Privacy Policy (last updated February 23, 2021)

Thank you for choosing to be part of our community at Pamex Inc.  For over 30 years, Pamex has been in the business of providing door hardware to ensure the security and safety of properties and occupants.  It is only natural that we also value the importance of personal data security and privacy.  We are committed to protecting your personal information and your right to privacy. 

This Privacy Statement for Pamex Products & Services (“Privacy Statement”) describes the information that Pamex, Inc. and its subsidiaries and affiliates (collectively “Pamex”) collect, use, share, and store, including your personal information.  This Privacy Statement covers information related to the use of Pamex products and services, including:

• kapture, enkore, Konetik, and other Pamex products (collectively “Product(s)”);
• Our websites pamexinc.com, www.kapturehome.com, and associated websites that link to those websites, including the user portal websites for our Products (collectively “Website(s)”);
• Software or applications that may be accessed through our Websites or downloaded to your smartphone, tablet, or computer to access our services (“App(s)”);
• Subscription services, including services that can be accessed using the Websites and Apps; and
• Other related services, sales, marketing, or events

(collectively “Pamex Products & Services”).  By using Pamex Products & Services, you agree to allow us to collect and process information as described in this Privacy Statement.  If there are any terms in this Privacy Statement that you do not agree with, please discontinue use of Pamex Products & Services.  If you have any questions or concerns about our policy or practices, please contact us at help@pamexinc.com.

Please read this Privacy Statement carefully as it will help you make informed decisions about sharing your personal information with us.

1.  WHAT INFORMATION DO WE COLLECT?

Personal Information You Disclose to Us

We collect personal information that you voluntarily provide to us when registering for and using Pamex Products & Services, expressing an interest in obtaining information about us or Pamex Products & Services, contacting us through our Websites, by email, or by telephone, or otherwise contacting us.  The personal information that we collect depends on the nature of your interactions with us and the Pamex Products & Services, the choices you make, and the Products and features you use.  The personal information we collect may include the following:

• Name and contact data, including emails, mailing addresses, and phone numbers;
• Credentials, such as logins, passwords, and security information used for authentication and account access, such as IP address, mobile device identifiers, and photographs taken to use certain features of Pamex Products & Services;
• Wi-Fi network information (e.g., network name and password); and
• Payment information, including credit card and other billing information.

Pamex may also provide you with the ability to enable additional authorized users to access your account, Apps, Products, or Services.  If you do so, the additional authorized users may view and control all of your devices, content, and settings.  Invited users may also add additional authorized users to your account, so be careful to add only those you trust.  Information collected about invited users will be stored with your account and be subject to, and will be used and disclosed as set forth in, this Privacy Statement.  All invited users must be informed and expressly consent to such use and disclosure as a user of Pamex Products & Services.  If you are a guest and do not consent to such use, you should stop using Pamex Products & Services.  Any additional users added by you should also be aware that you may be able to see information about the user’s usage of the device or Pamex Products & Services, and may revoke or limit access rights in your discretion at any time, without notice.  In connection with the user invitation process, we may ask for access to your contact list.  However, we will only store information for contacts that you add as additional authorized users.

In addition, Pamex may use third party service providers that may collect and use your personal information.  For example, we use Google Play Services to ensure our Apps runs smoothly with certain mobile devices or tablets.  You can view the privacy policy for Google Play Services here.  

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information Automatically Collected

We automatically collect certain information when you visit, use, set up, or navigate Pamex Products & Services.  This information does not reveal your specific identity (like your name or contact information), but may include:

• Technical and usage information about the computer, mobile device, or tablet that you use to register or use Pamex Products & Services, such as IP addresses, browser and device characteristics (including device ID, model, and manufacturer), operating system, language preferences, referring URLs, country, geolocation, software version, device Bluetooth or Wi-Fi data, App configurations, time and date of use, and other technical information;
• Information about the Products, including how and when you use certain Products, such as device information (e.g., name, model, serial number), device status, battery charge level, Wi-Fi connectivity, information from device sensors (e.g., detecting manual tampering of locks), device activity logs (e.g., locking/unlocking, setting or changing settings), activities the Products performs (such as sending notifications or signals), your responses to our notifications, error logs, authorized user information, device performance data, and data when other Pamex Products & Services are added or linked to your account.

Information Collected from Other Sources

We may obtain information about you from other sources, such as public databases, joint marketing partners, and other third parties.  Examples of the information we receive from other sources include social media profile information, marketing leads, and search results and links, including paid listings (such as sponsored links).  Any data that Pamex receives from third-parties will be processed and stored by Pamex and will be treated in accordance with this Privacy Statement.

2.  HOW DO WE USE YOUR INFORMATION?

We use personal information collected through Pamex Products & Services for a variety of business purposes described below.  We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”).  We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process with your Consent.
• To provide, develop, and improve Pamex Products & Services. We may also use collected information to assess and recommend other Pamex Products & Services we think you may be interested in.  We may use your contact data to send you this information or other communications from Pamex.
• To send administration information to you for Business Purposes. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
• To fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through Pamex Products & Services.  We may also use third-party service providers who provide billing services, website support, facilitate communications, enable customer support, and other services connected to Pamex Products & Services, but only to the extent necessary to support or provide Pamex Products & Services.
• To respond to any customer support requests you make. We may access any collected data to help troubleshoot any issues you experience with Pamex Products & Services.
• To request feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of Pamex Products & Services.
• To protect Pamex Products & Services for Business Purposes. We may use your information as part of our efforts to keep Pamex Products & Services safe and security (for example, for fraud monitoring and prevention).
• To enforce our terms, conditions, and policies for Business Purposes.
• To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of promotional campaigns, and to evaluate and improve Pamex Products & Services, sales, marketing, and your experience.

In addition, Pamex may use third parties service provider companies and individuals to administer, support, and provide Pamex Products & Services on our behalf, including bill and credit card payment processing, maintenance, administration, support, hosting, and database management services.  These third parties may have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.  If you access Pamex Products & Services through a third-party (e.g., by managing your Pamex Products & Services through your mobile phone or tablet), or otherwise use a third party service provider in connection with Pamex Products & Services, or request or authorize us to give access or data to a third-party service provider (e.g. a delivery service or property management or rental service), we may provide your personal information and other information about Pamex Products & Services and their usage to such third-parties.  You should only use trusted service providers, and give your authorization and information to trusted recipients.  We encourage you to read the privacy policies and service terms of the third-party services that you use, as their privacy policies and terms govern their usage of the information that you provide them.  While we make reasonable efforts to protect your information while it is under our control, we have no obligation with respect to the functionality of such third-party services or the use of such information under control of these third parties.

Legal Bases for Processing Information for UK/EEA Users

For registered users from the United Kingdom (“UK”) or European Economic Area (“EEA”), the legal bases for this data processing are:

• Performance as necessary to support a Product or Service you have asked for under a contract, including administering your account, enabling functionality of the Product or Service, providing customer support, communicating with your regarding Pamex Products & Services, and delivering our Terms of Service.
• Our legitimate interest to process the data, including to protect the security or integrity of our computer systems and data protection, to carry out statistical or other analysis about Pamex Products & Services, to understand and improve upon Pamex Products & Services, to send you marketing or other communications about Pamex, to measure the performance of our Products or Services and communications efforts, to enforce legal claims, and to conduct market research.
• In order to comply with legal obligations, such as when we respond to a legal process or governmental request.
• With your consent.

3.  WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share and disclose your information in the following situations:

• Compliance with laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
• Vital interests and legal rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud or abuse, security or technical issues with Pamex Products & Services, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. 
• External processing. We may have vendors, service providers, and technicians help with some of our processing and storage, including helping to answer your questions.  They may also assist with monitoring our servers for technical problems.  These technicians (as well as Pamex employees) can access certain information about you or your account in line with this work but these technicians are not allowed to use this data for non-Pamex purposes. 
• With your consent. We may disclose your personal information for any other purpose with your consent.

4.  HOW LONG DO WE KEEP YOUR INFORMATION?

Pamex generally stores your information on our servers for as long as reasonably necessary to fulfill the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.  If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

5.  HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented security measures that meet industry standards and are designed to protect the security of any personal information we collect and process.  However, please remember that we cannot guarantee that the internet itself is 100% secure.  Although we will do our best to protect your personal information, transmission of personal information to and from Pamex Products & Services is at your own risk.  You should only access Pamex Products & Services within a secure environment.

Pamex is based in the United States, but your personal information may be collected, processed, and stored by Pamex or its service providers in the US or other countries where our servers reside.  Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country.  If you are using Pamex Products & Services in the EEA or other regions with laws governing data collection and use that may differ from United States law, you agree to the transfer of your personal data to the United States and other countries where Pamex operates.

International Data Transfers

When we transfer personal data from the EEA, Switzerland, or the UK to other countries, including to the US, we use various legal mechanisms to help ensure your data is appropriately protected.  Pamex complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework (the “Privacy Shield”) set forth by the U.S. Department of Commerce regarding the collection, use, sharing, and retention of personal information from the EEA, Switzerland, or UK to the US.  Pamex has certified to the Department of Commerce that we adhere to the Privacy Shield Principles (the “Principles”).

As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, you may refer a complaint to your local data protection authority and we will work with them to resolve your concern.  (In certain circumstances, the Privacy Shield Framework provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Privacy Shield Principles.)  If you have a Privacy Shield-related complaint, please contact us at help@pamexinc.com.

Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other authorized statutory bodies.  Under certain circumstances, participants like us may be liable for the transfer of personal information from the EEA, Switzerland, or UK to third parties outside the EU. 

We may share, as described in this Privacy Statement, information with our affiliates and subsidiaries, and third parties.  We may disclose information in response to legal process and lawful requests by public authorities in the US and other countries for the purposes of law enforcement and national security.

6.  DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age.  By using Pamex Products & Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor’s use of the Pamex Products & Services.  If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.  If you become aware of any data we have collected from children under age 18, please contact us at help@pamexinc.com.

7.  WHAT ARE YOUR RIGHTS AND CHOICES?

If you would at any time like to review or change the information in your account or terminate your account, you can do so by logging into your account to change the settings directly or by contacting us using the contact information provided below.  Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases as soon as is practical, but some information may be retained in our files for our records or to comply with legal requirements. 

Some information is processed and stored directly on the Products.  Personal information from the Products is encrypted while it is being transmitted to Pamex.  You can delete the information on the Products by resetting it to the defaults.  In addition, Product owners may request deletion of activity logs, including guest information, unless such information is required to be maintained in order to fulfill an existing legally required purpose. If you are a guest or visitor to a home where you used a Pamex Product or Service and wish to exercise your data subject rights regarding your personal data, then please contact the product owner directly, as we can only fulfill such requests when expressly authorized by the Product owners.  We may not accept a request to modify or erase your personal data where we cannot verify your personal data, where we require it to comply with a legal obligation, or in relation to a legal claim.  For additional information about how to requests to exercise your rights, please see contact us at the information provided below.

If you access Pamex Products & Services through a mobile device and you do not wish to share location-tracking information, you can disable the GPS or other location-tracking functions on your mobile device. See your mobile device manufacturer’s instructions for further details. Of course, if you do this, use and functionality of the Product or Service may be affected.

You may also unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send.  You will then be removed from the marketing email list; however, we will still need to send you service-related emails required for the administration and use of your account and Pamex Products & Services.  To otherwise opt out, you may contact us at help@pamexinc.com.

Personal Data Rights of UK/ EEA Users

For registered users from the UK or EEA, you also have the right to:

• Request a copy of your personal data from our records (including in a machine-readable format, which you are entitled to transfer to another data controller);
• Request that we correct, delete, or stop or restrict our processing of your personal data (though this may affect the use or functionality of your Pamex Products & Services and Pamex’s ability to process requests or troubleshoot);
• Withdraw your consent to us to process your data for marketing purposes at any time; and
• File a complaint with the appropriate supervisory authority in your country of residence, if you believe that we are violating the European Union's General Data Protection Regulation.

8.  DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

If you are a California resident, you may have additional rights and options to your data under the California Consumer Privacy Act (“CCPA”).  This Privacy Statement provides the disclosures and ways you can exercise your rights to receive information about our data practices, to request access to and update/deletion of your information, and to download a copy of your information.  Please feel free to contact us at the information listed below if you have any questions about the questions or requests related to your rights under the CCPA.

Pamex does not sell your personal information.  Pamex shares and uses your information for the purposes described in this Privacy Statement, which include “business purposes” under the CCPA.  These Business Purposes are described in Section 2, above.

9.  DO WE MAKE UPDATES TO THIS PRIVACY STATEMENT?

We may update this Privacy Statement from time to time.  The updated version will be indicated by the “Last Updated” date and the updated version will be effective as soon as it is accessible.  If we make material changes to this Privacy Statement, we may notify you by directly sending you a notification.  We encourage you to review this Privacy Statement frequently to be informed of how we are protecting your information.  Your continued use of Pamex Products & Services after any notice or posted modified Privacy Statement indicates acceptance of the modified Privacy Statement.

10.  HOW CAN YOU CONTACT US ABOUT OUR PRIVACY STATEMENT?

If you have any questions or comments about our Privacy Statement, you may email us at help@pamexinc.com or by contacting: