Contactless Entry Privacy Policy

Last modified: June 4, 2020

Introduction

Angus Systems Group, Ltd. (“Company”, “We”, “Us” and similar terms) respects your privacy and takes steps to protect it through our compliance with this Mobile App Privacy Policy (the “Policy”). This Policy describes: 

  • The types of personal information collected, accessed, used, or otherwise processed by Contactless Entry (the “App”); and

  • our practices for collecting, using, maintaining, protecting, and disclosing that personal information.

This Policy applies only to information about identifiable individuals (“personal information”) , which We collect in this App and in email, text, and other electronic communications sent through or in connection with this App.

This Policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through this App. 

  • You provide to, or is collected by, any third party.

  • Information that is not about an identifiable individual, where there is no serious possibility that an individual could be identified through the use of that information, alone or in combination with other information.

Our websites, our other apps, and other third parties may have their own privacy policies, which We encourage you to read before providing information on or through them.

Please read this Policy carefully to understand our policies and practices regarding your personal information and how We will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this Policy. This Policy may change from time to time (see Changes to our Privacy Policy). Your continued use of this App after We revise this Policy means you accept those changes, so please check the Policy periodically for updates. 

Information We Collect and How We Collect It

We collect information from and about users of our App, as follows:

  • We collect information about you, directly from you, when you provide it to Us; 

  • We collect information from your tenants when you cause them to use the App or to provide information required for the App to function; and

  • Certain information is collected automatically when you use the App or cause a Visitor (as defined below) to use the App. 

Further details are provided below.

Information You Provide to Us

When you download, register with, or use this App, We may ask you to provide certain information, including:

  • Information that you provide by virtue of using the App. This includes information provided at the time of registering to use the App, which may include your name, title, email address, phone number, and place of work. We may also ask you for information when you report a problem with the App.

  • Records and copies of your correspondence (including email addresses and phone numbers) if you contact Us.

Information Collected From and About your Visitors and Tenants

In order to function, the App will also necessarily access, use, store and otherwise process:

  • The name, email address, phone number, and place of work of your tenants’ representatives, which such individuals enter through our web portal in connection with your use of the App (“Tenant Information”); and  

  • Personal information about any visitor to your building/office who you have directed or permitted to use the App in order to obtain access to your building/office (“Visitor”).

The Visitor’s information, which will include the Visitor’s name, email address and company name as well as the visit date and time (collectively “Visitor Information”), is provided by you or your tenants when you or your tenants log in to our web portal and provide such information. The system then generates a specific QR code that is sent to the Visitor via email along with certain information so the Visitor can confirm compliance with your conditions of entry.  When the Visitor comes to your building/office at the appointed time and scans the QR code on the App, the App recognizes that QR code as valid (if the conditions of entry have been confirmed), approves the entry of the Visitor, connects the QR code to the Visitor’s name as entered through the web portal, and sends you or your tenant an email that the Visitor has arrived.  Our system will store a copy of the Visitor’s information as well as a copy of the interaction. It is your responsibility to ensure that you or your tenant provides any notices to the tenant’s representative(s) and all Visitors, and obtains any consents from such tenant representatives and Visitors, as required by applicable laws (including relevant privacy and data protection laws) and regulatory guidelines, prior to providing such individuals’ personal information to Us through our web portal or allowing them to use the App on your device(s).

How We Use Personal Information

We use the personal information that We collect or that you provide to Us, in order to:

  • Provide you with the App, its contents, its services, and any other information, products or services that you request from Us.

  • Fulfill any other purpose for which you provide it.

  • Give you notices about your subscription, including expiration and renewal notices.

  • Notify you when App updates are available, and of changes to any products or services We offer or provide though it.

For clarity, We use the Tenant Information and the Visitor Information that you or your tenant provides to Us solely as needed for operation of the App. We may also use aggregated information about Visitors that does not identify any individual or device, without restriction, where such information does not constitute personal information under applicable laws.

The personal information that We collect, store or otherwise process, is accessible to the following categories of individuals within our organization: the Customer Success Team; the Database Management Team; the IT Operations Team; the Quality Assurance Team; the Account Management Team; and the Product Development Team.

Disclosure of Your Information

We may disclose personal information that We collect or you, your tenants, and/or Visitors to your building provide to Us through or in connection with the App, as follows:

  • To your building/office management to track the flow of Visitors to your building/office.

  • To our subsidiaries and affiliates, including Angus Systems Group, Inc.

  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.

  • For any other purpose disclosed by Us when you provide the information, with your consent (express or implied, as appropriate, in accordance with applicable laws).

  • Where required by applicable law, including to comply with any court order, law, or legal process, including to respond to any government or regulatory request.

  • Where permitted by applicable law, if We believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our affiliates and subsidiaries, our customers, or others. 

Some of our affiliates, subsidiaries and service providers may be located outside the country in which you reside.  Personal information will be stored in Canada and the US, and therefore, may be accessible to courts, law enforcement, and national security authorities in either or both of these countries.

Accessing and Correcting Your Personal Information

You can generally review, change, rectify, and/or update your personal information by logging into the App or the web portal and visiting your account profile page. 

Individuals may also contact Us to access, change, rectify, or update any personal information they cannot access directly, subject to providing satisfactory proof of identity (see Contact Information).

Your California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. At this time, We do not engage in this type of disclosure.

Data Security

We have implemented measures designed to secure personal information from theft, accidental loss, and from unauthorized access, use, alteration, and disclosure. All personal information that you provide to Us, or that We otherwise collect in connection with the App, is stored on our secure servers behind firewalls. 

The safety and security of the information also depends on you. Where We have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential and secure. We recommend that you choose a secure password, and We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although We do our best to protect the personal information, We cannot guarantee the security of the personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures We implement.

Changes to Our Privacy Policy

We may update this Policy from time to time. If We make material changes to how We treat the personal information, We will post the new privacy policy on this page with a notice that the Policy has been updated, and We will also notify you of material changes by email at the email address specified in your account, where applicable.

The date the Policy was last revised is identified at the top of the page. You are responsible for ensuring We have an up-to-date active and deliverable email address for you and for periodically visiting this Policy to check for any changes.

Contact Information

You may contact our CFO, COO – Ryan Dewey, legal@angus-systems.com, 1125 Leslie Street, Toronto, ON M3C 2J6, or 416-385-8550, in order to:

  • Ask questions, make a complaint, or otherwise comment about this Policy or our privacy and personal information handling practices;

  • Access, correct or update your personal information, to the extent you are not able to do this by logging into the App or the web portal and visiting your account profile page; 

  • Withdraw consent to continued use and disclosure of personal information, subject to any legal restrictions and reasonable notice; and

  • If you are located in Canada, obtain written information about our policies and practices with respect to our service providers outside Canada (including affiliates that provide a service to Us), or to ask questions about the collection, use, disclosure or storage of personal information by such service providers and affiliates.