App Data Privacy Policy
Implementation of the requirements of Article 25 DS-GVO (Basic Data Privacy Regulation)
The measures to ensure data privacy compliance in accordance with Article 25 DS-GVO are described below.
Developers
The Clex Key smartphone applications for iOS and Android operating systems are developed by Uhlmann & Zacher GmbH, Gutenbergstr. 2 -4, 97297 Waldbuettelbrunn. The software is used for opening and closing the locking units in systems manufactured by Uhlmann & Zacher GmbH and your OEM partners.
Data privacy officer
Mr Konrad Griebel; Phone: +49 (0) 931 406720; E-Mail: contact(at)uundz.de
Access rights of the app
The application requires access to your location to communicate with the locking units. This access right is required to display the locking units within the range of the Bluetooth® module of the mobile terminal and to communicate with the locking units. The app does not require any other access rights.
General data processing information about Uhlmann & Zacher GmbH processing personal data
Personal data is only collected and stored on your own mobile device by the Clex Key software.
Data is only collected if it is entered by the user or generated through conscious interaction with the hardware. No personal data or usage data is collected or sent to Uhlmann & Zacher GmbH.
Processing of personal data by the operator of the locking system from whom you have received a usage invitation
To receive an invitation to use Clex Key, share personal data such as e-mail address and telephone number with the operator of the locking system outside Clex Key. These are stored by the operator on his system and processed. All interactions with the locking units are recorded both on your own mobile device, as well as in the locking units. They can be viewed later by those who have access to your mobile device and by those who manage the locking system. This can also be used to draw inference about your location at certain times and movement profiles could be created by the operator of the locking system. You can not use the application if you generally do not want such data to be collected.
Waldbuettelbrunn, 03.03.2020 - Konrad Griebel, Data privacy officer
Implementation of the requirements of Article 25 GDPR (General Data Protection Regulation)
The measures to ensure data privacy compliance in accordance with Article 25 GDPR are described below.
Developers
The Keyng smartphone applications for iOS and Android operating systems are applications for managing Clex private locking systems and are developed by Uhlmann & Zacher GmbH, Gutenbergstr. 2-4, 97297 Waldbüttelbrunn.
Data privacy officer
Mr Konrad Griebel; Phone: +49 (0) 931 406720; E-Mail: contact(at)uundz.de
Access rights of the app and data usage
- Bluetooth® & NFC
for the communication with transponder keys and electronic locks the application needs access to the Bluetooth and NFC modules of your smartphone
- Location (due to Bluetooth® communication)
The application does not directly use location data, but by using Bluetooth® communication and interacting with BLE devices, other persons could draw conclusions on previous locations. Your Interaction with electronic locks are logged on the locks itself and other persons in possession of a service key of your locking system can see and evaluate this data.
- Contacts (read)
For the selection of individuals and the creation of mobile keys, the contact list is read and displayed directly by the app. Of the chosen contacts, names, e-mail and mobile phonenumber are saved in the app itself.
- File system (read & write)
For manual database exports and imports by the users, the application requires access to the file system.
The app does not require any other access rights.
General data processing information about Uhlmann & Zacher GmbH processing personal data
Personal data is only collected and stored on your own mobile device. Data is only collected if it is entered by the user or generated through conscious interaction with the hardware. No personal data or usage data is collected or sent to Uhlmann & Zacher GmbH.
The following information refers to data privacy measures for personal data that you collect from third parties as a user, as well as requirements of Art. 25 GDPR from you as the administrator of a locking system using the Keyng application.
Implementation of the requirements of Article 25 GDPR
The measures to ensure data privacy compliance in accordance with Article 25 GDPR are described below.
1. Software operation
With the Keyng management software, a Clex private locking system is managed locally from a mobile device. The Keyng program is operated by the organisation using it or an individual and runs on his/her own mobile device. The responsibility for data privacy lies with those mentioned above.
2. User authorisation concept
The Keyng software is designed for only one user. This user is the owner of the mobile device. Users have to ensure that only they have access to their mobile device and it is advisable to enable the security features such as automatic locking and biometric data for authorisation on the device.
3. Storing, sending and resetting passwords
The Keyng software does not have its own password management. Therefore, login data or passwords are not stored.
4. Access concept
The user has access to the data pertaining to keys and locks entered by himself/herself such as first and last names, and descriptions. Using a suitable service key, users can also read data from compatible locks.
5. Different authorisation levels
Only the user has access to the personal data stored on the mobile device. Serial numbers of each authorised key is stored on the compatible locks. Other users who possess the same service key can also view these numbers and associated events.
6. Options to block individual program functions for users
A user-dependent blocking of individual software functions is not provided.
7. Identification of personal data in the Software
Using the service key, the user also has access to the technical data of the locks, current authorisations and event logs from the locks. Authorisations of keys on locks are stored both in the app as well as in the concerned lock.
However, only serial numbers of the keys are stored in the lock, but not the assignment of these to individuals. Even events of keys in the lock that were earlier authorised by other users on the lock can be read. An automatic assignment of the IDs to individuals can only be done if the same key is managed by the user by name. Even other users can in turn read events from locks using the appropriate service key. Automatic assignment to individuals in the event log or in the authorization list can be done by these other users only if your system was already aware of this assignment.
8. Options to safeguard the rights concerned
8.1 Right of access under Art. 15 GDPR
The data for the stored keys may contain personal data such as last names and first names, e-mail address and phone number, as well as other personal data in the "Description" field.
To view and share the data for the information purposes, select the respective key in the "Key" tab and either note the data entered there or take a screenshot via the screenshot function of your mobile device.
8.2 Right to rectification under Article 16 GDPR
The data for the stored keys can be changed in the "Key" tab. To do this, select the respective key by clicking on the list, and then click the "Pen" icon to edit the data in the "Data" tab of the key. Events in the event log cannot be changed later.
8.3 Right to erasure under Art. 17 GDPR
To delete a key and the associated data from the list of keys, the authorisation of the key has to be first revoked for each lock. Then, click the "Edit" button in the list of saved keys, and then click on the red "minus symbol" next to the respective key. If only the personal data associated with the key has to be deleted, it is adequate to overwrite the stored data with other data. Proceed as described in section 8.2.
Neither individual entries with personal data nor the entire list can be deleted from the event log even in the software itself. These can only be deleted from the user's device by deleting the application.
8.4 Right to restriction under Art. 18 GDPR
This right cannot be reasonably implemented due to the nature of the data collected in conjunction with the locking system software and is not likely to be used by the concerned individuals.
8.5 Obligation to notify under Art. 19 GDPR
Only personal data is collected and stored on the system of the software operator. A notification to third parties is currently not required after any change or deletion.
8.6 Right to data portability under Art. 20 GDPR
This right cannot be reasonably implemented due to the nature of the data collected in conjunction with the locking system software and is not likely to be used by the concerned individuals.
8.7 Right to object under Art. 21 GDPR
In the event of an objection under Article 21 GDPR, please proceed as described under "8.3 Right to erasure under Art. 17 GDPR".
9. Technical measures to protect the data
Users of the software have to ensure that unauthorised persons do not have access to their personal mobile device. It is advisable to always enable security features such as automatic locking and biometric data for device authorisation. In addition, the security key for accessing data in the locks should always be protected from third party access.
Waldbüttelbrunn, July 6th 2021 - Konrad Griebel, Data privacy officer
Privacy Policy
for ClexFWProg software (for Android)
Realization of the requirements of Art. 25 GDPR (General Data Protection Regulation)
The measures to ensure data protection compliance in accordance with Art. 25 GDPR are described below.
Developer
The ClexFWProg application für Android operating systems is developed by the Uhlmann & Zacher GmbH, Gutenbergstr. 2-4, 97297 Waldbüttelbrunn. The software is used for the firmware update of the locking units in systems of the Uhlmann & Zacher GmbH.
Data Protection Officer
Mr. Konrad Griebel; phone: +49 (0) 931 406720; email: contact(at)uundz.de
Access rights of the app
The application requires access to your location for the communication with locking units. This access right is required to display locking units in reach of the Bluetooth® module of the mobile terminal device and to communicate with the locking units. Beyond that the app requires no further access rights.
General data processing information for processing personal data by the Uhlmann & Zacher GmbH
Personal data are only collected and stored by the ClexFWProg on your own mobile terminal device. Data are only acquired if these are entered by the user themselves or generated through conscious interaction with hardware. When uploading the update history back to the Uhlmann & Zacher server conclusions can be drawn about behavior and movement profiles. In addition firmware data are downloaded from the Uhlmann & Zacher server with user/password which are assigned by the Uhlmann & Zacher GmbH.
No personal data are collected by the Uhlmann & Zacher GmbH or transferred to them.
Waldbüttelbrunn, 2025-07-01 – Konrad Griebel, Data Protection Officer