mobiBadge application privacy policy

CONSENT TO INSTALLATION OF THE APP

Under data protection laws, we are required to provide you with certain information about who we are, how we

process your personal data and for what purposes, and your rights in relation to your personal data. This information

is also provided at PRIVACY_POLICY and it is important that you read that information.

By continuing use of this APP, you consent to our processing of your personal data (including your name, contact

details, and device information) as described in this policy.

How you can withdraw consent

You may change your mind and withdraw consent at any time by contacting HID Global’s Data Privacy Manager

(details below) but that will not affect the lawfulness of any processing carried out before you withdraw your consent.

* * * * *

HID Global Corporation is committed to protecting your personal data and respecting your privacy.

INTRODUCTION

This policy (together with our end-user license agreement as set out at EULA (EULA) and any additional terms of

use incorporated by reference into the EULA, together our Terms of Use) applies to your use of:

• MobiBadge mobile application (App) hosted on Apple’s App Store and/or Google’s Play Store (App Site), once

you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).

• Any of the services accessible through the App (Services) that are available on the App Site or other sites of

ours (Services Sites). This policy sets out the basis on which any personal data we collect from you, or that

you provide to us, will be processed by us. This App is not intended for children and we do not knowingly

collect data relating to children. Please read the following carefully to understand our practices regarding your

personal data and how we will treat it.

IMPORTANT INFORMATION AND WHO WE ARE

HID Global Corporation, an ASSA ABLOY Group company, (the “Company” or “HID Global”), is a controller and

processor of your personal data which will be clear to you when you use our App. We have appointed a data privacy

manager. If you have any questions about this privacy policy, please contact them using the details set out below.

Contact details

Our full details are:

• HID Global Corporation

• Data Privacy Manager

• DPM@hidglobal.com

• 611 Center Ridge Drive, Austin, TX 78753

• +1 512 776 9000

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK

supervisory authority for data protection issues or other competent supervisory authority of an EU member state if

the App is downloaded outside the UK.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

This version was last updated on 03 August 2018. It may change and if it does, these changes will be posted on this

page and, where appropriate, notified to you by SMS, by email, or when you next start the App or log onto one of the

Services Sites. You consent to receiving notice of changes to this privacy policy by any means listed above. The

new policy may be displayed on-screen and you may be required to read and accept the changes to continue your

use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your

personal data changes during our relationship with you.

THE DATA WE COLLECT ABOUT YOU

We may collect, use, store, and transfer different kinds of personal data about you as follows:

• Identity Data.

• Event Data.

• Contact Data.

• Device Data.

• Content Data.

• Profile Data.

• Usage Data.

We explain these categories of data in the GLOSSARY below.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose.

Aggregated Data could be derived from your personal data but is not considered personal data in law as this data

will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the

percentage of users accessing a specific App feature. However, if we combine or connect Aggregated Data with

your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which

will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or

ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership,

information about your health, and genetic and biometric data). Nor do we collect any information about criminal

convictions and offences.

HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and/or process the following data about you:

• Information you give us. This is information (including Identity and Contact Data) you consent to giving us

about you by filling in forms on the App Site and the Services Sites (together Our Sites). It includes

information you provide when you register to use the App Site, download or register an App, and when you

report a problem with an App, our Services. If you contact us, we will keep a record of that correspondence.

• Information we collect about you and your device. Each time you use one of our Apps we will

automatically collect personal data including Device and Usage Data.

• Information we receive from other sources including third parties and publicly available sources. We

will receive personal data about you from various third parties (the controller of your personal data).

• Identity, Event, and Contact data from third parties

• Device Data from your device manufacturer or telecommunications providers

• Usage Data from third party analytics providers

• Unique application numbers. When you want to install or uninstall a Service containing a unique application

number or when such a Service searches for automatic updates, that number and information about your

installation, for example, the type of operating system, may be sent to us.

Tracking/Usage Technologies

We use tracking technologies to distinguish you from other users of the App, App Site, the distribution platform (App

store) or Services Sites and to remember your preferences. This helps us to provide you with a good experience

when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data

in the following circumstances:

• Where you have consented before the processing.

• Where we need to perform a contract we are about to enter or have entered with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental

rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/activity

Type of data

Lawful basis for processing

To install the App, register you as a

new App user, and provision virtual

credentials

Identity

Event

Contact

Device

Your consent

To manage our relationship with you

including notifying you of changes to

the App or any Services, and

updating/issuing credentials

Identity

Event

Contact

Profile

Usage

Your consent

Necessary for our legitimate

interests (to keep records updated

and to analyse how customers use

our products/ Services)

Necessary to comply with legal

obligations (to inform you of any

changes to our terms and

conditions)

To administer and protect our

business and this App including

troubleshooting, data analysis,

system testing, and App

improvements

Identity

Contact

Device

Usage

Necessary for our legitimate

interests (for running our business,

provision of administration and IT

services, network security)

DISCLOSURES OF YOUR PERSONAL DATA

When you consent to providing us with your personal data, we will also ask you for your consent to share your

personal data with the third parties set out below for the purposes set out in the table:

• Internal Third Parties as set out in the GLOSSARY.

• External Third Parties as set out in the GLOSSARY.

• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our

business, then the new owners may use your personal data in the same way as set out in this privacy policy.

INTERNATIONAL TRANSFERS

We may share Your information with other companies in our group or with our trusted subcontractors in order to

provide the Services and for the purposes set out in this Privacy Policy. Processing of Data may therefore take place

in countries other than Your home country. Data collected in the European Economic Area (the “EEA”), may be

stored, processed or transferred outside of the EEA, as described in this Privacy Policy. The destination country

may not offer the same level of protection of the Data as the country where You are located and may only provide

you with fewer legal rights in relation to the Data. However, We will only process the Data as described in this

rules. You expressly consent to Your information being used as set out herein. Whenever we transfer your personal

data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following

safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of

protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the European

Commission which give personal data the same protection it has in Europe.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield

which requires them to provide similar protection to personal data shared between Europe and the US.

HID Global complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield

Framework(s), as applicable) as set forth by the U.S. Department of Commerce regarding the collection, use,

and retention of customer personal information transferred from the European Union and Switzerland to the

United States. HID Global has certified to the Department of Commerce that it adheres to the Privacy Shield

Principles. If there is any conflict between the terms in this privacy notice and the Privacy Shield Principles, the

Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our

certification, please visit https://www.privacyshield.gov/ or see our Privacy Shield Statement at

https://www.hidglobal.com/about/privacy.

Please contact us if you want further information on the specific mechanism used by us when transferring your

personal data out of the EEA.

DATA SECURITY

All information you provide to us is stored on secure servers.

Once we have received your information, we will use strict procedures and security features to try to prevent your

personal data from being accidentally lost, used or accessed in an unauthorized way.

We may collect and store personal data on your Device using a secure wallet technology.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any

applicable regulator when we are legally required to do so.

DATA RETENTION

Details of retention periods for different aspects of your personal data are available in our retention policy which you

can request by contacting us.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for

research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of 3 months then we may treat the account as expired and your

personal data may be deleted.

YOUR LEGAL RIGHTS

Under certain circumstances you have rights under data protection laws in relation to your personal data. To find out

more about these rights, see YOUR LEGAL RIGHTS in the GLOSSARY section below:

• Request access to your personal data.

• Request correction of your personal data.

• Request erasure of your personal data.

• Object to processing of your personal data.

• Request restriction of processing your personal data.

• Request transfer or your personal data.

• Right to withdraw consent.

You can exercise any of these rights at any time by contacting us at privacy@hidglobal.com.

GLOSSARY

LAWFUL BASIS

Consent means processing your personal data where you have signified your agreement by a statement or

clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific,

informed and unambiguous indication of what you want. You can withdraw your consent at any time by

contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable

us to give you the best service/product and the best and most secure experience. We make sure we

consider and balance any potential impact on you (both positive and negative) and your rights before we

process your personal data for our legitimate interests. We do not use your personal data for activities

where our interests are overridden by the impact on you (unless we have your consent or are otherwise

required or permitted to by law). You can obtain further information about how we assess our legitimate

interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a

contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for

compliance with a legal obligation that we are subject to.

THIRD PARTIES

INTERNAL THIRD PARTIES Other companies in the Assa Abloy Group acting as joint controllers or processors

and who are based in United States, Sweden and India and provide IT and system administration services and

undertake leadership reporting.

EXTERNAL THIRD PARTIES Service providers acting as processors based in United States and Ireland who

provide IT and system administration services.

YOUR LEGAL RIGHTS You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables

you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or

inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you

provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where

there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove

your personal data where you have successfully exercised your right to object to processing (see below),

where we may have processed your information unlawfully or where we are required to erase your personal

data to comply with local law. Note, however, that we may not always be able to comply with your request of

erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third

party) and there is something about your particular situation which makes you want to object to processing on

this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object

where we are processing your personal data for direct marketing purposes. In some cases, we may

demonstrate that we have compelling legitimate grounds to process your information which override your

rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the

processing of your personal data in the following scenarios:

(a) if you want us to establish the data’s accuracy;

(b) where our use of the data is unlawful but you do not want us to erase it;

defend legal claims; or

(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate

grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party

you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this

right only applies to automated information which you initially provided consent for us to use or where we used

the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this

will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw

your consent, we may not be able to provide certain products or services to you. We will advise you if this is the

case at the time you withdraw your consent.

DESCRIPTION OF CATEGORIES OF PERSONAL DATA

• Identity Data: first name, last name, maiden name, username or similar identifier, company, title, date of birth,

gender, nationality, country of residence and photo.

• Event Data: venue, seating, vending and discount codes.

• Contact Data: billing address, delivery address, email address and telephone numbers.

• Device Data: includes the type of mobile device you use, a unique device identifier (for example, your

Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone

number used by the Device), mobile network information, your mobile operating system, the type of mobile

browser you use, and time zone setting.

• Content Data: includes information stored on your Device, including friends’ lists, contacts, photos, videos or