Privacy Policy

2. Information We Collect

2.1 Personal Information

We collect information that you provide directly to us:

• Account Information: Phone number, email address, name
• Authentication Data: Password (stored securely hashed), PIN (stored locally on device)
• Property Information: Addresses, property names, unit details
• Vehicle Information: License plate numbers, vehicle make/model
• Identity Verification: Government ID documents (processed via Persona, a third-party KYC provider)

2.2 Automatically Collected Information

• Device Information: Device ID, model, operating system version
• Push Notification Tokens: Firebase Cloud Messaging (FCM) tokens for notifications
• Usage Data: App interactions, access logs, feature usage
• Security Logs: Login attempts, access events, device approvals

2.3 Biometric Data

If you enable biometric authentication (fingerprint or face unlock), this data is processed locally on your device using your device's secure enclave. We do not transmit or store biometric data on our servers.

3. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain the MyLock service
• Authenticate your identity and secure your account
• Send push notifications for security events, calls, and access requests
• Enable video intercom functionality with your property kiosks
• Manage shared access permissions with family, guests, or service providers
• Process identity verification for enhanced security features
• Improve and personalize your experience
• Communicate with you about service updates and security alerts
• Comply with legal obligations

4. Data Sharing and Disclosure

We may share your information in the following circumstances:

• With Your Consent: When you share access with other users
• Service Providers: Third parties who assist in operating our service (e.g., Persona for identity verification, Firebase for notifications)
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal information to third parties.

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information:

• All data in transit is encrypted using TLS/HTTPS
• Passwords are hashed using bcrypt before storage
• PINs are stored locally on your device using secure storage
• Access tokens expire and require periodic re-authentication
• Device approval system prevents unauthorized device access
• Two-factor authentication available for enhanced security

6. Data Retention

We retain your personal information for as long as your account is active or as needed to provide you services. You may request deletion of your account and associated data at any time through the app settings or by contacting us.

7. Your Rights

Depending on your location, you may have the right to:

• Access and receive a copy of your personal data
• Rectify or update your personal information
• Request deletion of your data
• Object to processing of your data
• Data portability
• Withdraw consent

To exercise these rights, please contact us at privacy@my-lock.eu

8. Children's Privacy

Our Service is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your data in accordance with this Privacy Policy.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us:

• Email: privacy@my-lock.eu
• Company: Archil Lab Tech
• Website: https://my-lock.eu