KONE Elevator Call App Privacy Statement

This privacy statement describes how KONE Corporation (including its subsidiaries, partners, and its affiliates, hereinafter "KONE") processes your personal data when offering the KONE Elevator Call services (the “KONE Services”) and KONE Elevator Call mobile app (the “App”) solely for your convenience and use of the KONE Services at the designated building(s) (the “Building”). The scope of the KONE Services made available in the Building is depending on the contract KONE has concluded with the Building’s facility manager, owner or tenant (the “Manager”). For more information about the KONE Services available in the Building, please contact the Manager.

User Profile

The following data is always integrated from the Building access management system to enable the use of the KONE Services and the App:

• Name (first name and family name)
  
• Email
• Access profile (i.e., the access rights granted to you in the Building access management system, such as the floors to which you have been granted access rights to)
  
• Phone number (this is not mandatory but can be selected to be integrated from the Building access management system by the Manager)
  
• Timestamp and version number of your approval of legal documents (like this Privacy Statement or App Terms & Conditions)

Your User Profile may also include information on which optional functionalities of the provided KONE Services you are allowed to use (e.g., whether you are allowed to use VIP elevator call or create visitor invitations and what kind of access rights you may grant to such visitors).

KONE will also store the password you create for your User Profile in an encrypted format to be able to allow your future sign-in to the App.

Access ID

You will be generated a unique Access ID number for each of the methods you are using the KONE Services with – the App being one of those. Other methods made available to you can include e.g. electronic key card. All the Access IDs granted to you are attached to your User Profile, and thus, reveal your identity.

Preference Data

The following data about your preferences can be added by you in the App:

• Frequent floor(s) (a floor that you often visit and want to thus store to the App)

The following data about your preferences will be automatically generated through your use of the App:

• Start floor (the App will remember the last floor to which you made an elevator request to and suggest it as the starting floor the next time you use the App)

Feedback and Log Data

You may select to send KONE feedback or log data through the App. If you select to do so, KONE will receive the written text you have included in your feedback, as well as your App user log (i.e., technical data and time stamps on the operations of the App) in identifiable format.

Log Data – Elevator Calls and Access Points

KONE collects the log data about the elevator calls made with each Access ID, including elevator calls made with the App. Such access log includes the timestamp, the start and destination floors and your Access ID, which can be linked to your identity through your User Profile.

In some Buildings, besides the access points available by the elevators, there may be other access points that are utilizing the KONE Services, including gates, turnstiles, or automatic doors. Similar log data is collected of the use of such other access points (i.e., log consisting of the timestamp and the Access ID used on the respective access point).

Log Data – Application Use

KONE is by default collecting anonymous log of all functionalities used within the App and by the App.

Such data is generated automatically when you use the App and includes device description, model and operating system (of the device you are using the App with) and basic information about usage of the App (e.g., login and logout time, time spent using the App, most popular functionalities). You may select to also send these kinds of logs to KONE in identifiable format when sending Feedback (see subsection iv (Feedback) above).

Contacts

If you use the App in a Building where the provided KONE Services include functionality to create visitor access keys, and your User Profile has been granted the right to create visitor invitations, you may grant the App access to the contact information stored on your mobile device to be able to quickly select from your contacts the person to whom you want to send the visitor invitation. Only the contacts you select will be transferred to the App and through the App to KONE. I.e., KONE will not receive access to or copy of your mobile device’s full contact list.

Geofence Triggering

If you use the App in a Building where the provided KONE Services include a geofence triggering functionality, please note the following data protection related aspects:

• To enable the Geofence Triggering, your mobile devices Bluetooth and GPS needs to be turned on.
• The App will use the location data to recognize when you enter the geofenced area. This will trigger the Application to automatically be turned on and make an elevator call to the relevant floor you are in. The floor information is generated based on the geofence trigger. KONE is not by default collecting the location data. Log collection of the elevator call takes place as presented above in subsection v (Elevator Calls and Access Points).

Unless otherwise informed to you, KONE is always the data controller for personal data processing related to the App as described in this Privacy Statement. However, please note that as the User Profile data is directly integrated to KONE data systems from the Building’s access management system, KONE is acting as data controller in regards to the data management actions taken within KONE’s own IT systems and KONE’s own sphere of influence. The Manager, or a party designated by the Manager, is responsible for the accuracy, correctness, and legality of the initial collection of the User Profile related personal data and transfer of this data to KONE. Moreover, any changes to your User Profile require action from the Manager.

KONE may also transfer the personal data described above in Section 2 to the Manager. The Manager shall be independently responsible as a parallel data controller of its processing of the relevant personal data after such disclosure. You may request the Manager for more information of any such personal data processing.

Processing of personal data is based on KONE’s legitimate interests related to the purposes defined below.

The purpose of collecting and processing of the personal data is to be able to provide the App and KONE Services for your use in the Building. This includes enabling the functioning of the App and your use of KONE equipment with the App; analyzing and correcting any possible defects in the App, KONE Services or KONE equipment; and monitoring and ensuring the security of the App, KONE Services, KONE equipment, the Building and personal data. As part of these actions, KONE may also use the data to contact you. KONE may also use the data to contact you to receive further feedback or information from you (e.g., for incident management purposes) or to provide you guidance on usage of the KONE Services or relevant information about updates, service breaks or issues relating to the KONE Services.

Processing of personal data may also be performed for purposes of ensuring Building security and safety; for identity and credential management, such as verification and authentication; for detecting, analyzing and resolving security threats; and for fraud detection and prevention.

In certain circumstances, KONE may process the personal data to de-identify or re-identify the data with or from the user; to make back-up copies for business continuity and disaster recovery purposes, and for corporate governance, including mergers, acquisitions, and divestitures.

Furthermore, KONE may process personal data for the analysis of how the App and KONE Services are being used to enable product, service, and application development. From time to time, KONE may also need to process personal data for the purposes of internal auditing, analysis, reporting (e.g., security audits), or certifications (e.g., ISO certificates). KONE will anonymize the personal data before conducting the above-described actions when possible.

As allowed or required by applicable laws, KONE may process personal data in legal and administrative proceedings or for compliance, e.g., for fulfilling a request for a resolution or information by authorities, in submissions for court, or for the establishment, exercise or defense of legal claims.

Processing of personal data is necessary for KONE to be able to provide you the App and for you to use KONE equipment and KONE Services in the Building with the App. If you do not approve of the collection and use of personal data or have requested KONE to stop the processing of your personal data, you may not use the App anymore, and you shall remove the App from any devices where you have installed it. In most cases, you can still use KONE equipment in the Building with alternative means (e.g., a key tag), but some elements of the KONE Service may not be available to you anymore. You may request more information of your options from the Manager.

If you enter any information concerning another natural person than yourself into the App, you must ensure you have received such other person’s consent to do so before entering the information into the App. You are not allowed to add personal data of a child under 16 years to the App unless you are the holder of parental responsibility of the child in question.

KONE will store other personal data than Log Data until you inform KONE that you wish to stop using the App or KONE otherwise can verify you have ceased to use the App (e.g., the App has been inactive for an extensive period of time, or the User Profile is deleted from the Building’s access management system). Personal data can be also deleted by KONE if the KONE Services are no longer provided in the Building.

KONE shall not retain the Log Data more than one (1) year from the collection of such data.

In case personal data is processed for the establishment, exercise, or defense of legal claims or for legal compliance, personal data is retained as long as necessary to resolve the case or demonstrate compliance, and thereafter the data is archived and retained as required or allowed by applicable laws and regulations.

However, KONE or the Building owner or manager may delete the user account or specific access permissions already earlier if you are no longer allowed to access the Building, or the KONE Services / the App is no longer in use in the Building.

KONE may use reliable subcontractors’ services when processing personal data for the above-mentioned purposes. To the extent such subcontractors have access to personal data or host personal data, KONE shall conclude agreements with the subcontractors to oblige the subcontractors to use the personal data only to the extent described in this Privacy Statement, and commit subcontractors to other relevant confidentiality, data privacy, and data security obligations.

KONE may transfer personal data to its affiliates and subsidiaries and to the Manager.

The transfer of personal data between i) KONE and the Manager; ii) KONE and a subcontractor; or iii) their affiliates and subsidiaries for the purposes of performing the services does not constitute the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic means the personal data for monetary or other valuable consideration.

Due to technical and practical requirements, some of the personal data is processed outside the country where the Building is located (including outside the EU/EEA area) by the subcontractors, Manager, or KONE companies. KONE ensures that there is a legal basis for such transfers. You can get more information about the data transfers by contacting KONE.

Your personal data may be disclosed to public authorities in situations where the applicable local law explicitly demands and allows for KONE to do so.

If you are using the functionality to create visitor invitation, your name and e-mail will be disclosed to the visitor to whom you are sending the invitation.

You have a right to review the personal data collected on you, right to have incorrect personal data corrected and right to request deletion of personal data. Depending on the applicable law, you may also have a right to object to processing based on a specific individual circumstance and request data portability. You may use some of these rights through the App. If this is not possible, you may use these rights by contacting the Manager or KONE:

KONE Corporation

KONE Building

Keilasatama 3, 02150 Espoo, FINLAND

Telephone: +358 204 751 Attention: Data Protection Counsel, Legal Affairs, personaldatarequest@kone.com

In any requests relating to the User Profile, please contact the Manager first, before contacting KONE.

In the event you have concerns or remarks regarding legality of personal data processing, you may lodge a complaint with a competent local data protection supervisory authority or pursue to enforce your legal rights in the absence in jurisdictions without such data protection supervisory authority.