Last modified: 2022-06-29
Categories of Personal Information We Collect:
We only collect personal information when we truly need it to provide a Service to You or improve the overall user experience. We may collect the following categories of personal information:
Identifiers. To set You up as a user for our Services, we collect Your basic personal information, such as Your name, email address, postal address and phone number; we may also collect Identifiers of individuals that fill out a contact form or otherwise contact us;
Account Information. When You register Your 1VALET account, we collect Your username and an encrypted version of Your passcode;
Commercial Data. We receive commercial information, like purchase history, or delivery information, when You make transactions through the App or the Portals;
Technical Data. When You use our Website, Portals or App, we automatically receive Your device’s technical information such as Your wireless device ID, IP address, browser type, language and operating system. We receive information on how You use the Portals or the App; we are also able to view anonymized information on how You navigate on our Website or Portals, and the referring URL or the webpage that led You to our Website;
Hardware Usage Data. When you use our proprietary hardware (e.g. our entry console) or hardware we integrate, such as door locks and thermostats), or if something is not working properly, we collect Your hardware usage information;
Sensory Data. When You enter or visit a 1VALET-powered Building through a public access door, we collect a recording of Your image;
You also have the option to enable Facial Entry for added convenience in the App. By enabling Facial Entry, You consent to the collection of information pursuant to our Facial Entry Policy. Please review such policy in detail before opting into the Facial Entry feature.
Geolocation Data. To enable certain features or use of our Services, we may collect Your device’s location information, such as city, state, and zip code or postal code associated with Your IP address or derived through wireless location triangulation;
Communications. When You contact us, for example in connection with requests for customer support or for product information, we collect the information and communications You share with us.
Sources from which We Collect personal Information
We obtain the categories of personal information listed above from the following categories of sources:
Directly from You: We collect personal information that You voluntarily provide to us when You register on the Portals, App or Website, express an interest in obtaining information about us or our Services, or when You otherwise contact us and communicate with us;
From our Affiliates and Partners: In order to enhance our ability to provide relevant services to You, create Your user account, and update our records, we may obtain personal information about You from other sources, such as Your Property Management company, and our Affiliates and Business Partners like third-party software providers, payment processors and analytics providers;
Through Your Use of Our Services: We automatically collect certain personal information when You visit, use, or navigate the Website, Portals and our App. This information does not reveal information that identifies You, but may include device and usage information, like Usage Data, Technical Data, Geolocation Data, and other technical information. This information is primarily needed to maintain the security and operation of our Website, Portals and App, and for our internal analytics and reporting purposes.
Purposes for which We Collect or Share personal information:
We process Your personal information for purposes based on legitimate business interests, as requested by You specifically, for the fulfillment of our contract with You, and to ensure compliance with our legal obligations. Specifically, we use the information we collect or receive for the purpose of:
Providing You with the best user experience when performing Services as required, including creating, maintaining, or servicing Your account, verifying Your information, identifying You to grant You access into a Building , processing or fulfilling orders and transactions, processing payments, providing analytics services, providing advertising or marketing services, or providing similar services (“Performing Services”);
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”);
Analyzing how You use our Services to improve our Website, Portals, App and Services, respond to Your desires and preferences, and to identify and repair errors that impair existing or intended functionality (“Repairs”);
Undertaking internal research for technological development and demonstration (“Research and Development”);
Requesting Your feedback and contacting You about use of our Services (“Feedback Request”);
Complying with legal requirements, and responding to legal requests that require us to inspect data to determine how to respond (“Legal Requirements”);
Enforcing our terms, conditions, and policies for business purposes (“Business Purposes”); and
Undertaking activities to verify or maintain the quality or safety of our Services and the hardware we integrate with (for example, the access system), and to improve, upgrade, or enhance such Services and hardware (“Quality and Safety”).
From time to time, we may send You informational messages relating to our features like notifications about important updates, or offers for trusted services that You may find useful, such as moving or cleaning services. If You do not wish to receive these notifications, You may opt out of such communication by following the instructions contained in the message. We may however still send You messages relating to the Services You have requested or received from us.
Who do we share Your personal information with:
First and foremost, we never sell or share Your personal information to third parties for the purpose of marketing or advertising to You. We also don’t publicly share personal information that could identify You.
We only share personal information with third parties when required to do so by law, to process data, or to better provide You with current or prospective Services. These third parties are only provided with such personal information as is necessary to perform the services for which they have been contracted, and they are required pursuant to a written contract with us to keep Your personal information confidential and secure. They are also restricted from using Your personal information for any other purpose other than as described herein or as otherwise permitted by law.
We may share Your personal information with:
Property management that has been hired by You or Your landlord to manage a Building, to help with troubleshooting, and assist in the provision of our Services (“Property Management”);
Our business partners who perform services for us on our behalf and require access to such information to do that work, such as hosting our Website, processing Your payments made through the App, sending communications, operating a call center, or help us with troubleshooting if necessary (“Business Partners”);
Vendors that You choose to use, such as insurance companies or cleaning companies that are accessible through our App (“Third Party Vendors”);
Any entity that acquires all or a portion of our business, assets, or stock, including in connection with a merger, reorganization, or other commercial transaction, or that acquires a Building (“Successors”);
Authorities, subject to applicable laws, including to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside Your country of residence (“Authorities”);
Your landlord, if necessary to ensure the safety of the Building or a unit in a Building (“Landlord”);
Your roommates, to alert them of changes in certain settings of the App and Services provided (e.g., temperature settings) (“Roommates”);
Organizations that provide services for accessing or using the Internet (“Internet Service Providers”); and
Visitors, when and to the extent necessary for them to access the Intercom’s directory to get access to a Building (“Building Visitors”).
What Happens With Your Publicly Displayed Information
Any information You share on the Community Bulletin Board in our App is visible to other tenants in Your community and Your property management. Personal information, like Your name and telephone number, which You submit to one of these forums, can be read, collected, or used by other individuals. We are not responsible for the personal information You choose to submit in these forums.
How Long Do We Retain Your Information
We only retain collected information for as long as necessary to provide You with Your requested service, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process Your personal information, we either delete or anonymize Your personal information. If this is not possible (for example, because Your personal information has been stored in backup archives), then we will either anonymize or securely store Your personal information and isolate it from any further processing until deletion is possible.
New York City Users – Keyless Entry Systems (New York City Tenant Data Privacy Act (TDPA))
If You are a tenant in a Building in New York City, and we have collected or generated personal information through a keyless entry system authenticating You so You can get access into such Building (“Authentication Data”), we remove, delete, or anonymize such Authentication Data within 90 days of collection or generation. We also remove, delete, or anonymize any personal information against which Authentication Data is checked for verification of Your identity (“Reference Data”) within 90 days after You permanently vacate the Building or withdraw Your consent. We may only retain Authentication or Reference Data if it is needed to (i) detect security incidents, (ii) prosecute or protect against malicious, deceptive, fraudulent, or illegal activity, or (iii) debug and identify repair errors that impair existing intended functionality.
How We Protect Your personal information
While security measures are never perfect or impenetrable, we implement reasonable security procedures and practices appropriate to the nature of the personal information to protect the personal information from unauthorized or illegal access, destruction, use, modification, or disclosure. Our Portals and App are scanned on a regular basis for security holes and known vulnerabilities in order to make Your visit and use safe. Furthermore, personal information that may identify You is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. All sensitive personal information You supply is also encrypted via Secure Socket Layer (SSL) technology. All financial transactions are processed through a gateway provider and are not stored or processed on our servers. Should a data breach occur nevertheless, we will notify You via email within ten (10) business days.
COPPA (Children Online Privacy Protection Act)
We do not knowingly collect personal information from children under 13, and we also do not specifically market to children under the age of 13. If You are a parent and learn that Your child has provided us with personal information without consent, please contact us as set forth below.
Our Website, Portals or App may link to external websites of third parties that are not operated by us, and which have separate and independent privacy policies. Please be aware that we have no control over the content and practices of these websites, and cannot accept responsibility or liability for their respective privacy policies. Nonetheless, we seek to protect the integrity of our Website, Portals and App and other Services and welcome any feedback.
If You purchase services or products from Third Party Vendors that are accessible through our App, all commercial and related legal terms and conditions are between You and the Third Party Vendor, including without limitation, delivery, quality, warranties, indemnities, returns, etc.
We also use third-party advertisers to support our Website and the Partner Portal (but not the 1Connect Portal or the App). Some of these advertisers may use technology such as cookies, which will also send these advertisers certain information (such as Google through the Google AdSense program), including Your IP address, Your internet service provider, and the browser You used to visit our Website or the Partner Portal. This is generally used for location customization (showing New York real estate ads to someone in New York, for example) or showing certain ads based on specific websites visited (such as showing cooking ads to someone who frequently visits cooking websites).
For more information, please visit https://policies.google.com/technologies/partner-sites. You can opt out of Google’s collection and processing of data generated by Your use of the Services at https://tools.google.com/dlpage/gaoptout.
You can choose to disable or selectively turn off our cookies or third-party cookies in Your browser settings, or by managing preferences in programs such as Norton Internet Security. Since every browser is a little different, look at Your browser’s Help Menu to learn the correct way to modify Your cookies. However, disabling or turning off cookies can affect how You are able to interact with our Website, Portals as well as other websites.
Access to and Update of Personal Information
We believe that it is imperative that the personal information as it relates to the 1VALET account be as accurate, complete and as up-to-date as possible. Accordingly, we encourage You to access and verify all of the personal information collected by us and Your property manager as often as necessary. Please reach out to Your Building’s property management company in case Your personal information needs to be corrected or amended, or contact us at email@example.com.
Additional Rights as a Resident of California or Canada
If You live in Canada, You have a right to access the personal information that we have collected, used or disclosed about You. If You would like to make a request, please contact us or have Your authorized agent contact us at firstname.lastname@example.org. In order to verify Your request and protect Your privacy, we may need You or Your authorized agent to supply additional information.
If You are a California resident, You have the right to request twice annually that we disclose to You the specific pieces of personal information we collected about You in the preceding twelve months. You may also ask about the categories of information that we have shared with third parties for their direct marketing purposes, and the contact information of such third parties. If You would like to make such a request, please contact us or have Your authorized agent contact us at email@example.com. In order to verify Your request and protect Your privacy, we may need You or Your authorized agent to supply additional information.
Finally, if You are a California resident, You have the right to request that we delete any of Your personal information that we collected from You, subject to certain exceptions. If You or Your authorized agent submit a valid and verifiable request and we can confirm Your identity or Your agent’s authority to make the request, we will delete or anonymize Your information, so it no longer identifies You. An exception may be that we are legally required to keep the personal information, or to use it for another legally justifiable reason, for example:
To complete a transaction for which we collected the personal information;
To the extent we need the personal information to perform our contract with You, or if You are a resident to the extent Your property management needs the information to perform their contract with You as expected based on Your relationship with us and/or property management;
To identify and repair errors that impair existing intended functionality;
For fraud prevention or to maintain security; or
To comply with a legal obligation.
As a California resident, You also have the right to direct a business that sells Your personal information to third parties not to sell Your personal information. This right is referred to as “the right to opt-out.” Because we do not sell Your personal information, we do not provide any mechanism for You to exercise the right to opt out.
We will not discriminate against You for exercising Your privacy rights under the California Consumer Privacy Act (CCPA) or any other of Your privacy rights.