Master Lock Company LLC Privacy Policy

We collect information directly from you when you provide it to us.

If you register an account, create a profile, purchase Services, register products, or otherwise engage with us, you may provide personal information such as name, home address, email address, phone number, payment information (credit card information, bank account information, PIN), username, date of birth, and other similar identifiers. We also may collect information relating to the business you represent and demographic information such as domain information, zip codes, trade group association, and areas of interest. We may collect any other information you choose to provide.

We may receive the aforementioned personal information from third-party sources such as payment processors, product registration services, other service providers, and social media sites with which you interact to obtain or inquire about Services.

We also collect personal information about you when you use or interact with the Services:

• Access and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Sites and Devices, including device information, access times, pages viewed, links clicked, referral channel, items added to shopping cart, and the page you visited before navigating to our Services.
• Precise Geolocation: If you use certain of our connected Devices, we may collect your geolocation data, including information that permits us to determine your location, such as if you provide location information or enable your mobile device to send us location information when using the Services. You may stop the collection of precise location information at any time, but please note that the functionality or availability of the Services may be affected should you choose to do so (see the Your Privacy Rights and Choices section below for details).
• Transactional Information: When you make, exchange, or return a purchase, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction.
• Audio Recordings, Photos, and Chat Content: If you contact customer service through our chat feature or by phone, we may monitor and retain those conversations, including for training purposes.
• Usage Information Collected By Devices: If you use our Devices, we may collect telemetry data associated with use of the Device. We may collect GPS location data to pair your Device with the associated mobile app or other Services. When you have a Device connected to our Services, we will collect various Device event data, such as information required to provide the Services to you, when the Device is used, whether the Device is turned on or off, whether certain features on the mobile app or Device are used and how, and aggregate Device activity information.
• Your Content: With your permission, we may collect information and content stored on your mobile device, such as your contact list for use with our Services.
• Information Collected by Cookies and Similar Technologies: We use cookies, pixels, web beacons, device identifiers, and other similar technologies to collect information about your interaction with the Services. These technologies help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. For more information about the cookies and other tracking technologies we use, and the choices available to you, see the Your Privacy Rights and Choices section below.

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address or infer that you are looking to purchase certain products based on your browsing behavior and past purchases.

We process your personal information for various purposes, including to:

• Provide, maintain, and improve our products, Devices, and services;
• Develop new products and services;
• Process transactions and send you related information, including confirmations, receipts, invoices, customer experience surveys, product information and recall notices;
• Better understand your interests in order to personalize and improve your experience with our Services;
• Send you technical notices, security alerts, and support and administrative messages;
• Respond to your comments and questions and provide customer service;
• Provide support and services to you, including related to our limited and lifetime warranties (as applicable);
• Communicate with you about products, services, and events offered by us and our affiliates and provide news and information that we think will interest you;
• Monitor and analyze trends, usage, and activities in connection with our Services;
• Personalize the advertisements you see on third-party platforms and websites (for more information, see the Targeted Advertising and Analytics section below);
• Create customer profiles to personalize and enhance your experience across our affiliated brands;
• Facilitate trade programs, rebates, discounts, contests, sweepstakes, and promotions and process and deliver entries and rewards;
• Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect our rights and property and those of others;
• Debug to identify and repair errors in our Services;
• Comply with our legal and financial obligations; and
• Carry out any other purpose described to you at the time the information was collected.

We engage others to provide analytics services, serve advertisements, and perform related marketing and analytics services across the web and in mobile applications. These entities may use cookies, pixels, web beacons, SDKs, device identifiers, and other technologies to collect information about your use of our Services and other websites and mobile apps, including your IP address, web browser and mobile network information, device fingerprint, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information is used to deliver advertising targeted to your interests on other companies’ sites or mobile apps and to analyze and track data, determine the popularity of certain content, and better understand your activity. In addition, we may share identifiers, like email addresses and phone numbers, with some of our advertising partners. These advertising partners translate that information into a unique identifier that can then be used to show ads that are more relevant to you across the web and in mobile apps. Some of the activities described in this section may constitute “targeted advertising,” “sharing,” or “selling” under certain laws. To learn more about the choices available to you with respect to these practices, see the Your Privacy Rights and Choices section below.

You can also learn more about interest-based ads or opt out of having your web browsing information used for behavioral advertising purposes by companies that participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices, or, if you reside in the European Union, by visiting www.youronlinechoices.eu. Your device may also include a feature that allows you to opt out of having certain information collected through mobile apps used for behavioral advertising purposes.

We may disclose your personal information in the following situations:

• With vendors, service providers, and consultants that perform services for us, such as companies that assist us with web hosting, site analytics, shipping and delivery, payment processing, bill collection, fraud prevention, customer service, product development and maintenance, research, customer reviews, and marketing and advertising.
• If you submit a product review or post content in another public area of our Services, we disclose this information publicly on our Services.
• If you choose to use or implement third party integrations we facilitate on our Services or with other third parties, such as a smart home platform, voice assistant, map service or a weather provider, we may disclose certain information to the entity and/or device integrated with our Services. If you choose to use or implement integrations we offer on our Services or with our Devices or to logon to our Services using credentials from a third-party platform, such as a smart home platform, voice assistant, map service or a weather provider, we may receive certain information from the third party and/or Device integrated with our Services. When such third parties allow for deletion of data collected from their platform, you may request us to delete personal information we collected from such third party by contacting us. Personal information collected by such third parties or third-party platforms are governed by the applicable third party’s privacy policy.
• If you choose to participate in a program we have with third parties, such as insurance companies, non-profit environmental organizations, or installation or repair service providers, we may disclose information about you, including certain information captured by your Device(s), to the third party with your consent.
• We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
• We may disclose personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, or safety of us, our users, the public, or others.
• We disclose personal information to our lawyers and other professional advisers where necessary to obtain advice or otherwise protect and manage our business interests.
• We may disclose personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Between and among our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
• With your consent or at your direction.

We also disclose aggregated or de-identified information that cannot reasonably be used by the recipients to identify you.

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, contractual, and warranty (to you and to third parties), or other compliance obligations. For example, we may retain some information from closed accounts so that we can comply with the law, prevent fraud, assist with investigations, resolve disputes, analyze or troubleshoot service, enforce our agreements, facilitate your ability to reactivate your account or take other actions permitted by law. Likewise, if your account is terminated or suspended by us, we may maintain some information to prevent re-registration.

Access, Correction, and Deletion

Depending on where you reside, you may have the right to:

• Request to know more about and access your personal information we have processed, including in a portable format,
• Request deletion of your personal information, and
• Request correction of inaccurate personal information.

To request access, correction, or deletion of your personal information, visit this page or call our toll-free number at 1-800-308-9244.

We may verify your request by asking you to provide information related to your recent interactions with us, such as your name, email address, or phone number.

Account Information

Registered users may update and correct certain account information at any time by logging into their account at the website where you created the account. If you wish to delete your account, please log into your account at the same Site you created the account and select the options to delete the account, but note that we may retain certain information (see Retention of Information section above).

Opting Out of Targeted Advertising, Sharing, and Sales

As described in the Targeted Advertising and Analytics section above, we process personal information to understand and improve your experience with our Services and to serve you advertisements on third party properties. Some of these activities may be considered “sales” or “sharing” of your personal information or “targeted advertising” under certain privacy laws.

Depending on where you reside, you may have the right to opt out of targeted advertising, sharing, and sales of your personal information. You can do so by following the prompts when first visiting our Sites, by clicking here, or by visiting our Sites with a legally-recognized opt-out preference signal enabled (such as the Global Privacy Control).

Cookies & Other Tracking Technologies

Most web browsers are set to accept cookies and other tracking technologies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. You can also adjust certain cookie settings by selecting the appropriate option on the banner that appears when first visiting our website or by accessing the “Privacy Settings” link at the bottom of our website at any time and selecting the appropriate options. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving promotional emails from us by following the instructions in those communications or, as applicable, by adjusting the communications options associated with your account. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications

With your consent, we may send push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Mobile Device Access

With your consent, certain of our products and services with mobile applications may access information on your mobile device such as your camera or contact list. You can always withdraw such access by not allowing our products to access features on your device 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 deny or revoke this access, it could affect the availability and functionality of the product or Service and of certain features of the mobile application.

We are headquartered in the United States and we have operations and vendors in the United States and other countries. Therefore, we and those that perform work for us may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. Where required by law, we provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing Standard Contractual Clauses. Where relevant, you may request a copy of these Standard Contractual Clauses by contacting us at customerservice@mlock.com.

If you need information or have any questions or concerns about this Privacy Policy or our use of your Personal Information, you may contact our Customer Care via e-mail at customerservice@mlock.com, or via mail at:

California, Colorado, Connecticut, Oregon, Texas, Virginia, and Utah have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures (“State Laws”). If you are a resident of one of these states, this section applies to you and describes our data practices today and in the preceding 12 months, and you may have certain rights with respect to your personal information depending on the state in which you reside.

Categories of Personal Information Collected

We have collected the following categories of personal information: identifiers such as name, alias, postal address, unique personal identifier, online identifier, device identifier, Internet Protocol address, email address, or account name; commercial information such as records of products or services purchased; internet and electronic network activity; geolocation data; audio and visual information; professional or employment-related information; inferences drawn about your consumer preferences; and Characteristics of protected classifications under California or U.S. federal law such as age and gender. For more details about the personal data points we collect, the categories of sources of such collection, and the business or commercial purposes for processing such data, please see the Information We Collect and Why We Collection Your Information sections above.

Categories of Third Parties to Whom We Disclose Personal Information

In the preceding 12 months, we have disclosed the following categories of personal information for certain business purposes (see Why We Collection Your Information section above) to the following categories of recipients:

Categories of Personal Information Sold or Shared

In the preceding 12 months, we have disclosed the following categories of personal information to third parties to engage in targeted advertising and other marketing activities, including to expand the reach and effectiveness of our own marketing campaigns. These disclosures may be considered “sales” or “sharing” or use of personal information for “targeted advertising” under certain State Laws.

Other Details About Our Information Practices

• As described in more detail in the Information We Collect section above, we collect personal information from different sources, including: directly from you, automatically when you access or use our Services, and from third-party sources.
• We do not knowingly collect, sell, or share personal information about consumers under the age of 16.
• We retain personal information for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes. See the Retention of Information section above for more detail.

Sensitive Personal Information

By using our Services in connection with certain connected Devices offered by us or another company within the FBIN family of companies, we may collect your precise geolocation in order to provide you with the Services you purchased or requested. You may provide your consent to provide such information through settings on your mobile phone at the point of collection. You may withdraw your consent to collection of such information by toggling off GPS or other location tracking on the Site or your mobile device. However, by doing so, some features and functionality of our Site or Services may not be available or perform as intended. We do not disclose this information, or any other sensitive personal information, with third parties, including for the purpose of inferring characteristics about you, without receiving your express consent.

Financial Incentives

We may provide discounts, coupons, and other benefits for customers who sign up to receive our marketing emails or join certain discount programs. When you participate in such a program, we collect personal information from you, such as identifiers like your name and email address and commercial information like your purchase history. You can opt into such a program by following the sign-up instructions, and you have the ability to opt-out of the incentive at any time by following the instructions in the emails received. In some cases, we may provide additional terms and conditions, which we will provide to you when you sign up. The value of your personal information is reasonably related to the value of the offer or discount presented to you.

Your Rights

Access, Correction, and Deletion

Please see the Your Privacy Rights and Choices section above for more information about the privacy rights you have under applicable State Laws and how to exercise your rights.

Authorized Agents

If you are from California, Colorado, or Connecticut and submitting a rights request as an authorized agent, we may ask you to submit proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with this request, such as a driver's license or other government-issued ID. In some cases, we may contact the individual who is the subject of the request to verify their own identity or confirm you have permission to submit this request.

If you are an authorized agent seeking to make an access, correction, or deletion request on behalf of a California resident, please fill out this form.

Right to Opt Out of Sales, Sharing, Targeted Advertising

Some of the activities described in the Targeted Advertising and Analytics section above may be considered “sales” or “sharing” of your personal information or use of your information for “targeted advertising” under the law that applies to you. You may opt out of these activities by following the prompts at Privacy Settings. You may also opt out by broadcasting the Global Privacy Control (GPC) (to the extent your browser supports such a signal). If you choose to use the GPC signal, you will need to turn it on for each browser you use. If you opt out, we will not be able to offer you personalized ads and some features and functionality of our Services may not be available or perform as intended.

Nondiscrimination

We do not discriminate against any individual who exercises the rights described above.

Appeals

If we deny your privacy request, you may to appeal our decision by contacting us at customerservice@mlock.com. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

If you are a resident of Canada, these additional terms apply to our collection, use and disclosure of personal information. Any reference in this Privacy Policy to “personal data” should be understood to refer to “personal information” under applicable Canadian privacy laws.

Consent: By submitting personal data to us, or our service providers and agents, you consent to the collection use, disclosure, and transfer of your personal data, including transfers outside of Quebec, for the purposes described in this Privacy Policy and as permitted or required by law.

Access and Correction: Upon your written request, and subject to certain exceptions provided by law, we will inform you of the existence, use, and disclosure of your personal data and give you access to that information. We may charge a minimal fee for providing such access to you. If you are able to establish that the information is not accurate or complete, we will take reasonable steps to delete and/or correct the information so that it is accurate, complete, and up-to-date. You may make these requests by calling 1-800-308-9244 or e-mailing us your request to customerservice@mlock.com. We may verify your request by using a third party identity verification service. Any such information will only be used for the purpose of confirming your identity and will not be retained by us. Please note that, for your safety and to protect your privacy, we cannot fulfill certain requests if we cannot verify your identity. Further, please make any privacy related requests or inquiries by calling 1-800-308-9244 or e-mailing us your request to customerservice@mlock.com.

Canada’s Anti Spam Law (“CASL”)

We will only send you commercial electronic messages (“CEMs”) where we have your express or implied consent to do so. Your consent to receive CEMs is implied where we have an existing business relationship with you, or you have reached out to us and made an inquiry within a certain time frame. You may unsubscribe from receiving CEMs at any time, by clicking the unsubscribe button on an email or following the direction provided in a text message.

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, the following section applies to you.

Legal Basis for Processing

When we process your personal data as described above, we do so in reliance on the following lawful bases:

• To perform our responsibilities under our contract with you (e.g., processing payments for and providing the products and services you requested).
• When we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
• To comply with our legal obligations (e.g., to maintain a record of your consents and track those who have opted out of marketing communications).
• When we have your consent to do so (e.g., when you opt in to receive marketing communications from us). When consent is the legal basis for our processing your personal data, you may withdraw such consent at any time.

Data Subject Requests

Please see the Your Privacy Rights and Choices section above for more information about your privacy rights and how to exercise them. In addition, you may have the right to object to certain processing or request we restrict certain processing. To exercise any of these rights, please contact us at 1-800-308-9244.

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en

For individuals in the UK: https://ico.org.uk/global/contact-us/

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html