BlueSky Privacy Policy for USA

BlueSky Privacy Policy for USA
(including California)


Click here for the BlueSky General Privacy Policy

Effective Date:  June 13th, 2021

The California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws provide certain rights for California residents with respect to their privacy, including right to notice, right to access, right to opt out (or right to opt in) of the sale of personal information, if applicable, right to request deletion, and right to equal services and prices.  Because your privacy is important to us and as part of our commitment to you as our valued client, we voluntarily extend the same rights that are available under CCPA and other California privacy laws to all consumers residing in the USA. Any terms defined in the CCPA have the same meaning when used in this Notice. 

Information We Collect

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we may collect the following categories of personal information from consumers from the BlueSky Mobile App. Also, in the past twelve (12) months before the effective date of this privacy notice we may have collected the following personal information.

  • Identifiers: A real name, alias, telephone number, unique personal identifier, online identifier, email address, IP address, login credentials, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, or telephone number.
  • Information that you provide to us: If you contact us by email, your email address, and the information provided by you to us. 

To the extent we may obtain the categories of personal information listed above, this information may come from the following categories of sources:

  • Directly and indirectly from you, your authorized representative(s) and/or the owner/customer of the BlueSky account. For example, from the set-up, registration and use of the BlueSky Mobile app.
  • Indirectly from you. For example, from observing your access to the BlueSky mobile app;
  • From our service providers, distributors, product integrators, resellers, including independent sales representative agencies, partners which have a contract with you or your account owner.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes: 

  • To fulfill or meet the reason you provided the information. 
  • To provide support services to you or the owner/customer of the BlueSky account, which you or the owner/customer of the BlueSky account have requested.
  • To create, maintain, or customize your account and deliver your registration key to your mobile device.
  • To process your requests, purchases, transactions (including any referrals from our service providers, distributors, product integrators, resellers, including independent sales representative agencies, partners), and payments, and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To improve our services to you. 
  • To help maintain the safety, security, and integrity of our products, services, databases and business.
  • For testing, research, analysis, and product development, including to develop and improve our products, and services and to identify trends in various industries.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To meet our obligations and enforce any of our rights that arise from or are related to agreements between you and us. 
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about the users of our BlueSky Mobile app users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. 

We may share your personal information with the following categories of third parties: 

  • Service providers.
  • Our distributors, product integrators, resellers, including independent sales representative agencies, and partners which have a contract with you or your account owner.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months we may have disclosed your personal information for a business purpose to service providers. In the future, we may disclose your personal information for a business purpose to the following categories of third parties: 

  • Service providers.
  • Our distributors, resellers, and partners which have a contract with you or your account owner.

Sales of Personal Information 

We do not sell personal information within the scope of the application of the CCPA, nor have we sold any personal information in the past twelve months. 

Your Rights and Choices 

CCPA provides consumers with specific rights regarding their personal information. This section describes your rights as a consumer and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: 

  1. Complete the transaction for which we collected the personal information, provide a product or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Emailing us at: data.protection@dormakaba.com 
  • Calling us at the following numbers: 1-800-999-6213 (North America) or +1-514-340-9025 (Worldwide)

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: Your email address or phone number.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 

Non-Discrimination

We will not discriminate against you for exercising any of your rights. Unless permitted by the applicable laws, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. If there are material changes to this privacy notice, we provide a prior, prominent notice to you in a manner that will allow you to exercise your privacy rights. 

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in the BlueSky General Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-800-999-6213 (North America) or +1-514-340-9025 (Worldwide)
Email: data.protection@dormakaba.com