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1. Introduction
Airelay ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our smart lock management system and related services.
Your Privacy Matters: We are committed to transparency about our data practices and protecting your personal information. This policy describes how we handle your data when you use our smart lock management services.
2. Information We Collect
2.1 Information You Provide
We collect information you provide directly to us, including:
- Account Information: Email address, name, and contact details when you create an account
- Device Information: Smart lock device IDs, names, and configuration settings
- Access Codes: Temporary access codes generated for authorized users
- Reservation Data: Guest information, check-in/check-out dates, and property details
- Communication: Messages and support requests you send to us
2.2 Information We Collect Automatically
When you use our service, we automatically collect:
- Device Status: Online/offline status, connectivity information, and device health data
- Access Logs: Timestamps of lock/unlock events, access attempts, and user interactions
- System Logs: Error messages, performance metrics, and system events
- Usage Data: How you interact with our web interface and API endpoints
- Technical Information: IP addresses, browser type, device type, and operating system
2.3 Information from Third Parties
We may receive information from:
- Shelly Cloud: Device status and configuration data through their API
- Email Services: Delivery status and bounce information for notifications
- Analytics Services: Aggregated usage statistics and performance metrics
3. How We Use Your Information
We use the information we collect to:
| Purpose |
Information Used |
Legal Basis |
| Provide smart lock management services |
Device data, access codes, reservation info |
Contract performance |
| Send notifications and alerts |
Email address, device status, access logs |
Legitimate interest |
| Monitor system performance |
System logs, error messages, usage data |
Legitimate interest |
| Provide customer support |
Account info, communication history |
Contract performance |
| Improve our services |
Usage patterns, feedback, analytics |
Legitimate interest |
| Ensure security and prevent fraud |
Access logs, IP addresses, device status |
Legitimate interest |
4. Information Sharing and Disclosure
4.1 We Do Not Sell Your Data
We do not sell, rent, or trade your personal information to third parties for marketing purposes.
4.2 When We May Share Information
We may share your information in the following circumstances:
- Service Providers: With trusted third-party service providers who help us operate our service (email delivery, hosting, analytics)
- Legal Requirements: When required by law, court order, or government request
- Safety and Security: To protect the safety and security of our users, properties, or the public
- Business Transfers: In connection with a merger, acquisition, or sale of assets
- With Your Consent: When you explicitly authorize us to share your information
Important: We may share aggregated, anonymized data that does not identify individual users for research, analytics, or business purposes.
5. Data Security
We implement appropriate technical and organizational measures to protect your information:
- Encryption: Data is encrypted in transit and at rest using industry-standard protocols
- Access Controls: Strict access controls and authentication mechanisms
- Regular Audits: Security assessments and vulnerability testing
- Employee Training: Regular security training for our team
- Incident Response: Procedures for responding to security incidents
Your Responsibility: You are responsible for maintaining the security of your account credentials and access codes. Never share your passwords or access codes with unauthorized individuals.
6. Data Retention
We retain your information for as long as necessary to provide our services and comply with legal obligations:
6.1 Retention Periods
- Account Information: Retained while your account is active and for 2 years after deactivation
- Access Logs: Retained for 1 year for security and audit purposes
- Device Status Data: Retained for 6 months for monitoring and troubleshooting
- Reservation Data: Retained for 3 years for business records
- System Logs: Retained for 90 days for technical support
6.2 Data Deletion
You may request deletion of your personal information by contacting us. We will delete your data within 30 days, except where retention is required by law or for legitimate business purposes.
7. Your Privacy Rights
Depending on your location, you may have the following rights regarding your personal information:
7.1 Access and Portability
You can request access to your personal information and receive a copy in a portable format.
7.2 Correction and Updates
You can request correction of inaccurate or incomplete information.
7.3 Deletion
You can request deletion of your personal information, subject to legal and business requirements.
7.4 Restriction and Objection
You can request restriction of processing or object to certain uses of your information.
7.5 Withdrawal of Consent
Where processing is based on consent, you can withdraw consent at any time.
Exercise Your Rights: To exercise any of these rights, please contact us using the information provided at the end of this policy.
8. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your experience:
8.1 Types of Cookies
- Essential Cookies: Required for basic functionality and security
- Performance Cookies: Help us understand how you use our service
- Functional Cookies: Remember your preferences and settings
8.2 Cookie Management
You can control cookies through your browser settings. However, disabling certain cookies may affect service functionality.
9. International Data Transfers
Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for such transfers, including:
- Standard contractual clauses approved by data protection authorities
- Adequacy decisions for certain countries
- Other appropriate safeguards as required by law
10. Children's Privacy
Our service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we have collected information from a child under 13, please contact us immediately.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by:
- Posting the updated policy on our website
- Sending email notifications to registered users
- Displaying prominent notices in our service
Your continued use of our service after changes become effective constitutes acceptance of the updated policy.
13. Complaints
If you have concerns about our data practices, you may:
- Contact us directly to resolve the issue
- File a complaint with your local data protection authority
- Seek legal remedies as provided by applicable law