Privacy Policy

Last updated:
August 27, 2025

Last Lock Inc Privacy Policy

Scope and Consent

This Privacy Policy (“Policy”) describes how Last Lock Inc (“Last Lock”, “we”, or “us”), with registered office at 25 W. Main Street, Suite 550, Madison, WI 53703, collects, uses, stores, shares, and protects your personal information. It applies to any website run by Last Lock, including www.lastlock.com, all related websites, and any applications, services, products, and tools where this Policy is referenced (collectively the “Site”), regardless of how you access or use them or where you are located. By using the Site, you are consenting to this Policy.

Our goal with this Policy is to provide an open and transparent explanation of the types of information we collect, and how we manage and use personal information.

Throughout this Policy, we use the term “Personal Information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been de-identified, made anonymous, or aggregated so that it cannot be used, whether in combination with other information or otherwise, to identify a specific user.

We may update this Policy from time to time in response to changing legal, technical, or business developments. Please check back from time to time to review the current Policy which is effective as of the revision date listed above. When we update our Policy, we will take reasonable measures to inform you, consistent with the significance of the changes we make. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Site for the first time if material changes are made. Your continued use of the Site after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy. 

Our Pledge on Privacy

We do not share your Personal Information with any third parties except in accordance with our Privacy Policy.

Key Definitions.  

In this Policy, the following words will have the following meanings:

  • “Applicable Privacy Laws” means, as relevant, the EU and UK General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”), the Brazilian LGPD, the Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”), the Japanese Act on the Protection of Personal Information (“APPI”), Australia’s Privacy Act 1988, and any other data-protection statute or regulation that applies to our processing activities.
  • “Personal Information” shall have the meaning set forth in the Applicable Privacy Laws.

What Personal Information Does Last Lock Collect And Why?

The Personal Information that we may collect about you broadly falls into the following categories:

A. Personal Information Collected Directly Through the Site and Our Interactions With You

Creating an Account, Signing up for Communication, Inquiries. 

Certain parts of the Site may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, and/or to submit inquiries to us.

Interactions with Last Lock

We will also collect the following types of information and Personal Information directly from you through the Site and our interactions with you:

  • Your account authentication information (e.g., email, encrypted password, profile image);
  • Personal Information contained in legal agreements (such as invoices and orders);
  • Personal Information included in any job inquiry when you respond to a Last Lock job listing, including by emailing us (this information may be subject to an additional privacy policy specific to employment-related matters);
  • Personal Information, including but not limited to IP address ,or location or device identifier, shared with Last Lock as part of technical support services, including account and product configuration information, usage data, and/or other similar information or to ensure account/location security or block malicious requests;
  • Personal Information you provide to us in communications with us, during a phone call with a Last Lock representative or via webinars and events.

Analytics

Our Site may integrate analytics, including third-party analytics, that track your interactions with the Site, your usage of the Site, and the effectiveness of the Site design and marketing efforts. This may include, without limitation, Square Space Analytics, Google Analytics, or other similar products.  When you interact with the Site or our ads (e.g., clicks, views) and perform conversions (e.g., purchases, form submissions), certain data is collected and processed, including Personal Information. This data may include information about your interactions, device details (such as IP address, device type, browser type), and timestamps of events.

We use this information to:

  • Provide the Site, including its related offerings, services, and programs, and to improve the Site by better understanding how users access and use the Site and to customize their experience (including by estimating audience size and usage patterns, storing information about preferences, speeding up searches, and recognizing when you use the Site);
  • Authenticate users;
  • Process orders;
  • Give you notices about your account, including expiration or renewal notices;
  • Effectuate or enforce a transaction or agreement;
  • Respond to requests or inquiries including for customer service or job listings;
  • Provide technical support, troubleshooting, and security for users of the Site;
  • Fulfill any other purposes for which you provide it;
  • From time-to-time to send you information that we believe may be of interest to you, including news and offers about our products and services or those of our chosen partners, where permissible to do so under Applicable Privacy Laws. Examples can include our blog, newsletter, and co-marketing efforts with our reseller partners.

B. Information that we collect automatically

When you interact with the Site, we strive to make your experience easy and meaningful. Our Site uses technology, or those of third-party service providers, such as cookies, web beacons (clear GIFs) and similar technologies to track user activity and collect site data including analytics information about your use of and activity of the Site (i.e., automatically collected through the Site, such as the Site from which visitors came, Site visitors' IP address, browser type and other information relating to the device through which they access the Site). We may combine this data with the Personal Information we have collected from you.

  • Device Data: As with most websites and technology services delivered over the internet, our servers automatically collect information when you access or use the Site and record it in log files. This log data may include your Internet Protocol (IP) address, device type and settings, hardware MAC address, device ID number, the address of the web page visited before using the Site, error logs, browser type and settings, the date and time the Site were used, information about browser configuration and plugins, and language preferences.
  • Embedded Content: The Site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracing your interaction with the embedded content if you have an account and are logged in to that website.
  • Location Data: We receive information from you that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. We may also collect location information from devices in accordance with the consent process provided by your device.  If you upload images to the Site, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the Site can download and extract any location data from images on the Site.
  • Cookies: We (including our chosen third-party service providers) use cookies to track visitor activity on the Site. For more information about cookies, cookie management, and cookie deactivation, contact us at info [at] lastlock.com. Where required by Applicable Privacy Laws, we will obtain your consent before placing non-essential cookies on your device.
  • Third Parties: As noted, when you use the Site, certain third parties may use information collection technologies, including automatic information collection technologies, to collect information about you or your devices.  For example, we may also engage third parties to track and analyze Site activity on our behalf. To do so, these third parties may place cookies or web beacons to track user activity on the Site. They may collect information, including Personal Information, about your online activities over time and across different websites, apps, and other online services. We use the data collected by such third parties to administer and improve the quality of the Site, analyze usage of the Site, and provide a more enhanced user experience on the Site, such as personalizing and delivering relevant offers and content based on user activity on the Site. We do not provide these third parties with your Personal Information.

C. Information Collected Through Last Lock Products

Some information is processed and stored directly on the Last Lock hardware product. We may collect the following types of Personal Information from and through certain of Last Lock products as part of their routine functioning and/or in connection with enhanced features enabled on the Site:

  • Access Control Data: This includes:
    • Data about individuals using the access control devices (e.g. full name, email address, organization association, organization address, profile image, start/end date, badge ID, employee ID, display name, etc.), associated access group(s), access level(s), access credentials, and historical event information; and
    • Door usage data, including list of door events and entry/exit actions by individual user.

We use information collected from Last Lock products to:

  • Authenticate users;
  • Provide Last Lock products to customers and to improve them;
  • Send customer alerts (e.g., motion notifications, tamper alerts, etc.) generated by your Last Lock products;
  • Respond to customer requests or inquiries, and for similar, customer service-related purposes;

D. Information From Other Sources

From time to time, we may obtain Personal Information about you from third-party sources, including publicly available sources such as professional contact pages of company websites.

We may also receive Personal Information about you from companies who provide us with marketing services, but only where these third parties either have your consent or are otherwise legally permitted to disclose your Personal Information to us.

The types of information we collect from other sources include your professional contact information (such as name, office address, work email address, work phone number).

We use this information to send you material that we believe may be of interest to you, including news and offers about our products and services, where permissible to do so under Applicable Privacy Laws.

E. Information Collected Through BLE Proxy Functionality

When you use our products or services that incorporate Bluetooth Low Energy (BLE) Proxy functionality, we may collect additional information to enable secure and efficient device communication. This may include:

  • Device identifiers (such as Bluetooth MAC addresses, UUIDs, or other unique device tokens); 
  • Proximity or location data (e.g., signal strength, timestamp, and approximate distance between devices); 
  • Interaction logs (such as connection attempts, successful authentications, and error events);  and
  • Device type, operating system, and firmware version.

We use this information to:

  • Authenticate users and devices for access control purposes;
  • Facilitate secure communication between authorized devices;
  • Improve the performance, reliability, and security of our BLE-enabled products and services;
  • Detect and prevent unauthorized access or misuse of our systems; and 
  • Analyze usage patterns to enhance user experience and product development.

Legal Basis for Processing Personal Information

Our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

Where the GDPR or UK GDPR applies, we will normally collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Information from you or may otherwise need the Personal Information to protect your vital interests or those of another person.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will inform you of this at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will inform you at the relevant time of those legitimate interests. If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided under the “How to Contact Us” heading below.

Storage of Personal Information

Collected information may be stored indefinitely, in the discretion of Last Lock, unless you contact us requesting its deletion.

Disclosure of Information and Personal Information

We may disclose your Personal Information as follows:

  • To our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties that we use to support our business (e.g., web hosting services, payment processors, banks, and collection agencies);
  • To provide our products and services;
  • To service providers to provide you, on our behalf, information relating to our products or services that we believe you may find of interest;
  • To any competent law enforcement body, regulatory, government agency, court or other third-party in response to a subpoena or where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights (including enforcement of a contract and for billing and collection), or (iii) to protect your vital interests, property or safety of us, our customers, or those of any other person;
  • To an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger, restructuring, reorganization, dissolution, or sale or transfer of any part of our business, whether as a going concern or as part of voluntary or involuntary dissolution (bankruptcy) of our business, provided that we inform the third party it must use your personal information only for the purposes disclosed in this Privacy Policy; and
  • To any other person with your consent to the disclosure;
  • For any other purpose disclosed by use when you provide the information.
  • Note: comments made on the Site may be checked through an automated spam detection service.

In addition to the foregoing, we may share information collected via the BLE Proxy SDK with trusted third-party service providers who assist us in delivering BLE functionality, analytics, or integration with other platforms. These third parties are contractually obligated to use your information only as necessary to provide services to us and in accordance with this Privacy Policy.

Your Data Protection Rights 

Depending on your location, you may have the following rights regarding your Personal Information:

  • Access: You have the right to request access to your Personal Information. There are some exemptions, which means you may not always receive all the information we process. For other access requests, please contact us at info [at] lastlock.com.
  • Erasure: You have the right to ask us to erase your Personal Information in certain circumstances, subject to statutory exceptions. Please contact Last Lock at info [at] lastlock.com if you have questions regarding how to delete your account or information associated with it. If you choose to delete an organizations  account, then all the data associated with your organization’s Last Lock account will likewise be deleted, including any stored image thumbnails or archived video footage. We may retain certain data for a longer period of time if we are required to do so for legal reasons. If you are an individual whose information may have been collected by Last Lock products in use by one of our customers, please contact the operator of the Last Lock system to request deletion of such Personal Information.
  • Rectification: You have the right to ask us to rectify information you think is inaccurate and to complete information you think is incomplete. For rectification requests, please contact us at info [at] lastlock.com.
  • Object/Restrict Processing / Request Portability: In certain circumstances, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. To make such a request, you can contact us info [at] lastlock.com.
  • Opt-Out of Marketing Communications: You have the right to opt-out of marketing communications we send you at any time. You can exercise this right at any time by following the opt-out link or instructions contained in any such email and follow the instructions listed there. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us at no-spam [at] lastlock.com. Please note that it may take a few business days for us to process opt-out requests and we will need to retain your Personal Information on a suppression list to honor your opt-out request. If you opt-out of receiving marketing emails or promotions, we will still send you service-based emails where requested by you, or in reference to other customer service purposes in accordance with this Policy.
  • Withdraw Your Consent: Similarly, if we have collected and process your Personal Information with your consent, then you can withdraw your consent at any time by emailing info [at] lastlock.com. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.  If you withdraw consent for the use or disclosure of your personal information for certain purposes set out in this Policy, we may not be able to continue to allow you to access the Site or provide you with use of the Last Lock products.
  • Complain to a DPA: You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with Applicable Privacy Laws.

Your Data Protection Rights (California Residents)

If you are a resident of California and interact with us as a consumer, you have certain rights under the California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.), as amended, including to request access to and deletion of your Personal Information. You may exercise these rights as explained above with respect to EEA and UK residents, or by contacting us at info [at] lastlock.com.

We do not sell your Personal Information, but we may allow our advertising partners to collect certain device identifiers and electronic network activity to show ads that are targeted to your interests. To opt out of having your Personal Information used for targeted advertising purposes, please unsubscribe via the link in the marketing email you have received.

California Residents under 16 years of age may have additional rights regarding the collection and sale of their Personal Information.

Your Data Protection Rights (Japanese Users)

If you are located in Japan, please note that your personal information may be transferred to and processed in countries outside of Japan, including the United States. We ensure that such transfers are conducted in accordance with the Act on the Protection of Personal Information (APPI) and that appropriate safeguards, such as standard contractual clauses or equivalent measures, are in place to protect your information. For more information about these safeguards, or to request a copy, please contact our privacy team at info [at] lastlock.com

Your Data Protection Rights (Brazil, Canada, Australia, and Other Jurisdictions)

To the extent required by local law, you may have similar rights to those listed above. We will handle such requests in accordance with the applicable statute and within the prescribed timelines.

Your Data Protection Rights – BLE Proxy Functionality (All Users)

If required by Applicable Privacy Laws, we will obtain your consent before collecting or processing BLE-related data that may be considered personal information. You may withdraw your consent or disable BLE functionality at any time through your device settings or by contacting us at info [at] lastlock.com. Disabling BLE functionality may limit your ability to use certain features of our products or services.

How We Protect Your Information

We implement industry-standard security measures to protect information collected, including information collected via BLE Proxy functionality. These measures may include, where applicable, encryption of data in transit, secure storage of device identifiers, and regular security assessments. 

Third-Party Links

The Site contains links to other, third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Third-Party Advertisers

Our Site uses third-party advertisement platform providers and their free conversion tracking features on certain pages. If you visit the Site, the destination page may have embedded code that will help us understand the path you took to arrive on that page.

International Data Transfers

Last Lock is headquartered in the United States and most of our primary services are located there. Consequently, your Personal Information may be transferred to, processed in, stored in, or accessed from jurisdictions other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). 

Information collected via BLE Proxy functionality  may be transferred to, and processed in, countries other than your country of residence, including the United States. We have implemented safeguards to ensure an adequate level of data protection for such transfers, as described in this Policy. 

By providing your information to Last Lock, you acknowledge the transfer of your information to the United States for storage, use, processing, maintenance, and onward transfer of such information to other entities, regardless of their location. However, such activities will be done in accordance with this Policy and any relevant Terms of Service. Where required by Applicable Privacy Laws, Last Lock has implemented safeguards to ensure an adequate level of data protection for your Personal Information. Further details can be provided upon request.

Data Retention

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). Please refer to product information which may contain additional details about device specific data retention and deletion. We retain BLE-related data only as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by law. When no longer needed, BLE data will be securely deleted or anonymized. 

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Children and Minors

The Site is not directed to individuals under the age of 18, and we do not knowingly collect information from anyone under 18. If you become aware that a child has provided us with personal information, please contact us at info [at] lastlock.com.  If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information as soon as possible.

How to Contact Us

We encourage your questions and comments about how your data is collected, used, or retained. To request deletion of your data, or any other privacy concerns, please contact us at info [at] lastlock.com.