisdiction to produce such information and SentriLock’s legal representatives determine such requests are legal and enforceable.

  1. Enforcement

18.1 SentriLock conducts periodic self-assessments to verify that the attestations and assertions it makes about its privacy practices are true and that such privacy practices have been implemented as presented. SentriLock will take commercially reasonable steps to remedy any problems arising out of failure to comply with the Privacy Shield Principles.

18.2 The Federal Trade Commission has jurisdiction to investigate claims against SentriLock regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy in the United States.

18.3 EU citizens may report privacy complaints directly to their local Data Protection Authorities. You may also contact us to be directed to the relevant contacts.

  1. Notice to California Residents.If you are a California resident, under California Civil Code Section 1789.3, you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 N. Market Blvd., Suite S-202, Sacramento, California 95834, or by telephone at (800) 952-5210 in order to resolve a complaint regarding the Service or to receive further information regarding use of the Service.

 

  1. Other Action You May Take to Address Privacy Issues

Please refer to our End User License Agreement for consumer information regarding use of our product and system.  If you have any questions or suggestions regarding this Policy, please contact us at: Privacy Officer, SentriLock, 7701 Service Center Drive, West Chester, OH 45069, or by e-mail: privacy@sentrilock.com.

  1. Governing Law

You agree that to the maximum extent permitted by applicable law, rule, or regulation: (i) any dispute over privacy, the use, processing, controlling, or disclosure of your information (including Personal Information), or the terms contained in this Privacy Policy will be governed by the law of the State of Ohio, and (ii) all such claims, disputes, or controversies will be governed by the limitations of liability contained in our Terms of Use, which are incorporated herein by reference.