Privacy Policy

1. What Personal Information Will Luxer One Process, and Why?

A. Information Processed to Provide the Service

We collect and process the following categories of personal information in order to provide our locker management and package delivery services:

1. Name
2. Email address
3. Job title or role (for property managers and administrators)
4. Mailing address and property/facility information
5. Telephone number
6. Account credentials and portal access and usage records
7. Package delivery and locker access logs
8. Billing and payment information

B. Information Processed for Business Purposes

In addition to providing the Service, we process personal information for the following legitimate business purposes:

• To administer, maintain, and improve the Service and our locker solutions
• To develop and update our products and services
• To send package delivery and pickup notifications (email, SMS, and push)
• To respond to support requests and other communications
• To send administrative notices, including updates to this policy
• To detect, prevent, and address fraud, security incidents, and technical issues
• To conduct statistical analysis and internal recordkeeping
• To comply with legal and regulatory obligations
• To contact you regarding sales and as part of our customer relationship processes (where consent has been provided)

C. Information Collected Automatically

When you use our Service, we may automatically collect certain technical information using cookies, pixels, and similar tracking technologies, including:

• Device identifiers and IP addresses
• Browser type, operating system, and referring URLs
• Pages visited, time spent on pages, and links clicked
• Location data (where applicable and permitted)

A "cookie" is a text file stored on your device for record-keeping purposes. "Pixels" are small, invisibly embedded graphics with unique identifiers used to track web user movements. We do not control how third-party analytics providers use pixels. For detailed information, please see our Cookie Policy. You may set your browser to reject cookies, though some features of the Service may not be available without them.

We use Google Analytics to track website usage statistics. Google's use and sharing of information collected by Google Analytics is governed by the Google Analytics Terms of Service.

D. Information Received from Third Parties

We may receive personal information about you from:

• Property management companies or employers who deploy Luxer One systems
• Delivery carriers (such as UPS, FedEx, USPS, and Amazon)
• Other ASSA ABLOY Group entities
• Analytics, identity verification, and payment processing service providers

2. Legal Basis for Processing

We will always use your personal information with a lawful basis. We process your personal information when:

3. Transfer and Sharing of Personal Information

3.1 ASSA ABLOY Group Entities

We may share your personal information with other legal entities within the ASSA ABLOY Group. Such sharing is limited to what is necessary to provide the Service or to fulfill our business purposes as described in this policy.

3.2 Service Providers

We may share your personal information with third-party service providers (such as IT hosting providers, payment processors, email delivery services, and legal counsel) who act on our behalf. These providers may only use your personal information according to our instructions and are prohibited from using it for their own independent purposes.

3.3 Property Managers and Administrators

If you use a Luxer One locker at a residential property, office, university, or other facility, the administrator of that location may have access to certain information, including package delivery logs and access records, as required for property management purposes.

3.4 Delivery Carriers

We may share limited personal information with delivery carriers to facilitate package delivery and pickup.

3.5 Do Not Sell My Personal Information

Luxer One does not sell or rent your personal information to third parties. We may share your personal information with service providers and other ASSA ABLOY Group entities only for "necessary" purposes as described in this policy. Neither our service providers nor other ASSA ABLOY entities sell your personal information.

California residents may exercise their right to opt out of any sale or sharing of personal information by visiting: www.luxerone.com/do-not-sell-my-personal-information or by contacting us as described in Section 11.

3.6 Business Transfers

If Luxer One is involved in a merger, acquisition, reorganization, or sale of all or a portion of its assets, your personal information may be transferred as part of that transaction. We will notify you of any change in ownership via email and/or a prominent notice on our website.

3.7 Legal Requirements

We may disclose your personal information if required by law or in response to valid legal requests (such as subpoenas, court orders, or government regulations), or where we believe disclosure is necessary to protect the rights, property, or safety of Luxer One, our users, or the public.

4. International Use and Data Transfers

Luxer One operates with servers and offices in the United States. It is possible that your personal information may be transferred to, stored, or processed in the United States or other countries in connection with our operations and those of our service providers and ASSA ABLOY affiliates.

We take measures to protect all personal information transferred to third parties or to other countries, in accordance with applicable data protection laws. For EU customers, we can offer a Data Processing Agreement upon request. Please contact us using the information in Section 11.

When you use the Service, you understand and consent to the collection, storage, processing, and transfer of your personal information to our facilities and to those of authorized third parties as described in this policy.

5. Data Retention

ASSA ABLOY and Luxer One store personal information for as long as necessary to fulfill the purpose for which it was collected, unless a longer retention period is required or permitted by law. We delete personal information when it is no longer necessary to process a request or order, or to manage your account or our client relationship, and when the required retention period has expired.

Package delivery and access logs are typically retained for up to three (3) years for operational and legal compliance purposes. Account information is retained for the duration of your account and for a reasonable period thereafter.

6. Your Rights

6.1 Right to Know Personal Information Collected

You have the right to know which personal information has been collected from you, including the categories of personal information, the purposes for which it was collected, and whether it has been disclosed and to whom.

6.2 Right to Access and Rectification

You have the right to request access to the personal information relating to you and to request correction of inaccurate or incomplete information. We will make good-faith efforts to resolve such requests, except where (1) the request is unreasonable, (2) it requires disproportionate technical effort or expense, (3) it jeopardizes the privacy of others, or (4) it is otherwise impractical.

6.3 Right to Deletion

You may request that your personal information be deleted in the following situations:

• The personal information is no longer necessary for the purposes for which it was collected
• You object to processing where we have no overriding legal basis to maintain it
• The processing is unlawful
• Deletion is required to comply with a legal obligation

Please note that we may retain personal information where required or permitted by law. We are not required to delete information that federal or state law requires a third party or us to maintain, that is anonymized, or that was provided in exchange for compensation or other consideration.

6.4 Right to Equal Service (Non-Discrimination)

Luxer One does not discriminate against users who exercise their privacy rights. You are entitled to exercise your rights without prejudice to receiving different services in quantity or quality.

6.5 California Residents (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), including the right to:

• Know the categories and specific pieces of personal information collected about you
• Know whether your personal information is sold or shared and to whom
• Opt out of the sale or sharing of your personal information
• Request deletion of your personal information (subject to exceptions)
• Correct inaccurate personal information
• Limit the use and disclosure of sensitive personal information

California Civil Code Section 1798.83 allows California residents to obtain, once per year free of charge, a list of any third parties to whom we have disclosed personal information for direct marketing purposes in the preceding calendar year. To request this information, contact us at: Attn: ASSA ABLOY AMERICAS Data Protection Manager, 110 Sargent Dr., New Haven, CT 06511, with "California Privacy Rights" as the subject.

6.6 Nevada Residents

Nevada residents may opt out of the sale of their personal information by contacting us at privacy@luxerone.com.

6.7 How to Exercise Your Rights

To exercise any of the rights described above, please contact us using the information in Section 11, or visit: www.luxerone.com/do-not-sell-my-personal-information.

7. Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies to enhance your experience on our Site. For detailed information about the types of cookies we use, the purposes for which we use them, and how you can manage your preferences, please see our Cookie Policy.

The only way to completely opt out of the collection of information through cookies or other tracking technologies is to delete and disable cookies and other tracking/recording tools in your browser settings. Please note that doing so may affect the availability of certain features of the Service.

Your selection of the "Do Not Track" option in your browser may not affect our collection of personal information, as there is currently no uniform industry standard for honoring such signals.

8. Security

We maintain technical, physical, and administrative security measures designed to protect your personal information against loss, misuse, unauthorized access, disclosure, or alteration. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security assessments.

However, no transmission of data over the Internet can be 100% secure. There is always a risk that information collected by and displayed on the Service may be compromised or accessed, notwithstanding the steps we take to secure it. Accordingly, you acknowledge that you provide such personal information at your own risk.

9. Children's Privacy

The Service is not directed to children under the age of 18, and we do not intend to or knowingly collect personal information from anyone under 18. If we become aware that personal information has been submitted to us by or relating to a person under 18 in contravention of applicable law, we will delete that information immediately from our servers (unless retention is required by law).

If you believe content from a person under 18 has been posted in our Service, please notify us at privacy@luxerone.com.

10. Changes and Updates to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, regulatory, or operational requirements. We will take appropriate steps to notify users of any such changes, including the date they take effect. The latest version of this Privacy Policy is always available at www.luxerone.com/privacy-policy.

Your continued use of the Service after any updates take effect constitutes acceptance of the changes. If you do not accept any updates, you should stop using the Service.

11. Contact Information

For questions, concerns, or to exercise your privacy rights, please contact us: