1 Latch Privacy Policy 

This Privacy Policy forms part of the Agreement between Latch and the Customer and should be read in conjunction with the following Latch documents; 

– Terms and Conditions of Service 

– Latch Features and Pricing Plans as specified on the Latch.Chat website 

– Any such additional terms and conditions provided for on the Latch.Chat website. 

Terms not defined herein shall have the meaning set forth in the Latch Terms & Conditions. 

The Latch Privacy Policy constitutes, for the purposes of the Agreement, the choices you have in respect of the use and disclosure of information, Customer Data and Content that is gathered by Latch in respect of the Latch Platform and Services. 

You may decline to submit any information through the Service, in which case we may not be able to provide our Service to you. 

2 Changes to this Privacy Policy 

Any changes we make to our Privacy Policy will be posted on our website www.latch.chat and implemented as a change to the Agreement. The Customer retains the right to cancel their Account should they disagree with the changes to the Privacy Policy. 

3 Definitions 

“Customer” (also referred to as; you, your, yours) is the person, company, entity, group or other organisation that is the contracting party entering into the Agreement with Latch for the supply of Services by way of a Customer Account. 

“Customer Data” has the meaning described herein the section titled ‘Information we collect and or receive’ 

“Information” means collectively the Customer Data and Other Information 

“Latch” (also referred to as; us, we, our) means Latch.chat Ltd, the entity that gathers, handles and manages your information when using the Website or Services. 

“Latch Platform” has the meaning ascribed to it in the Terms and Conditions of Service. 

“Non-Latch Product” has the meaning stipulated herein the section titled ‘Exclusions Section 5’. 2 

“Other Information” has the meaning described herein the section titled ‘Information we collect and or receive’. 

“Services” means the Latch mobile and desktop applications, downloaded, activated, used or delivered through the Latch platforms and infrastructure, www.latch.chat, or any other interaction between the Customer and Latch products and services. 

“Third-Party Providers” means companies external to Latch who provide third-party websites, products, services, software and/or applications which are examples of “Non-Latch Product”. 

“Third-Party Service Providers” means companies external to Latch who may: 

• Facilitate Latch Services 

• Provide and or perform a service on our behalf 

• Assist Latch in analysing how the Services are used. 

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“User” means any individual or administrator that has registered, or been pre-registered to use the Latch Platform and Services on the Customer Account.; 

“Website” means any Latch website used to provide Latch Services. 

4 Applicability of this Privacy Policy 

This privacy policy applies between the Customer and the Latch, the provider of the Latch Platform and Services. This privacy policy applies to data use in respect of the Latch Platform and Services. The use of the Latch Platform and or Services means that you, the Customer, hereby accept and agree to abide by the policies contained herein for yourself and on behalf of your Users. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Latch’s business. 

The Customer must ensure that its Users are informed about the provisions of this Privacy Policy, any updates, changes and of any other information relevant to the access or use of the Services including the sharing of Customer Data and Other Information. 

The Customer is responsible for its policy and procedures with regards to information provision and can control their own information and content through the settings and administration provision on their Account and or on the User Device. 

If the User has specific queries in respect of their information or content, they should, in the first instance, contact their Customer administrator. 

5 Exclusions 

The Latch Platform enables Third-Party Providers to develop services, act as data controllers and provide applications and content to Customers and Users (Non-Latch Products). This Privacy Policy does not apply to the practices of Third-Party Providers that we do not own or 3 

control or individuals that we do not manage or employ, including any Third-Party Providers or products that the Customer may elect to access through the Website or Services. Latch may collect, receive and share Information, with Third-Party Providers in order to facilitate the integration and or provision and or access of Non-Latch Products. As these services are not operated by Latch, we assume no responsibility and will not be held responsible for any information that is used, deleted, disclosed, modified, transmitted or accessed in respect of the Non-Latch Products, services or content and recommend that you review the Privacy Policies of these Third-Party Provider websites and businesses. The Customer is responsible for ensuring Information is secure, protected and maintained when under their control and or the control of Third-Party Providers and Latch bears no responsibility in this regard. 

Please feel free to contact Latch if you have any questions about this Privacy Policy or Latch’s practices or if you are seeking to exercise any of your statutory rights. You can contact us at www.support@latch.chat . 

6 Your rights 

Subject to applicable laws, individuals in certain countries, including the European Economic Area, have statutory rights in respect of their personal data. Personal data is essentially data which identifies you as an individual. These rights include things such as the right to request access to the information, to have it corrected, erased or restricted, the right to move, copy or transfer data and the right to object to our use of data. Some of these actions can be changed within the Account settings and or on the Device, others may require Latch involvement. 

Questions in respect of General Data protection Regulation (GDPR) should be directed to www.support@Latch.chat. 

7 Information we collect and or receive 

Latch may collect and or receive Information, collectively Customer Data and other information and data (“Other Information”) in a variety of ways: 

7.1 “Customer Data” 

7.1.1 Customer data comprises identifiable information which is made available by Customers, Users or individuals using the Latch Website and Services such as: 

• • Account information including your full name, email address, phone number, password, domain and/or similar account details. 
• • Business information including your title, department, colleagues and other information related to your work. 
• • Customers provide billing details including credit card information, banking information and/or a billing address. 
• • Contact information provided from the device such as the address book 

7.2 “Other Information” 4 

Other Information comprises information that could be used to identify Customers, Users or individuals using the Latch Website and Services. 

7.2.1 Communications Content, the content of all communications on or through the Services including : 

• • information that you or other people may share about you when they use the Services including all content, pictures, videos, messages, other information or comments uploaded or shared with users, 

• • Information provided to Latch when you or the other people that you engage with contact us for Services support, suggestions or contact Latch for other assistance. 

• • Information context about the frequency, duration and patterns of contact, for example Latch logs the Groups, participants, channels, content and links you interact with along with the frequency and the duration, the types of files shared and what Non-Latch Products are used (if any). 

7.2.2 Website and Service Usage information 

• • Log data. As is standard for most Internet, website and technical service providers, we routinely collect information that your browser sends when visiting Latch and record it in log files. This log data includes information such as the date and time the Service was used, length of visit, page views, website navigation paths, as well as information on timing, frequency and pattern of use, the Internet Protocol (IP) address, the browser and version used, along with any settings, configurations, plugins, language preferences, cookie data and pages of web sites visited before accessing the Latch Website and Services and other standard log information. 

• • Device information. Latch collects information about your use of your device accessing the Services, including the device type or model and operating system, the Internet Service Provider (ISP), device settings and unique identifiyers, application IDs, and crash data. Latch may collect information from or about the computers, phones or other devices where you install our Services including but not limited to geographic information through GPS, Bluetooth or wi-fi. We may associate or link the information we collect from different devices to assist us in providing a seamless service across all devices. 

• • Location information: We receive information from you and other third parties that assists in determining your location. We use Google maps in this regard and they use a variety of indicators, such as cell towers, IP and GPS. The location information is used to provide you with location-based services, for example when you select to share your location with another User. The User has control over whether to provide their location 

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• on their device and will be asked for access when setting up their account. Should the User select not to provide location information we may not be able to provide some or all Services to you. 
• • Cookies. Latch, like many sites uses Cookies to collect Other Information. You can select to refuse Cookies, this is a setting within your browser, or you can select to be notified whenever a Cookie is being sent. If you do not accept Cookies, you may be unable to access some parts of the Website or Services. The Latch Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. 

8 How we use information 

The Information that is gathered by Latch is used in accordance with our terms and conditions of service provision and in accordance with the Customer’s instructions. The Customer dictates their own policies and procedures with regards to how information can be used, shared and disclosed. Latch may use Information collected from you in any one or more of the following ways: 

8.1 Services Delivery 

• • Latch uses Other Information in the furtherance of our legitimate interests, the proper administration and operation of our Platform, Services and business and the performance of our contract. 
• • To deliver, provide, and maintain the Platform, Services and Latch business for example addressing technical, security, insurance, managing risk, obtaining professional advice or addressing other service issues, 
• • To verify access rights to services; 
• • To compare information for accuracy, and verify it with third parties, including partners; 
• • For our internal records, auditing, tracking and business purposes; 
• • Third-Party Service Providers have access to Customer Information in order to perform the tasks assigned to them on our behalf. 
• • To provide you with access to particular tools and services included but not limited to the access and integration with Third-Party Providers for the access and use of Non-Latch Product. 

8.2 Account Management & Billing 

• • To register and service your Account; 

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• • For general Account administration such as invoicing, billing and payment tracking; 

8.3 Account Support 

• • To contact you in response to your questions or requests and or to provide you with technical or Services support and or to inform you about Services updates, and or deliver important Services-related notices, such as security and fraud notices. These communications are deemed to be a part of the Service and are not Customer controlled. Latch may keep records of communications, including but not limited to any questions, requests, comments and or responses in order to better manage the Account. 
• • If you contact us, we may use your Other Information to respond. 
• • To provide you with information regarding changes to the Service which may affect your Account, your use of the Service, and/or the products and services available through the Service; 

8.4 Research & Development and Product & Services Improvements 

• • To improve the Website, Platform and or Services for example, Latch may detect patterns of organisational behavioural change, that require new features or improved functionality 
• • For research and development purposes to create new products, and or update products and or services to enrich your experience. 
• • To optimise the Service offering to better deliver on the User requirements. 
• • To monitor and analyse usage, trends and other activities, track user movement and gather statistical information for aggregate use; 
• • To assess service levels, monitor traffic patterns and gauge popularity of different service options 

8.5 Security and Abuse 

• • To investigate, prevent and or detect suspicious activity, potential abuse, security issues, Agreement breaches, potentially prohibited or illegal activities, and to enforce terms and conditions; 

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8.6 Third-Party Service Providers 

Latch may employ Third-Party Service Providers and individuals to: 

• • Facilitate our services 
• • To provide the service on our behalf 
• • To perform service related Services 
• • To assist us in analysing how our Service is used. 

These Third-Party Service Providers have access to your Information in order to perform the tasks assigned to them on our behalf. 

8.7 Access and or Use of Non-Latch Product 

• • Our platform may facilitate links to other sites, if you select a Third-Party Provider link you will be re-directed to that site which is not operated by us. (refer to Privacy Policy Exclusions Section 5) 

8.8 Marketing 

• • To promote the Service or customize advertising that may be visible to you in connection with the Service; 
• • Where you have provided us with consent to do so, to carry out our marketing activities for example, emails outlining new features and or promotions. 

8.9 Legal & Regulatory Compliance 

• • As required by applicable law, legal process or regulation. Data may be identified and processed where necessary for the compliance with a legal obligation to which we are subject, or to protect your vital interest or the vital interest of another natural person, to exercise or in defence of legal claims, to maintain the protection and assertion of our legal rights, yours and the legal rights of others. 

9 Data retention 

Latch will retain and use Information only as long as is necessary to implement, administer and manage our performance obligations under the Agreement, to resolve disputes, to enforce our agreements, to support business operations, to develop and improve our Services or as required to comply with an applicable law. 

If your Latch Service is made available and administered by a Customer Account that was registered by your organisation (e.g. your Company employer) your User Account Information is retained for as long as the Company Customer Account is active. This means, that even after your User Account is deleted, the Information that you may have provided, for example, posts, comments, files, messages or other Information, will remain until the 8 

Customer Account is deleted in order to allow other Users to continue using the Services (for example project files or comments that you may have provided whilst using the Services) 

If your Latch Services are made available directly to you as the registered contracting party and administrator of such Customer Account, then on the deletion of Customer Account, the Information will be deleted, within 48 hours of receiving an Account deletion request. 

The deletion of Customer Data and other use of the Services by the Customer may result in the deletion and/or deidentification of certain associated Other Information. 

10 How we share or disclose information 

Latch does not sell your information to advertisers or to third parties. Latch does provide an open communications platform and Services which facilitates communication and as such, the sharing of information. The Customer controls their Information and sharing policies and procedures between and in itself and with third-parties. This section explains how Latch shares information. 

10.1 The Customer’s instructions. 

Within the Latch community, when you select to share, communicate and interact through the website and or Services within your selected audience. For example, your email address may be displayed with your comments on a chat or a channel communication. 

10.2 Third-Party Service Providers 

With Third-Party Service Providers who provide services, apps, Websites or assist Latch in providing Services or in supporting our business. 

10.3 Financial 

Financial transactions relating to our Platform and Services may be handled by payment service provides. We share transaction data with payment service providers to the extent necessary for processing, refunding payments or dealing with complaints or queries in relation to payments. 

10.4 Customer Administration 

The Customer may administrate and oversee User Accounts and all the associated information. 

10.5 Non-Latch Product 

Latch may share Information to facilitate and or enable the Customer and the User to access and make use of the services, applications, content of Non-Latch Product supplied by Third-Party Providers. (refer to the Exclusions section 5) 9 

10.6 Corporate affiliates. 

Latch may share Information with any member of our group of companies, this means our subsidiaries, ultimate holding company and all its subsidiaries. 

10.7 Latch business transaction 

A change in Latch’s business, such as financing, merger, consolidation, asset sale, acquisition, bankruptcy, insolvency, dissolution or re-organisation or some such similar transaction, Information may be shared or transferred subject to the standard Confidentiality Agreements. 

10.8 Business 

For the purposes of obtaining insurance cover, managing risk or obtaining professional advice in the general running of the business. 

10.9 Legal Compliance and enforcements of rights. 

Where disclosure is necessary for compliance with a legal obligation or regulation, investigation of fraud or in defence of legal claims including out of court procedures and in the defence and protection of rights. 

10.10 Safety and Security 

Where disclosure is necessary for safety and security such as the investigation of suspicious activity or breaches of our terms or policies 

10.11 De-identified or Aggregated data 

Data that is de-identified, so that it is no longer reasonably associated with an identified or identifiable natural person, may be retained and used by Latch for any business purpose for example to analyse trends for research and development in order to improve our Services but it will not be used to specifically analyse any personal characteristics about you. 

11 Security 

Latch takes security and reliability very seriously and we do our utmost to make sure our platforms are failsafe by using best of breed products and adhering to the highest industry practices. We may, at our sole discretion, enhance security procedures as new technologies and procedures become available. We use technical and organisational measures to safeguard your Information that we collect, process and store to prevent suspicious activity or breaches of our terms or policies. Technical and organisational measures include measures to deal with any suspicious activity and or suspected data breach. However, no system is perfectly secure or reliable, the internet is inherently an insecure medium. When you use the Latch Platform and or Services you accept that there are risks from intrusion by others. 10 

12 Age limitations 

Latch expressly prohibits the use of our website and Services to anyone under the age of 16 years. Latch Services are not knowingly provided to individuals under 16 years of age. If we learn that a child under the age of 16 years has provided us with information, we will take the necessary steps to delete such information. 

13 Contacting Latch 

Please feel free to contact Latch if you have any questions about this Privacy Policy or Latch’s practices or if you are seeking to exercise any of your statutory rights. You may contact us at support@latch.chat