Effective date: 08/15/2022
Updated date: 06/09/2023
Revolo does not share, rent, or sell your personal information with other non-affiliated people, non-affiliated companies, or non-affiliated partners unless you have requested or authorized us to do so. We may share personal information about you with third parties, affiliates, or trusted partners who work on behalf of or with Revolo to help Revolo and our partners to provide you with services you have requested or collect payment.
IF YOU DO NOT AGREE WITH THIS POLICY OR THE INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES DESCRIBED IN THIS POLICY, DO NOT USE THE REVOLO SERVICES OR REGISTER AN ACCOUNT.
This policy will help you understand the following:
1. INFORMATION COLLECTION PRACTICES
2. USE OF INFORMATION
3. INFORMATION SHARING
4. THIRD-PARTY PROVIDERS
5. ONLINE TRACKING AND YOUR CHOICES
6. INFORMATION SECURITY MEASURES
8. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
9. MLIMITATION OF WARRANTY
11. CALIFORNIA PRIVACY RIGHTS
12. MODIFICATION OF THIS POLICY
13. PRIVACY QUESTIONS
When you visit Revolo websites and use Revolo mobile applications without registering, you can browse without submitting personal information about yourself. If you register for an account within or to access Revolo Services, we will collect some personally identifiable information from you, including your username, email address, and hashed version of the password you select. When you interact with Revolo Services, we also receive and store certain additional types of information which, in general, do not directly identify you. For example, we automatically receive and record information on our server logs from your browser or device including your IP address, browser type and language, referring/exit pages and URLs, device type, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, and the date and time. This Section of the Policy outlines the various ways that information is collected from Revolo Services. Please fully review this Policy before you use Revolo Services or submit information to us.
(a) Registration and Login.
Certain Revolo Services require you to register for an account and/or log in using credentials. You can register for an account from our account registration system or a third-party site or service such as Facebook ("Account"). When you register for an Account you may be asked to provide some personally identifiable information, such as your email address, phone number, lock SN code, and a username and password that you select. When you are asked to create an Account using your credentials from a third-party site or service, you will be asked for your username, password, and other information to verify that you have an account with the third-party site or service. When you provide credentials for a third-party site or service, we may use those credentials to obtain information about you from that third party. See Section 1.4 (Information from Other Sources) and 3.4 (Social Sites) for more information. When you register an Account and log in to Revolo Services you must provide your current, complete, and accurate information. It is your responsibility to keep your information up to date. We are not responsible for any problems, interruptions in access, or liability that may arise if you do not give us complete and accurate information or if you fail to update your information so that it is current.
(b) Product Set Up. To use certain products such as our lock products, we may record information relating to the setup, general performance, and operation of our Service, your application and lock (and of other of our locks in your home or business or that you otherwise may access), including device status, logs of those who lock/unlock the device and Service, the guests that you invite, and those people who may invite you as a guest, to use the device and application. We may store this data along with your personally identifying information and other information about your use of our Service. We use this information to allow you (and us) to operate and monitor your device and our Service.
While your application connects to Revolo lock, you need to use Bluetooth features in your app, and the Revolo app needs to get your phone two permissions, Bluetooth permission is necessary to perform any Bluetooth communication, such as requesting a connection, accepting a connection, and transferring data. Also, location information permission is necessary because a Bluetooth scan can gather information about the location of the user. This information may come from the user's own devices, as well as Bluetooth beacons in use at locations such as shops and transit facilities. And if you enable the Auto-Unlock feature, the application will track your location information using GPS to determine when your application nears Revolo devices that you have permission to access (e.g. when you are near home). This location information will tell your mobile device to start listening for your lock more often (increasing the polling). This improves the Revolo device's performance and saves your mobile device's battery life.
(c) Correspondence. If you send us personal correspondence, such as emails or letters, about your use of Revolo Services, we may save the information in a profile specific to you.
(d) Information You Provide to Others. You may choose to share information with third parties such as social networking Sites like Facebook and WeChat ("Social Sites") by "sharing" a Bluetooth key. See Section 3.4 (Social Sites) for more information.
1.3. Automatically Collected Information.
We will collect some information about you and any product or device you use to access or use Revolo Services automatically using a variety of technologies. In general, automatically collected information about the use of Revolo Services does not directly identify you and the information may include your diagnostic log information, IP address, browser type, language, referring/exit pages and URLs, platform type, number of clicks, landing pages, cookie information, the pages you requested and viewed, the amount of time spent on particular pages, the actions performed in the Revolo App, the info(OS type/version, network, etc.) of the phone which the Revolo App was installed, and the date and time. We collect this information for the purposes described in this Policy, including to better understand our customer base and to improve the quality of our Revolo Services. We do NOT collect information not related to the use of the Revolo services.
(a) Mobile Data. When you use certain features of the Service, in particular our mobile applications, we may receive, store, and process different types of information about 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 Service or specific features of the platform). If you access the Service through a mobile device and you do not want your mobile device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your mobile device. See your mobile device manufacturer's instructions for further details. Of course, if you do this, Service functionality (such as the Auto-Unlock feature described immediately above) may not work.
(b) Guest Access.
As part of our Services, you may give others ("guests") permission levels to access your Revolo device – e.g. to unlock and lock your door (and possibly even to pass this access along to others). Needless to say, you must be careful of the guests that you invite and the access that you give them. YOU ARE RESPONSIBLE FOR ALL USES OF YOUR ACCOUNT, SO BE CAREFUL TO SECURE THIS INFORMATION AND ONLY GIVE ACCESS TO PEOPLE YOU TRUST.
If you send us a request (for example via a support email or one of our feedback mechanisms), we may use your information to contact you and provide support or a response. We also reserve the right to publish your request to help us clarify or respond to your request or to help us support other users.
1.4. Information from Other Sources.
With your permission, we may obtain both personal and non-personal information about you from business partners, Social Sites, and other third parties and add it to our account information or other information we have collected. We also collect information from Social Sites when you register or log in to use our Revolo Services by using your Social Site log-in and password. For example, our Site allows you to create an account and log in using your Facebook account credentials and, in addition to allowing you to log in to the Site and share videos with Facebook, we also use your authorization to obtain the following information from Facebook: Facebook username, first name, last name, and profile picture. The information we collect may depend on the privacy settings you have with the Social Site, so please consult the Social Site's privacy and data practices.
We may use your personally identifiable information (including tracking information) to manage your Account. We may also use it to operate, maintain, and improve the Revolo Services (including providing you with a more personal experience); communicate with you; provide you information about products and Revolo Services (including products and services of third parties); market; research purposes; resolve disputes; collect fees owed; detect and protect against errors, fraud, and criminal activity; assist law enforcement; enforce this Policy and any the terms related to our Revolo Services; and any other purpose described in this Policy or that we describe to you at the time of collection.
2.2. Email Communications.
We may use your personally identifiable information to send you emails or other communications related to your Account or the Revolo Services, or in response to your inquiries or requests. You may not opt out of receiving service-related messages that are not promotional. We may also send you marketing emails, surveys, or newsletters to notify you about products or services that may be of interest to you. If you would like to stop receiving marketing emails from us, please click on the unsubscribe link at the bottom of any marketing email you receive. You can opt out of marketing email in this way, but you will continue to receive service-related emails as they are a fundamental part of the services.
2.3. Non-identifying Information.
We may use non-identifying information for any lawful purpose, including analyzing trends, research, Revolo Services administration, tracking users' movements around the Revolo Services, and improving our business and the Revolo Services.
2.4. Retaining Your Information.
Retaining Your Information. In general, we will retain your information as long as legally required or allowed. If you cancel your Account or your Account is otherwise terminated, we may but are not obligated to, delete the information we have collected or obtained from third parties, and we may continue to use and disclose it following this Policy. But you can delete your account information manually, and it will be purged from our system.
2.5. Transfer of personal information outside of your jurisdiction.
Transfer of personal information outside of your jurisdiction. To the extent that we need to transfer personal information outside your jurisdiction, whether it is transferred to our affiliates (these may include communications, social media, technology, or cloud services) or to third-party service providers, we shall do so following the applicable laws. In particular, to ensure that all such transfers comply with applicable local data protection laws, we will implement appropriate security safeguards. You will have the right to be informed of the appropriate safeguards taken by Revolo for this transfer of your personal information. For example, if you choose to use other third-party services available for this product or service (such as Amazon, Google, etc.), those third parties may be able to read information about you, and information about you may also be transferred to a third-party server outside of your jurisdiction, and you agree to this kind of transfer.
Whenever we share personal data originating in the EEA with a third party that may or may not be a Revolo entity outside the EEA, we will do so based on EU standard contractual clauses or any other safeguards provided for in the GDPR.
For example, if you choose to use other third-party services available for this product or service (such as Amazon, Google, etc.), those third parties may be able to read information about you, and information about you may also be transferred to a third-party server outside of your jurisdiction, and you agree to this kind of transfer.
We will not sell or rent any of your personal information to third parties for marketing purposes. However, we may disclose your information to any affiliated entity or organization and to agents and service providers. We may also share non-identifying information with third parties for any lawful purpose, including analyzing trends, research, Revolo Services administration, tracking users' movements around the Revolo Services, and improving our business, products, and Revolo Services. Use of information by affiliated entities and organizations will be subject to this Policy or an agreement that is at least as restrictive as this Policy. For information on the use of information by agents and service providers see Section 4 (THIRD-PARTY PROVIDERS).
3.2. Legal Requirements.
In some cases, we may disclose your personally identifiable information as required by law; if we believe that disclosure is needed to protect our rights; to government regulators; to law enforcement authorities; in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Revolo Services; and to respond to a physical threat to you or another person.
3.3. Insolvency and Business Transitions.
If we ever file for bankruptcy or engage in a business transition such as a merger with another company or if purchase, sell, or reorganize all or a part of the Revolo Services or our business or assets, we may disclose your personal information, including to prospective or actual purchasers in connection with one of these transactions.
3.4. Social Sites.
We cannot ensure that all of your personal information will never be disclosed in ways not otherwise described in this Policy. For example, we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the Revolo Services. No transmission of data over the internet can be 100% secure.
We use third parties to help us operate and improve Revolo Services. We may provide these third parties information we collect, and they may collect information from you, and about your use of Revolo Services. We may provide the information we collect to third parties and it will, unless specifically noted otherwise in this Policy, be governed by this Policy and may only be used by those third parties to help us operate or improve our business or the Revolo Services and provide services to us. We do not control information collected by third parties and are not responsible for their use of that information. Please review their privacy policies for more information on their information collection, use, and sharing practices.
4.2. Google Analytics.
Keeping secure personal information that we collect is of great concern to us. While we have mechanisms in place to safeguard your personal information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure. When you provide information to Revolo Services, you do so at your own risk.
The Revolo Services are intended for general audiences and are not directed to children under 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information without parental consent, please contact us by using the contact information in the Privacy Questions section at the bottom of this Policy, and we will take steps to remove the information and terminate the child's Account.
If you would like to cancel your Account or update your personally identifiable information associated with your Account, you may make such changes by logging in to Revolo Apps. If you do not want your information accessed or stored as described in this Policy, you should not access, use, or register an Account with Home Services.
You assume total responsibility and risk for your use of the Site and the Internet. In no event shall Revolo be liable for any damages whatsoever, and in particular Revolo shall not be liable for special, indirect, consequential, or incidental damages, or damages for lost profits, loss of revenue, or loss of use, arising out of or related to any Revolo Site, or the information contained in it, whether such damages arise in contract, negligence, tort, under the statute, in equity, at law or otherwise. You also understand that Revolo cannot and does not guarantee or warrant that files available for downloading through the Service will be free of infection or viruses, worms, Trojan horses, or other code that manifest contaminating or destructive properties. You are responsible for implementing sufficient procedures and checkpoints to satisfy your particular requirements for accuracy of data input and output, and for maintaining a means external to the Site for the reconstruction of any lost data. Revolo does not make any express or implied warranties, representations, or endorsements whatsoever (including without limitation warranties of title or non-infringement, or the implied warranties of merchantability or fitness for a particular purpose) with regard to the Site, any merchandise, information, or Service provided through the Site or on the Internet generally, and Revolo shall not be liable for any cost or damage arising either directly or indirectly from any such transaction. It is solely your responsibility to evaluate the accuracy, completeness, and usefulness of all opinions, advice, services, merchandise, and other information provided through the Site or on the Internet generally. Some jurisdictions do not allow the exclusion of implied warranties, so the above exclusion may not apply to you.
You agree to indemnify, defend and hold harmless Revolo, its officers, directors, employees, agents, licensors, suppliers, and any third-party information providers to the Site from and against all losses, expenses, damages, and costs, including reasonable attorneys' fees, resulting from any violation of this Agreement or any activity related to your submissions to the Site (including negligent or wrongful conduct).
We will occasionally update this Policy. We recommend that you check our Revolo Services from time to time to inform yourself of any changes in this Policy or any of our other policies.
Please refer to the Federal Trade Commission's website at http://www.ftc.gov/bcp/menus/consumer/data. site for information on how to protect yourself from identity theft. You should be careful to maintain the secrecy of your user ids and passwords and/or account information and be responsible for protecting your Personal Identity Information and identity, both online and offline.
If you have questions or concerns about our privacy practices, please email us at: email@example.com