Privacy Policy
1. INTRODUCTION
Smarter Locks (Pty) Ltd (“Smarter Locks”, “we”, “us”, or “our”) respects your right to privacy and is committed to protecting the personal information we process in the course of our business operations and when you use our products and services.
This Privacy Policy explains how we collect, use, share, and protect personal information in accordance with the Protection of Personal Information Act, 2013 (POPIA) and other applicable South African laws.
By using our website, software, or products, or by providing us with your personal information, you agree to the terms of this Privacy Policy.
2. SCOPE
This Privacy Policy applies to:
All users of Smarter Locks smart lock products, accessories, and connected software services.
Property owners, hosts, tenants, or guests using our software or mobile apps.
Visitors to our website and other digital platforms.
It does not apply to third-party websites or services that may be linked from our platforms.
3. INFORMATION WE COLLECT
We collect and process the following categories of personal information, depending on your interaction with us:
3.1 Information You Provide to Us
Identification details: Full name, ID/passport number, business name (if applicable).
Contact details: Email address, phone number, and delivery address.
Billing and payment details: Bank or card information processed via secure third-party payment providers.
Account credentials: Username, password, and login details for our software platform.
Support communications: Enquiries, messages, and correspondence with our support team.
3.2 Information Collected Automatically
When using our website, app, or connected devices:
Device information: IP address, device type, operating system, browser version.
Usage data: Dates and times of access, actions performed, pages visited, error logs.
Smart lock activity: Lock/unlock events, device health, firmware version, access history (linked to your user account).
3.3 Information Provided by Third Parties
Property owners or managers may share guest or tenant information (e.g., names, emails, access codes) to enable digital key issuance.
We may receive verification or payment data from payment processors or financial institutions.
4. PURPOSES FOR PROCESSING PERSONAL INFORMATION
We process your personal information for the following purposes:
To supply, deliver, and support smart lock hardware and related services.
To register and manage user accounts and software subscriptions.
To enable secure access control, logging, and property management features.
To communicate regarding orders, system alerts, updates, or support.
To improve our Products, Software, and customer experience.
To comply with legal obligations, fraud prevention, and data-security requirements.
To send service notices, promotional offers, or updates (only with your consent).
5. LEGAL BASIS FOR PROCESSING
We process your personal information based on one or more of the following lawful grounds under POPIA:
Consent: You have given clear consent for the processing.
Contractual necessity: Processing is required to perform our agreement with you.
Legal obligation: We must comply with applicable laws and regulations.
Legitimate interest: To operate, improve, and secure our business and systems.
6. DISCLOSURE OF INFORMATION
We may share your personal information with:
Service providers (e.g. couriers, payment processors, data-hosting partners) strictly for operational purposes.
Installers or property managers where you authorise coordination or access integration.
Legal authorities where required by law, subpoena, or court order.
Affiliates or successors in the event of a business transfer, merger, or sale.
We do not sell or rent your personal data to third parties.
All third-party service providers are contractually bound to safeguard your information and use it only for authorised purposes.
7. CROSS-BORDER DATA TRANSFERS
Some of our cloud service providers or servers may be located outside South Africa.
When we transfer data internationally, we ensure that the receiving country or service provider offers an equivalent level of data protection as required by POPIA, through contractual safeguards or approved mechanisms.
8. DATA RETENTION
We retain personal information only for as long as necessary to:
Fulfil the purposes for which it was collected,
Comply with legal, accounting, or reporting obligations, and
Resolve disputes and enforce agreements.
Access logs and device data are typically retained for up to 24 months, unless required longer for security, auditing, or compliance reasons.
9. SECURITY OF INFORMATION
We take appropriate technical and organisational measures to protect your personal information against:
Unauthorised access or disclosure,
Loss, alteration, or destruction, and
Cybersecurity threats or misuse.
This includes encryption, access control, secure hosting, and staff confidentiality undertakings.
However, please note that no system is completely secure, and we cannot guarantee absolute protection against all potential risks.
10. YOUR RIGHTS UNDER POPIA
Under the Protection of Personal Information Act, you have the following rights:
Access: Request a copy of the personal information we hold about you.
Correction: Request correction of inaccurate or outdated information.
Deletion: Request deletion of data that is no longer required or unlawfully processed.
Objection: Object to processing under certain circumstances.
Withdrawal of consent: Withdraw consent where processing is based on consent.
Requests should be made in writing to our Information Officer at [insert email address].
We may require proof of identity before fulfilling requests.
11. DIRECT MARKETING
We will only send you marketing or promotional communications if:
You have explicitly consented, or
You are an existing client and communications relate to similar products or services.
You may opt-out at any time by using the “unsubscribe” link or contacting us directly.
12. COOKIES AND ANALYTICS
Our website and software may use cookies or analytics tools to:
Improve site performance and usability,
Remember preferences and login sessions,
Measure traffic and usage patterns.
You can disable cookies in your browser settings, though some features may not function properly.
13. CHILDREN’S INFORMATION
Our Products and Services are not directed at children under 18 years old.
We do not knowingly collect or process personal information of minors without verified parental consent.
14. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time.
The latest version will always be posted on our website with the effective date clearly indicated.
Your continued use of our Products or Services constitutes acceptance of any updated version.
15. CONTACT INFORMATION
Information Officer:
Smarter Locks (Pty) Ltd
Email: [Insert Email]
Telephone: [Insert Number]
Physical Address: [Insert Address]
If you believe we have not handled your personal information in accordance with the law, you may lodge a complaint with:
The Information Regulator (South Africa)
Website: https://inforegulator.org.za
Email: complaints.IR@justice.gov.za