3millID Privacy Notice – 3millID Mobile Apps & Services
3millID Corporation (“3millID”) is committed to protecting the privacy of users of its 3millID mobile applications (“Apps”) and related services (“Services”). It is important that our users understand how we collect, use, and disclose Personal Information (as defined below).
This Privacy Notice describes our practices related to Personal Information collected through 3millID’s Apps and Services.
The Bottom Line:
We use your Personal Information to provide you with the Apps and Services.
Location services can be used for the Apps’ Pathways feature and other positioning features, but you don’t have to. When you use location services, that location information is collected by your device and shared with a third-party service provider, but 3millID does not have access to it unless you elect to back up your Apps settings and preferences to the 3millID cloud.
You may elect to back up your Apps settings and preferences to the 3millID cloud, including your Pathways and other positioning features’ settings and preferences, but you don’t have to. When you elect to back up your settings and preferences to the 3millID cloud, 3millID does have access to those settings and preferences, but only for the purpose of hosting and making those settings and preferences available to you for use on a new or reset device and to provide technical support.
You can reach 3millID via email at support@3millID.com, or by mail at 9249 S. Broadway, Building 200, Suite 826, Highlands Ranch, CO 80129, U.S.A., with any concerns or questions about this Privacy Notice or your data privacy. Read on for more information.
What Personal Information does 3millID collect? How does it collect such Information?
“Personal Information” is any information that relates directly or indirectly to a natural person.
3millID collects, uses, and processes your Personal Information in order to provide you with the Apps and Services and other services, products, or information that you request.
The collection of information, including Your Personal Information, will be transparent to you, and you will have the opportunity to decide whether or not to provide it. If you choose not to provide any of the Personal Information requested, 3millID may be unable to complete your transaction, or provide the information, services, or products you have requested, including but not limited to the Apps and Services.
If you are using the Apps’ Pathways feature or other positioning features, the Apps collect your physical location when the Apps are in use (such as via GPS); however, that physical location information is not transferred to 3millID, but will be collected by 3millID’s service providers. Note that any location settings and preferences you choose to create a particular, reusable Pathway will be backed up, if you elect to back up your Apps settings and preferences to the 3millID cloud). (See “How may 3millID use and share location data?” below for more information on the Apps’ Pathways feature and positioning features and location data).
We might also need to collect other information for a specific form, feature, or other service that you may use or request. The content of such information will vary depending on the method of collection and the specific purpose(s) for which the information is being collected, but the request for information will be transparent to you and be specified as needed.
Except to the extent specifically requested from you by the Apps or Services, the Apps and Services are not intended to collect or process Sensitive Personal Information. As such, do not enter or store in the Apps any Sensitive Personal Information not specifically requested of you by the Apps or Services, including but not limited to any data revealing racial or ethnic origin, political affiliations or opinions, religious or philosophical beliefs, union memberships, or genetic, biometric or health data.
Why does 3millID collect your Personal Information?
Our purpose in collecting this information is to provide the Apps, Services and other information, services or products you have requested. If collected, your Personal Information will be used by 3millID to carry out our contractual obligations, including but not limited to authenticating you as a user and allowing you to use certain functions of the Apps and Services.
Personal Information collected on the Apps and Services will also be used to:
- Execute our contractual obligations, as laid out in the 3millID Mobile Apps and Services End User License Agreement.
- Provide requested information, products, items, or services, including the Apps and Services;
- Obtain your location data in order to provide requested information or services (but 3millID will not have access to that location data, only the service provider for location services will, however, any location settings and preferences you choose to create a particular, reusable Pathway will be backed up, if you elect to back up your Apps settings and preferences to the 3millID cloud);
- Comply with legal obligations:
- Screen against sanctions and antiterrorism lists as required by law;
- Respond to a legitimate legal request from law enforcement or judicial authorities or other government regulators;
- Satisfy 3millID’s legitimate interests:
- Protect against fraud or investigate suspected or actual illegal activity;
- Develop new offerings, improve the quality of our products, services and processes, including the Apps and Services, improve and personalize user experience, and better prepare future content based upon your interests and those of our general user population; or
- Conduct investigations to ensure compliance with, and comply with, legal obligations.
Where is Personal Information stored?
3millID stores your information in the United States. However, because 3millID engages with third party companies in providing the Apps and Services that are global companies with locations in many different countries (“3millID Service Providers”), we may transfer your information from one legal entity to another or from one country to another within the 3millID Service Providers group in order to accomplish the purposes listed above. These countries include, at a minimum, the member states of the European Union, Switzerland, the United Kingdom, Canada, and other countries, including some in Asia and Central and South America. We will transfer your Personal Information consistent with applicable legal requirements and only to the extent necessary for the purposes set out above.
3millID and 3millID Service Providers rely on adequate contractual provisions, as well as technical and organizational security measures, to enable the transfer of Personal Information across borders.
Does 3millID use your Personal Information to contact you?
3millID does not use the information collected through the Apps and Services to contact you.
If you choose to provide Personal Information to 3millID through channels other than the Apps and Services, 3millID may use the Personal Information you provide to contact you about products, services, promotions, special offers, surveys, and other information that may be of interest to you. If you prefer not to receive such communications, please use the “unsubscribe” function within the email, or let us know by sending an email to support@3millID.com. Also, 3millID will ensure that any marketing communications sent by electronic means will provide a simple method for you to opt-out or unsubscribe. Please note that if you unsubscribe from marketing communications, you may continue to receive communications about your account or transactions with us.
Does 3millID share the information it collects?
If you use the Apps’ Pathways feature or other positioning features, the Apps will utilize location services, such as Google Maps® or Google Places®, in order to provide you with that service. This requires the Apps to share your Personal Information, including location information, with the service provider for location services. In addition, if you elect to back up your Apps settings and preferences to the 3millID cloud, your Personal Information related to your Pathways and positioning feature settings and preferences will be stored on the 3millID cloud and accessible by 3millID in order to make those settings and preferences available to you for use on a new or reset device. (For more information on the Apps’ Pathways feature, see “What is Pathways and how do the Apps use location data?” below).
The Apps use Bluetooth permissions to detect and communicate with nearby 3millID readers.
The Apps use “read or write to external file storage” permissions to download and save the 3millID credential certificate which contains device-specific “signatures” required to communicate with the 3millID readers for door access.
3millID will not sell or otherwise transfer or share your Personal Information, except to:
- Service providers, dealers, distributors, resellers, agents, or contractors that 3millID has retained to perform services on our behalf or authorized to sell our products and services. 3millID will only share your Personal Information with third parties whom 3millID has contractually restricted from using or disclosing the information except as necessary to perform services on our behalf, sell our products and services or to comply with legal requirements;
- To a facility subscribing to the instance of the Apps you are using, where such facility requests details of the SSID/BSSID data of Apps users at their facility for their own analytic purposes, which may include gaining a better understanding of how many, or which, of their Apps users are connected to which Wi-Fi networks within their facility. Such SSID/BSSID data will not be shared in a manner that connects it with an Apps user’s identity
- Comply with legal obligations, such as in response to a legitimate legal request from law enforcement authorities, courts or other government regulators or authorities, among other things;
- Investigate suspected or actual illegal activity;
- Prevent physical harm or damage or financial loss; or
- Support the sale or transfer of all or a portion of our business or assets (including through bankruptcy).
Your Personal Information will also be maintained and processed by our service providers in the United States, the member states of the European Union, Switzerland, the United Kingdom, Canada, Asia, Central and South America and in other jurisdictions.
What is Pathways and how do the Apps use location data?
If you choose to use the Apps’ Pathways feature, you will have the opportunity to enable location services to create your own “Pathway”. You can also choose not to use the Apps’ Pathways feature or other positioning features and location services, but you will need to manually create and manually initiate your chosen Pathway in the Apps to use that functionality. Choosing not to use the Apps’ Pathways feature or other positioning features entirely will not decrease your ability to use other functions of the Apps or Services.
If you are using the Apps’ Pathways feature or other positioning features with location services, the Apps will collect location data generated by your use of the Apps’ software and the Services on your mobile device. The location data includes your set GPS location when you reach your selected location, and this GPS location information is kept on your mobile device and used by the location services provider, in the case of the Apps and Services, Google® (for Google Maps® and/or Google Places®, please review the privacy terms for those products if you have questions). In order to use the Apps’ Pathway feature, the Apps also requires access to your Wi-Fi status permission to determine your exact location. 3millID uses this location data to provide you the ability to use the Apps’ Pathways feature or other positioning features. 3millID will ask permission to collect your location data and so the collection of this location data will be transparent to you – you will have the opportunity to decide whether or not to provide your location data.
The Apps collect location data to enable the Pathways frequently travelled route feature and other positioning features with location services to function even when the Apps are closed or not in use.
If you elect to back up your Apps settings and preferences to the 3millID cloud, your Personal Information related to your Pathways and positioning feature settings and preferences, including but not limited to your preferred or frequently travelled routes, will be stored on the 3millID cloud and accessible by 3millID for the purpose of making those settings and preferences available to you for use on a new or reset device.
How does 3millID secure Personal Information?
3millID is committed to ensuring the security, availability, and integrity of Personal Information. 3millID has adopted reasonable physical, electronic, and managerial procedures to safeguard your Personal Information. However, due to the nature of Internet communications, we cannot guarantee or warrant that your transmission to us is secure. 3millID shall periodically re-evaluate the measures adopted to ensure that they remain reasonable and appropriate at all times, subject to the evolution of the industrial best-practices.
How can you correct, change, or delete your Personal Information held by 3millID?
You may request to access, update, correct, change, or delete your Personal Information from the 3millID system at any time. 3millID will use reasonable efforts to timely update and/or remove information; however, this will likely impact your ability to use or access 3millID’s services, including the Apps and Services. To protect the user’s privacy and security, 3millID will take steps to verify the user’s identity before providing any requested access or making any requested change. To access, updated, correct, change, or delete your Personal Information or to ask questions or to raise concerns, send an email to support@3millID.com.
Please note that while we will assist you in protecting your Personal Information, it is your responsibility to protect your devices, Apps, Services, passwords, and other access credentials from others.
What should you understand about the third-party links that may appear in the Apps or as part of these Services?
In some instances, 3millID may provide links to non-3millID controlled websites, which 3millID will make reasonable efforts to identify as such. 3millID does not control such third-party websites, however, and cannot be responsible for the content or the privacy practices employed by other websites. Furthermore, this Privacy Notice does not govern information collected about you by third parties.
How long do we keep your Personal Information?
Any Personal Information you provide to 3millID is only kept for as long as it is reasonably necessary for the purposes for which it was collected, taking into account our need to comply with contractual obligations, resolve customer service issues, comply with legal requirements and provide new or improved services to users. This means that we may retain your Personal Information for a reasonable period after you stopped using the Apps and Services. After this period, your Personal Information will be deleted from all systems of 3millID without notice.
What additional information should specific users know?
Parents, Guardians, and Children:
The Apps and Services are intended for users who are at least 18 years of age, or the age of majority in their jurisdiction of residence. 3millID does not knowingly solicit information from, or market products or services to, children. If you do not meet the age requirements set out above, please do not enter your Personal Information on this or any other 3millID website or Apps.
Users from California:
If you are a resident of California, effective January 1, 2020, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”), including the right to:
- Know what categories of personal information about you we have collected and used, including how the personal information was collected and the purpose for the collection and use;
- Know what categories of personal information are being sold or disclosed to third parties and, if sold or disclosed, the categories of third parties receiving it;
- Access specific personal information collected about you;
- Request that your personal information be deleted.
Requests to exercise rights under the CCPA are subject to verification by 3millID and are also subject to certain restrictions provided by the CCPA. We will not discriminate against California residents for exercising any of their applicable CCPA rights. While California residents have the right to opt-out of the sale of their personal information under CCPA, 3millID does not sell personal information to third parties. If our practices change, we will update this Privacy Notice and take any necessary action to comply with applicable law.
California residents who wish to exercise their CCPA rights can contact 3millID at support@3millID.com or by calling 303-475-4972. When contacting us to exercise your rights, please put “California Privacy Rights” in the subject and body of your request and describe the nature of your request.
Annually California residents may request and obtain information that 3millID shared with other businesses for their own direct marketing use within the prior calendar year (as defined by California’s “Shine the Light Law”). If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which 3millID shared this information in the immediately preceding calendar year. To obtain this information, please send an email message to support@3millID.com with “California Shine the Light Privacy Request” in the subject line as well as in the body of your message.
Users from the EU:
You have the right to lodge a complaint with your national or state data protection authority, which may also be known as a supervisory authority. You also have the right to: (i) request access to and correction or erasure of your Personal Information; (ii) seek restrictions on; or (iii) object to the processing of certain Personal Information and seek data portability under certain circumstances. To contact 3millID about a request to access, correct, erase, object or seek restrictions or portability, please use the contact methods indicated at the end of this notice.
Not all Apps and Services features and options are available in all locations.
How might 3millID change this Privacy Notice?
As 3millID expands and improves the Apps and Services, we may need to update this Privacy Notice. This Privacy Notice may be modified from time to time without prior notice. We encourage you to review this Privacy Notice on a regular basis for any changes. Substantive changes, if any, will be identified at the top of the Privacy Notice.
How can you contact 3millID?
If you have any comments or questions about this Privacy Notice, 3millID’s privacy practices in general, or to obtain information on the manner in which we or our service providers treat your Personal Information, please email support@3millID.com.
In the event that you are located in a country that will be governed by the General Data Protection Regulation and would like to contact the local Data Protection Officer, please note that in your email and your inquiry will be directed to the appropriate person. If you wish to opt-out from sharing your Personal Information with us or have your Personal Information be updated, corrected or removed, please email email@example.com or call 1-303-475-4972.
All trademarks are the property of their respective owners.