Privacy Policy

Revised: November 1, 2019

We at Janus International Group, LLC (“Janus”, “JIG”, “we”, “us”, or “our”) take the privacy of all visitors (“you” or “your”) to our websites and Noke® Smart Entry applications very seriously.  This privacy policy (“Privacy Policy”) informs you how Janus handles privacy matters and how we process your Personal Data.

This Privacy Policy covers all Janus websites, products and services, and the data that is shared by a visitor with us, whether directly via www.janusintl.com, (collectively, the “Site(s)”), the Noke® Smart Entry system, including the mobile app (“Mobile App”), or via email.  This Privacy Policy provides an explanation as to what happens to Personal Data that you share with us, or that we collect from you either directly via these Sites or via email. By using the Sites, you agree to the terms and conditions of this Privacy Policy. This Privacy Policy applies to the data collected by us, or those working on our behalf, through information you enter or from the data imported from authorized and approved sources. It does not apply to data collected through other websites, products, or services not approved by us. By using or accessing our Website or the Services in any manner, you acknowledge that you accept the practices and policies described in this Privacy Policy (and as updated from time to time), and you hereby consent that we may collect, use, and share your information as described herein. If you do not agree with our policies and practices, your choice is not to use our Sites or Mobile App. Your use of the Sites or Mobile App is at all times subject to our Terms of Use (available at janusintl.com/termsofuse (the “Terms”), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms

Table of Contents

Information We Collect

Information Received from Customers through Our Services

Information Received from the Noke® Smart Entry Application

Use of Cookies

Use of Personal Data

Sharing and Disclosure

Storing your Personal Data/Transfer of Data

Third Party Links

Individual Rights – Actions You Can Take

Security

Sensitive Data

Our Policy on Children’s Information

Policy Changes and Contact Us

Information We Collect

While using our Sites or Mobile App, you may provide us with certain Personal Data of our customers, employees of our customers using our app, or tenant data that can be used to contact or identify you. This Privacy Policy covers our treatment of personally identifiable information. This is information which may be connected to you specifically as the individual to whom the information relates. Such information may include name, mailing address, email address, telephone number, or any other information defined as personally identifiable information (or similar term) by applicable law. For this Privacy Policy the definition of “Personal Data” is the definition under the law applicable to the person whose data is collected. If the Personal Data is that of a European citizen or resident, the definition of personal data is defined under GDPR, so, please see the section toward the end of this Privacy Policy. If the Personal Data is that of a California resident, the definition is as provided under California law. Personal Data does not include your personally identifiable information that has been deidentified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (the foregoing in this sentence being referred to as “De-Identified Personal Data”).

Personal Data we collect from our Sites and Mobile App may include, but is not limited to:

• Tenant identification information
• Name (first & last)
• Mobile phone number
• Email address

• Geolocation information, when opted in

Other related data we may collect may include, but is not limited to:

• Tenant unique identifier for the tenant (that the PMS system generates and uses)
• Tenant unit number
• Activity associated with that unit
  • Note: Shared Key (we obtain the same information for anyone the “Master” tenant has shared their digital key with)
• Unit identification information
• Unit unique identifier (that the PMS system generates and uses)
• Last Updated
• Unit status - available, rented, overlocked, auction
• Unit name (usually an alphanumeric number associated with the unit)

Information Collected Automatically

Like many Sites, we and our third-party service providers, such as advertising and analytics providers, use cookies, web beacons and other data technologies to receive and store certain types of information when you interact with us through your computer or mobile device.  Using these technologies helps us recognize you, customize your experience and make relevant marketing messages.  Here are the types of information we collect:

• Log & Device data. When you visit our Site, we may automatically record information (“log data”), including information that your browser sends whenever you visit our Site. This log data may include your web address you came from or are going to, your device model, operating system, browser type, unique device identifier, IP address, mobile network carrier, time zone and location.
• Our third party service providers may provide us information that tells us how marketing ads, often placed on third party Sites, performed and who clicked on them. This information does not identify any specific individual and is generally non-identifying. If we were to associate it with you we would treat it as Personal Data.

Information Received from Customers Through Our Services

We receive data from our customers through our storage facility-related services.  We process this data pursuant to a contract in place with our customers. The use of information processed through these services shall be limited to the purpose of providing the service for which the customer has engaged Janus.  We process Personal Data at the direction of our customer and we generally have no direct relationship to the tenants whose Personal Data we receive on behalf of our customers. See below about your choices and access rights related to this data.

Information Received From the Noke® Smart Entry Application

We receive data from our customers’ employees, tenants, and certain company managers who use our Noke® Smart Entry app.  We process this data pursuant to a contract in place with our customers. The use of information processed through our service shall be limited to the purpose of providing the service for which the customer has engaged Janus. See below about your choices and access rights related to this data.

Use of Cookies

Our Sites use “cookies” (a small text file sent by your computer each time you visit our Site) or similar technologies to record log data. Many browsers default to accepting cookies.  You may be able to change this setting in your browser and you can also clear your cookies.  If you do, you may lose some functionality of our Site.  Check your browser’s help function to learn more about your cookie setting options.

For information on how Janus handles cookies for individuals outside the United States, click here: https://janusintl.co.uk/cookie-policy/. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For more information on how to opt-out of third-party advertiser tracking mechanisms, please click here.

We may use the following types of cookies:

• Advertising and analytics
• Essential cookies
• Functionality cookies
• Advertising cookies
  • Please see below for your choices on cookies in the use of advertising.
• To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails from us.  Please see the Your Choices section below.
• We might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address from the device which you loaded the page, the browser type. Pixel tags are also used by our third parties to collect information when you visit our Site, the links and other actions you take on our Site, and we may use this information in combination with cookies to display targeted advertisements.
• Other data technologies may be used that collect comparable information for security and fraud detection purposes.

If you have any questions about cookies or to generally find out more about cookies, visit allaboutcookies.org.

Use of Personal Data

We may use your Personal Data as described below: 

• Marketing and Communications:
  • To provide you with information requested from us relating to our products or services and to provide information on other products which we feel may be of interest to you if you have consented to receive such information, which are legitimate business interests.
  • To notify you about any changes to our Sites, such as improvements or service/product changes, that may affect our service.
  • If you are an existing customer, we may contact you with information about services similar to those already purchased.
  • If you do not want us to use your data for ourselves, you will have the opportunity to withhold your consent to this when you provide your details to us on the form on which we collect your data.
  • We will use Personal Data to communicate with you with your consent, to manage our contractual relationship with you and/or because we have a legitimate interest to do so.
• Deliver the product/service and customer support
  • We will use Personal Data to provide you or our customer’s access to the Noke® Smart Entry app. We use your Personal Data to provide you customer support.  We use Personal Data to manage our contractual relationship with you and/or because we have a legitimate interest to do so.  If you do not provide the data that we request, or prohibit us from collecting such data, we may not be able to provide the requested Services.
• Business Purposes:

• We use Personal Data to analyze our product and services, as well as the Sites, and to perform audits, security and fraud monitoring and prevention.  We also use Personal Data to develop new services, enhance, improve or modify our existing service, identify usage trends, determine the effectiveness of our marketing efforts, and to operate our business. We use Personal Data as described to manage our contractual relationship with you, comply with a legal obligation and/or because we have a legitimate interest to do so.
• To process transaction payments (including, but not limited to, service fees, membership dues and subscriptions, registration fees, voluntary contributions, and payments, refunds and reimbursements for any products or services that you choose to purchase from us).
• To ask for anonymized ratings and reviews of the Mobile App and/or the products or services that we offer to you.  
• In any other way we may describe when you provide the information or to fulfill any other purpose for which you provide it.

Sharing and Disclosure

We do not share your Personal Data with others except as indicated within this Privacy Policy or when we inform you and give you an opportunity to opt out of having your Personal Data shared.

We share your Personal Data in the following ways.

• With third party service providers, agents, or contractors.  We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with providing services to you. For example, we may engage Service Providers to process credit card transactions or other payment methods.  Or, we may engage Service Providers to provide services such as marketing, advertising, communications, infrastructure and IT services, to provide customer service, to collect debts, and to analyze and enhance data (including data about users' interactions with our service). These Service Providers may have access to your personal or other information in order to provide these functions. In addition, some of the information we request may be collected by third party providers on our behalf. We do not authorize them to use or disclose your personal information except in connection with providing their services.
• Analytics.  Specifically, for analytics providers, we use Google Analytics which is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Site available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/  Google also recommends installing the Google Analytics Opt-out Browser Add-on, available at  https://tools.google.com/dlpage/gaoptout,  for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

• Advertising.  We may use third-party Service Providers to show advertisements, which may include targeted advertisements on a third-party Site after you have visited our website.  We and the third-party service providers use cookies to inform, optimize, measure performance serve ads based on your previous visits to our Site.  Any tracking that a third party performs is subject to their own privacy notice.

Please note that at this time we do not recognize automated browser signals regarding tracking mechanisms, which may include "do not track" instructions.

We work with Google AdSense & DoubleClick Cookie Google, as a third-party vendor, uses cookies to serve ads on our Site. Google's use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Site or other websites on the Internet. You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads Settings web page: http://www.google.com/ads/preferences/.

Google AdWords/Analytics

Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page at  http://www.google.com/settings/ads.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page at http://www.google.com/intl/en/policies/privacy/.

Twitter: You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405 You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page at  https://twitter.com/privacy

Facebook: You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook's interest-based ads follow these instructions from Facebook at https://www.facebook.com/help/568137493302217. To see more about Facebook’s participation in the Digital Advertising Alliance please visit the Choices section of this Facebook website page. 

For more information on the privacy practices of Facebook, please see Facebook's Data Policy at https://www.facebook.com/privacy/explanation.

To comply with legal process or to protect Janus  

Except as otherwise described in this Privacy Policy, we will not disclose your Personal Data to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website, our Services, or any software we provide related thereto; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our Services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

• It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your Personal Information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.
• Business Transfers. : You consent to our disclosure of your Personal Information and other information to a potential or actual buyer of our company or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or other court proceeding, in which Personal Information held by us is among the assets transferred. You agree to and do hereby consent to (and shall not object to) our assignment, conveyance, transfer, and/or license (whether by contract, merger or operation of law) of any or all of our rights to your Personal Information and your consents, in whole or in part, and other information, with or without notice to you and without your further consent.

Storing your Personal Data/Transfer of Data

This Site is operated in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using this Site and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may be more, or less, comprehensive as those in other countries such as the European Union.  Our Service Providers use appropriate safeguards to transfer your Personal Data to the United States.

• We may transfer Personal Data that we collect from you to locations outside of headquarters for processing and storing. In addition, it may be processed by staff operating outside the office area who work for us or for one of our suppliers. For example, such staff may be engaged in the processing and concluding of your order, the processing of your payment details and the provision of support services. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take commercially reasonable steps to make sure that your Personal Data is treated securely and in accordance with this Privacy Policy.
• Personal Data that is provided to us is stored on our secure servers and/or those of our Service Providers. Details relating to transactions entered into via our Site will be encrypted to ensure its safety.
• The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and the transmission of such data is entirely at your own risk. Where we have given you (or where you have chosen) a password so that you can access certain areas of our Site, you are responsible for keeping this password confidential.
• The safety and security of your information also depends on you. You should maintain good internet security practices. Where you have password-protected access to certain parts of the Site or Mobile App, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If your email account or Facebook account is compromised this could allow access to your account with us if you have given us those details and/or permitted access through those accounts. If your email account is compromised it could be used to ask us to reset a password and gain access to your account with us. If you think that any of your accounts have been compromised you should change your account credentials with us, and in particular make sure any compromised account does not allow access to your account with us. The information you share in public areas may be viewed by other users. We’ll never email you to ask for your password or other account login information. If you receive such an email, please send it to us so we can investigate

Third party links

We may have links on our Site to other websites that we do not operate.  If you click on a third-party link, you will be taken directly to that website which is governed by its own privacy notice.  We strongly encourage you to read that privacy notice.  We do not control that website and assume no responsibility for the content, policies or its practices.

Data Retention

The time periods for which we retain your Personal Information depend on the purposes for which we use it. We will keep your Personal Information for as long as your account is active, or as long as you are a registered account holder or user of our Site or Mobile App or for as long as we have another business purpose to do so and, thereafter, for no longer than is required or permitted by law, or our records retention policy, reasonably necessary for internal reporting and reconciliation purposes, or to provide you with feedback or information you might request. This period of retention is subject to our review and alteration.

Following termination or deactivation of your account, we may retain your profile information and all information posted to public areas of the Site. Following termination or deactivation of your account, we may retain your Personal Data and other data, but will maintain it as confidential according to the Terms, this Privacy Policy, and as required by applicable law. We have the right to delete all of your Personal Data and other data after termination of your account without notice to you. We may retain De-Identified Personal Information for as long as we choose.

Your California Privacy Rights

Online Privacy Protection Act (“CalOPPA”)

Under California Civil Code Sections 1798.83-1798.84 (known as the “Shine the Light” law), California residents are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties with whom the business has shared such information during the immediately preceding calendar year. To make such a request, please contact us with “Request for California Privacy Information” in the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. To obtain information under CalOPPA from us, please contact us, or, see more at the CalOPPA website here.

Notices; Opting Out

By providing us with your email address (including by “following,” “liking,” linking your account to our Service or other services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices by email, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity related to our Site or Mobile App to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your opt-out request or by clicking “unsubscribe” at the bottom of our e-newsletter. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.

You can add, update, or delete information as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records. You may request deletion of your account by emailing us. It is your responsibility to maintain your current email address with us.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your Personal Data against loss, theft and unauthorized access, use and modification. Unfortunately, no measures can be guaranteed to provide 100% security. Accordingly, we cannot guarantee the security of your information.

Sensitive Data

We request that you do not send us any sensitive data such as social security or national identification numbers, information related to racial or ethnic origin, political opinions, religious beliefs, health data, biometrics or genetic, criminal background or trade union membership information. If you do send us this information, then you are consenting to its processing in accordance with this Privacy Policy.  To avoid processing of sensitive data, please do not submit it.

Our policy on children’s information

Our Site is not directed to children under 16. In the event that we learn that we have collected Personal Data from a child under age 16 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. If you learn that your minor child has provided us with Personal Data without your consent, please contact us.

Contacting us

We welcome any queries, comments or requests you may have regarding this policy please do not hesitate to contact us at legal@janusintl.com. If you would prefer to write to us, our contact address is:

135 Janus International Blvd.

Temple, GA 30179

Attn: Legal

Toll Free: (866) 562-2580

Phone: (770) 562-2850

The Following Provisions Apply Only to Citizens and Residents of the EEA and Switzerland

The following provisions apply to you only if you are a European or Swiss citizen or resident. If you are a European citizen or resident of the European Economic Area (“EEA”), Switzerland, or other regions with laws governing data collection and use that may differ from the laws in the United States, please note that we may transfer your Personal Data to a country or jurisdiction that does not have the same data protection laws as your jurisdiction. We may do so to process your Personal Data by staff operating outside the EEA who works for us or for one of our service providers. Under the European Union’s General Data Protection Regulation[1] (GDPR) and other countries’ privacy laws, you may have certain rights with respect to the processing of your Personal Data. These rights include:

• Choosing not to provide your Personal Data
• Accessing, or obtaining a copy of, your Personal Data
• Checking and editing your data in your user account
• Unsubscribing from direct marketing
• Checking and editing your Personal Data
• Blocking and deleting the cookies
• Permitting or refusing processing of your location data
• Erasure, or restriction of our processing, of your data
• Objecting to the processing of your Personal Data
• Withdrawing your consent
• Porting your data to another controller
• Lodging a claim the supervisory authority
• Data collected directly by our customers at storage locations

We strive to ensure that the Personal Data we possess are always accurate and therefore we encourage you to update your information in your own account in case any changes have occurred. We have listed below the rights that you may be able to exercise in respect of the processing of your Personal Data, subject to applicable law. We take commercially reasonable step to ensure that the Personal Data that we process are limited to the Personal Data that are reasonably required in connection with the purposes set out in this Privacy Policy.

For purposes of GDPR, and wherever applicable throughout this Privacy Policy, Janus is the data controller collecting Information from the Sites. We can be contacted at legal@janusintl.com.

Please note that upon exercising any of the rights listed below, you may be requested to provide additional information for identification purposes. Such additional information shall not be used for any other purpose and will be removed after successful identification.

• Providing your data: You may choose not to provide your Personal Data to us. It should be noted that some features of our websites, applications and other services may not be fully available to you if you choose not to provide us with your Personal Data (e.g., we may not be able to process your orders without the necessary details).
• Right of access: You may have the right to request access to, or copies of, your Personal Data, together with information regarding the nature, processing and disclosure of those data.
• Unsubscribing:We include an unsubscribe link in all electronic marketing messages we send to you. You may withdraw your consent to direct marketing at any time. If you do so, we will promptly update our databases, and will not send you further direct marketing, but we may continue to contact you to the extent necessary for the purposes of any products or services you have requested.
• Checking and editing your Personal Data: Should you have an online user account, you may edit and complete your Personal Data directly yourself. If you do not have an online user account, you may contact us, who will upon your request as soon as possible rectify, remove or complete the information which is incorrect, unnecessary, lacking or outdated.
• Blocking and deleting cookies:You may block the cookies using your browser settings. Please note that blocking the cookies may affect the usability of our websites. You may also delete the cookies from your browser via its settings, in which case the information collected by the previous cookie will not affect the account created based on the information collected after such deletion.
• Advertising. You can opt out of online targeted advertising by opting out within the advertisement itself or by visiting Digital Advertising Alliance, http://www.aboutads.info/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/.  You can also opt out of the Digital Advertising Alliance using your mobile device settings.
• Allowing use of location data: You may give your consent to the use of location data in the options of the device or the application. You may also withdraw such consent at any time from the options menu in your account, or by contacting us.
• Erasure, or restriction of our processing, of your data: Should you believe that we process your data which is not accurate; the processing is illegal; we are not processing your data in accordance with the processing purpose or you want to oppose the processing, you may contact us to request the erasure, or restrictions on the processing, of your data. Please note that we will investigate your request reasonably promptly, before deciding what action to take.
• Right to object: You may have the right to object, on legitimate grounds, to the processing of your Personal Data.
• Withdrawing your consent. You may at any time decide to withdraw your consent to the processing of your Personal Data. If your consent is withdrawn, it does not prevent us from processing your Personal Data based on other legal bases, such as fulfilling your orders and storing your order data as required by applicable law. However, it should be noted that your account(s) on our Web Portal will be altered, and advantages granted to you via your account will be reset. Please note that withdrawal of consent does not affect the lawfulness of any processing performed prior to the date on which we receive notice of such withdrawal.
• Right to data portability:You may have the right to have your Personal Data transferred to another controller, in a structured, commonly used and machine-readable format, to the extent applicable.
• Right to Lodge a Complaint: For European Union residents, if you feel that our processing of your Personal Data infringes on data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state where you habitually reside, your place of work or the location of the alleged infringement.  If you are located outside of the European Union, you may have rights under privacy laws in the jurisdiction where you live.

[1] The General Data Protection Regulation (EU) 2016/679 ("GDPR") is a regulation in EU law on data protection and privacy for all individuals within the European Union (EU) and the European Economic Area (EEA). It also addresses the export of personal data outside the EU and EEA areas. For more information regarding the GDPR, please visit https://eugdpr.org/.