Effective Date: December 31, 2019

This Privacy Policy describes the privacy practices of KeyMe, LLC ("KeyMe", "we", "our" or "us") in connection with consumer’s use of our mobile application (the "Application"), key duplication kiosks (the "Kiosks"), on www.key.me (the "Site") and the services, features, content or applications we offer (collectively with the Application, the Kiosks, and the Site, the "Services").

What Information Do We Collect?

INFORMATION YOU PROVIDE TO US:

• Contact information, such as your first and last name, email and mailing addresses, and phone number. Note that personal information such as names and mailing addresses are purged after a key copy mail order is fulfilled.
• Payment details, such as the last 4 digits of your payment card number..
• Fingerscan minutiae if you choose to use this method to authenticate yourself at a Kiosk.
• Transaction history, such as details of your purchases at Kiosk, via the Application, or over the phone.

INFORMATION WE OBTAIN FROM SOCIAL MEDIA PLATFORMS:

We may maintain pages for Key.me on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

INFORMATION WE OBTAIN FROM OTHER THIRD PARTIES:

We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

COOKIES AND OTHER INFORMATION COLLECTED AUTOMATICALLY:

We, our service providers, and other third parties may automatically receive and record information about you, your computer or mobile device, and activity occurring on or through the Site or Application. Our service providers and third parties may collect this type of information over time and across third-party websites and mobile applications. This information may include:

• Information about your device’s hardware, such as model and screen resolution
• Information about the software on your device, such as your browser type
• Unique identifiers associated with your device, such as device identifier (e.g., Google Advertising ID or Apple ID for Advertising)
• Information about the network to which you are connected and inferences we may draw from it, such as your IP address and general location information such as city, state or geographic area
• Information about your use of and actions on the Site or Application, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, links you access, access times, and length of access; and the website that referred you to the Site, if applicable
• Information about your interaction with our emails, such as whether you opened our email and how long you had it open

How Do We Use Personal Information?

We use personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

• To operate the Services, including to:
  
  • provide, operate and improve the Services, including to develop new products and services
  • establish and maintain your user profile on the Services
  • identify you and to authenticate your account using your fingerscan minutiae (if you have chosen to provide it to us) when you use the Kiosk
  • enable security features of the Services, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in
  • communicate with you about our products and services, including by sending you announcements, updates, security alerts, and support and administrative messages, and responding to your requests, questions, and feedback
  • understand your needs and interests, and personalize your experience with the Services and our communications
• To send you marketing and promotional communications. We may send you Key.me-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the “Opt out of marketing communications” section below.
• To display advertisements. We work with advertising partners to display advertisements online outside of the Services. These advertisements are delivered by our advertising partners and may be targeted based on your use of the Services or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Targeted online advertising.”
• To comply with law, for compliance, fraud prevention, and safety. We use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to (a) comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) enforce the terms and conditions that govern the Service; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

How Do We Share Personal Information?

We do not share your personal information with third parties without your consent, except in the following circumstances or as described in this Privacy Policy:

• Service providers. We employ and contract with people and other entities that perform certain tasks on our behalf or help us operate the Service (such as customer support, payment processing, hosting, analytics, email delivery, marketing, and database management services). We authorize these service providers by contract to use your personal only to perform services for us or on our behalf.
• At your direction. You may direct us to share your information with third parties via our Services. For example, you may use the Services to connect with an independent locksmith.
• For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
• Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

What Security Measures Do We Use?

We employ a number of safeguards designed to protect the information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of any information we collect or maintain.

Biometric Data Retention

KeyMe will retain your fingerscan minutiae only until the earlier of the time that you delete your account, or within 3 years of your last interaction with KeyMe. You may also email support@key.me to request that we remove your fingerscan minutiae from our databases.

What Choices Do You Have Regarding Your Information?

• Access, update, and delete your information. If you are a registered user, you can access and update certain information associated with your account by logging into the Services. You can delete your account by emailing support@key.me.
• Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at support@key.me. You may continue to receive service-related and other non-marketing emails.
• Cookies & Browser Web Storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
• Location data. Your may adjust your mobile device settings to authorize or prevent the sharing of your location data with the Application.
• Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Service may be members of organizations or programs that provide choices to individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising. Users may opt out of receiving targeted advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here.

Users of our Application may opt out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available here, and choosing to opt out within the app. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.

In addition, your mobile device settings may provide functionality to limit our, or our partners’, ability to engage in ad tracking or targeted advertising using the Google Advertising ID or Apple ID for Advertising associated with your mobile device.

If you choose to opt out of targeted advertisements, you will still see advertisements online but they may not be relevant to you.

• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites, Mobile Applications, and Services

The Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you by posting an announcement on the Services or sending you an email.
Except where otherwise required by applicable law, any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Services (or as otherwise indicated at the time of posting). In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Job Applicants

When you visit the careers portion of our website, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics. We may also use this information to communicate with you, and as otherwise necessary for compliance, fraud prevention, and safety purposes, as further explained in the “How Do We Use Personal Information?” section below.

How to Contact Us

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@key.me. We will make every effort to resolve your concerns.

Additional Information for California Residents

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of the personal information.

PERSONAL INFORMATION THAT WE COLLECT, USE, AND SHARE

We do not sell personal information. As we explain in this privacy policy, we use cookies and other tracking tools to analyze website traffic and facilitate advertising. If you would like to opt out of our (and our third party advertising partners’) use of cookies and other tracking technologies, please review the instructions provided in the Online Tracking Opt-out Guide.

Here is a summary of how we currently collect, use and share personal information, and how we have collected used and shared the information in the preceding 12 months.

Personal information we collect	CCPA categories (Definitions are available here)	Sources of personal information	Purposes for which we may collect and use personal information	Categories of third parties to which we disclose personal information
Contact information, Payment information	Identifiers Commercial information Financial Information	You	Service delivery Marketing Compliance & Operations	Service providers With partners, at your direction
Fingerscan minutiae	Biometric Information	You	Service delivery Compliance & Operations
Usage information Information about your device’s hardware and software Unique identifiers associated with your device IP address Demographic information General location information, such as city, state, or geographic area Inferences drawn from device data and online activity data	Unique Identifiers Commercial Information Internet or Network Information Geolocation Data Inferences	You Automatic collection	Service delivery Marketing Compliance & Operations	Advertising partners Service providers

Please note that we may also disclose personal information to comply with law, and for compliance, fraud prevention, and safety purposes; in the event of business transfers; and to our professional advisors, as further described above in the “How Do We Share Personal Information?” section.

CALIFORNIA RESIDENTS' PRIVACY RIGHTS

The CCPA grants California residents the following rights.

• Information. You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.
• Access. You can request a copy of the Personal Information that we maintain about you.
• Deletion. You can ask us to delete the Personal Information that we collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

You are entitled to exercise the rights described above free from discrimination.

How to make a request. To request access to or deletion of personal information:

• call 1-855-343-5776
• email support@key.me

Identity verification. CCPA requires us to verify the identity of the individual submitting the request before providing a substantive response to the request.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.