Privacy Policy

 

Data Privacy and Security Policy

Black Limited. (hereinafter referred to as “We”, “us” or “our”) is committed to protecting your personal privacy. Black is a product developed by Black Limited.

Black Limited operates a platform that manage all locks which integrate Black Limited PCBs.

This Privacy Policy sets out how Black Limited collects, uses or discloses personal data that you have provided to us through the Platform or Services.

By using the Platform or Services, you consent to the collection, use and disclosure of your personal data as set out in this Privacy Policy.

 

DEFINITIONS

“Aggregated Information” means information about all users or specific groups or categories of users that we combine together so that it can no longer identify or reference an individual user.

“Data Controller” means the company responsible for the use and processing of Personal Information.

“Personal Data” means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.

 

WHAT TYPES OF INFORMATION DOES BLACK LIMITED GATHER ABOUT ITS USERS?

1. Information that you give us

We collect and use the following personal data that you make available to us when accessing or using our Platform and Services. This personal data includes:

• (1) Your personal details, including your name, phone number and email address, such as when you register or update the details of your user account, or when you supply ID verification information.
• (2) Service, billing, and delivery address, such as when you order or control home automation devices such as smart locks, thermostats, cameras amongst others, or grant control to the platform to apply intelligent algorithms to assist in controlling these devices.
• (3) Contact list. You can select a phone number from your contact list and send an eKey to them.
• (4) Personal data that you have provided to Third Party Websites or services (e.g., Facebook or Airbnb, iCal or Gmail calendar) and connected or synced to your Black Limited account to the extent that you have authorised and consented to such disclosure by the Third-Party Websites or services; and
• (5) Any information you may have provided.

 

2. Mobile Data

When you use certain features of the Platform, in particular our mobile applications we may collect and use different types of personal data such as your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

 

3. Log Data

We may also collect and use Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with Black Limited or logged in to your Black account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.

 

4. Cookies and other Tracking Technologies

Black Limited uses cookies and other similar technologies, such as mobile application identifiers, on the Platform. As a result, when you access or use the Platform, you consent to the use of such technologies and providing or making available certain information to us and to our business partners as set out below.

While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application.

We make use of cookies and other similar technologies to track your activities if you click on advertisements for Black Limited services on third party platforms such as search engines and social networks and may use analytics to track what you do in response to those advertisements.

We may, either directly or through third party companies and individuals we engage to provide services to us, also continue to track your behaviour on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform.

Please note that if you have disabled cookies completely, you may not be able to access any or all of the features on the Platform, you may also still receive advertising on or about the Platform – it just will not be tailored to your interests.

 

HOW BLACK LIMITED USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE

We collect and use personal data for the following purposes:

• to enable you to access and use the Platform;
• to operate, protect, improve, and optimize the Platform, Black’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and where you have given your consent for advertising and marketing.
• to help create and maintain a trusted and safer environment on the Platform and Services, such as through fraud detection and prevention, conducting investigations and risk assessments.
• to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• where we have your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information about Black Limited or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications by contacting us at customersupport@black.inc;
• to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Black Limited or our business partners; and
• to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.

 

WHEN BLACK LIMITED DISCLOSES OR SHARES PERSONAL INFORMATION, AND TO WHOM

IMPORTANT: When you use the Platform, your data may be sent to the United States and possibly other countries
We may transfer, store, use and process your information, including any Personal Data, overseas such as to the United States or Europe. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.

Your Personal Data may be disclosed as follows:

• Parts of your public profile page that contain some Personal Data may be displayed in other parts of the Platform to other users for marketing purposes or to the extent necessary to operate and manage referral and rewards programs.
• As necessary to enable guests that you have approved to access the services you have subscribed to or the home automation devices available in your home. For example, an SMS or Email will be sent to your guest with the approved listing information to inform the guest on the check-in procedure.
• As necessary to enable the linking of your account on a third-party social networking site to your Black Limited account.

Do note that some features on the Platform may require the publication and display of information received from the third-party social networking site, as well as the publication and display of information from the Platform to the third-party social networking site. You will be able to control such disclosure through the settings and authorisation on the Platform and, to the extent possible, on the third-party social networking site.

• We may distribute parts of the Platform for display on sites operated by Black Limited business partners and affiliates, using technologies such as HTML widgets.
• We may allow our related entities such as our subsidiaries, and their employees, to use and process your Personal Information in the same way and to the same extent that we are permitted to under this Privacy Policy. These related entities comply with the same obligations that we must protect your Personal Information under this Privacy Policy.
• We may also engage third party companies and individuals, to provide services to us, including but not limited to technology services and services to help verify your identity, to conduct checks against databases such as public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, and to facilitate the payments or reimbursements you request (such as Concur and American Express). We may provide Personal Information about you to these third parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. We will ensure that such third parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.

This Privacy Policy is subject to any existing laws of Portugal in relation to the protection of information and if required by any lawful authority for any legal purposes such as the enforcement of any laws or to prevent the breaching of any laws, we shall release all such information as is legally required by the requisite and lawful authority in accordance with the directions of the lawful court of the competent jurisdiction.

We may also publish, disclose, and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing, and advertising, and other business purposes.

 

Our legal basis for collecting, holding and using your information

Data protection law sets the lawful legal bases (or conditions) which allow us to collect, hold and use your personal information.

These are:

• For the purposes of our own legitimate interests. We believe that we have a legitimate interest in being able to provide information about our products and services to our customer organisations. As set out in this notice, this sometimes requires us to collect and use personal information about individuals. We only use this legal basis where these interests are not overridden by your interests and fundamental rights or freedoms.
• Where we have entered into a contract with you. In these circumstances, we may need to process your personal information in order to fulfil the contract.
• Where we are under a legal obligation to process personal information. For instance, we are required to collect certain information in accordance with our obligations under equalities legislation.

 

Security and storage of your personal information

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 

Your rights

You have the right to request from us access to your own personal information. This is sometimes known as a ‘subject access request’. You also have the right to ask us not to process your personal data for direct marketing purposes.

From 25 May 2018, you will have additional rights to request that:

• Inaccurate information we hold about you is corrected
• Your information is deleted – We stop using your personal information for certain purposes – Decisions about you are not made by wholly automated means

Many of the rights listed above are limited to certain defined circumstances and we may not be able to comply with your request.

If you are dissatisfied with how we are using your personal information, or if you wish to complain about how we have handled a request, then please contact customersupport@black.inc, and we will try to resolve any issues you may have.

 

GDPR Compliance for Users in Europe

Data Controller and Contact Information: Black Limited is the Data Controller of your personal information. For any privacy-related inquiries or concerns, you can contact us at customersupport@black.inc. If applicable, our Data Protection Officer can be reached at Yaniv@black.inc.

Legal Basis for Processing Personal Data: We process your personal data on the following legal bases: consent, contract fulfilment, compliance with legal obligations, protection of your vital interests, performance of a task carried out in the public interest, and for our legitimate interests, except where such interests are overridden by your rights and interests.

Data Subject Rights: Under the GDPR, you have the right to access, rectify, erase, restrict processing, and port your data. You also have the right to object to processing and to not be subject to decisions based solely on automated processing. Requests to exercise these rights can be directed to customersupport@black.inc.

Data Transfer and Adequacy Decision: Personal data transferred outside the EEA is safeguarded by data protection clauses or adherence to the EU-U.S. Privacy Shield Framework.

Retention Period: Personal data is retained as long as necessary for the purposes set out in this policy or as required by law. The criteria for determining the duration include the nature of our ongoing relationship with you and legal obligations.

Right to Withdraw Consent: If we process your data based on consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your member state.

 

Considerations for Users in the USA

State-Specific Regulations: We comply with state-specific privacy laws, such as the California Consumer Privacy Act (CCPA), where applicable.

Consumer Rights Under State Laws: You may have the right to know what personal data is being collected, request deletion of personal data, and opt-out of the sale of personal data.

Data Breach Notification: In the event of a data breach, we will notify affected individuals in compliance with applicable state laws.

Children’s Privacy: If applicable, we comply with the Children’s Online Privacy Protection Act (COPPA) and do not knowingly collect personal information from children under 13.

 

General Enhancements

Explicit Consent: We ensure that consent for processing personal data is clear, specific, freely given, and documented. For sensitive data, we use a double opt-in mechanism.

Data Protection Impact Assessment (DPIA): DPIAs are conducted for processing operations that may result in high risk to the rights and freedoms of individuals.

Regular Audits and Updates: Our privacy policy and practices are regularly audited and updated to ensure compliance with evolving regulations.

 

HOW TO CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR BLACK LIMTED ACCOUNT

You may review, update, correct or delete the Personal Information in your Black Limited account. If you would like to correct your information or cancel your Black Limited account entirely, you can do so by logging in to your account.

 

SECURING YOUR PERSONAL INFORMATION

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction, or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.

 

YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES

The Platform will contain links to other websites not owned or controlled by Black Limited. Black Limited does not have any control over third party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Data from you. They will have their own rules about the collection, use and disclosure of Personal Data. We encourage you to read the terms of use and privacy policies of the other websites that you visit.

Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google’s terms of use (located at http://www.google.com/intl/en_us/help/terms_maps.html) and Google’s privacy policy (located at http://www.google.com/privacy.html), as may be amended by Google from time to time.

 

CHANGES TO THIS PRIVACY POLICY

We may change how we collect, use, and disclose Personal Data at any time. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you by posting a notice on the Platform and by sending an email to you. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.

It’s important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue providing the Platform and Services to you, and your only option will be to stop accessing the Platform and Services and deactivate your Black Limited account. You can deactivate your account by sending us an email to customersupport@black.inc.