PRIVACY POLICY Effective: January 11, 2019

Thanks for using Portal Entryways! This Privacy Policy (this “Privacy Policy”) serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive and collect when you access and use our website (our “Website”), use our mobile application (the “App”), or access and use such other subscriptions and services that may be provided by us from time to time, such as our accessibility services (collectively with the services provided through the App and the Website, the “Services”). This Privacy Policy is a legally binding agreement between Portal Entryways, Inc. (“Portal Entryways,” “we,” “our” or “us”) and you (and your employer or an entity if you are acting on their behalf) (“you” or “your”) as the user of the Services. By using the Services, you hereby warrant and represent that: (i) you have read, understand and agree to this Privacy Policy, and (ii) if you are acting on behalf of your employer or an entity, you have the authority to accept and agree to this Privacy Policy. PLEASE DO NOT ACCESS OR USE THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on our Website. Your use of the Services following any such notice will signify and constitute your agreement to and acceptance of such revised Privacy Policy.

1. INFORMATION COLLECTION. The types of information that we may collect and access from you in connection with your use of the Services are described below. For the purposes of this Privacy Policy: (i) “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, phone number, and e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data, and (ii) “Non Personal Information” means information collected by us or our service providers in a form that does not personally identify you. Non-Personal Information can include certain Personal Information that has been de-identified; that is, information that has been rendered anonymous. In this Privacy Policy, we refer to all information collected from or about you, including Personal Information and Non-Personal Information, as “Your Information.”

2. PROFILE AND LOGIN INFORMATION. When you use the Services, we collect Personal Information that you voluntarily provide or that is provided to us from third parties when you setup your account in or otherwise use the App. For example, if you login to the App using your Facebook or Google credentials, we will receive information from Facebook or Google, respectively, in accordance with your Facebook or Google privacy settings. Such information may include your full name, Facebook/Google username, gender, age range, e-mail address, profile photo, country, region and city location, your time zone and any other information you have permitted Facebook and/or Google to share with us.

3. INFORMATION YOU PROVIDE DIRECTLY TO US. We will collect any Personal Information or other information that you voluntarily provide to us when you interact with us, for example, any Personal Information that you include in any e-mail communications with us or message requests to facilities managers. If you contact us, whether by e-mail, telephone or otherwise, we may keep a record of that correspondence (including any of Your Information included therein) and your contact details.

4. LOCATION INFORMATION. When you use the Services, we may receive information about the location of your device based on its proximity to a door that is powered by the Services (“Location Information”). We may collect, use and share the Location Information to provide you with the Services; provided that your Location Information will only be displayed and shared with others as necessary to provide the Services (such as sending a request to the facilities manager to repair a door) and for no other purpose. Most browsers and devices provide tools to allow you to turn off location services, so please turn off such location services if you do not wish to provide us with Location Information. But note that the functionality of the Services will be severely impaired or may become unavailable if you do not provide us with such Location Information. By using the Services, you consent to the use of your Location Information to provide the Services.​

5. DEVICE INFORMATION. Portal Entryways and its service providers (such as Google Firebase Analytics), may also collect information about the device you’re using the Services on, including what type/model of device it is, what operating system and version you’re using, what country you are located in, what app store was used to download the App, unique device identifiers, your age range, and crash data. Whether we collect some or all of this information often depends on what type of device you’re using and its settings. To learn more about what information your device makes available to us, please also check the policies of your device manufacturer or software provider.​

6. INFORMATION ABOUT YOUR USE OF THE SERVICES. Portal Entryways and our service providers will automatically collect certain information about your use of the App. Such information includes, without limitation: (i) total number of App launches, (ii) total number of App openings, (iii) total number of logouts, (vi) time zone you are located in and (v) your Location Information.

7. USAGE AND ANALYTICS INFORMATION. Portal Entryways and our analytics providers and other service providers, including but not limited to Google Firebase Analytics, Google Analytics, and Hotjar may use a variety of technologies, now and hereafter devised, that automatically record certain traffic and usage information related to the Services. Such technologies include cookies (as described below), as described in further detail below. We may receive reports based on the use of these technologies by these service providers on an individual and aggregated basis. When accessing the Services, Portal Entryways and our service providers may log information about your use of the Services (the “Usage Information”) such as your IP address, access URL, time of access, geographic location, language settings, browser type, referral URL, how often you visit the Website, what pages you visit when you do so and what other sites you used prior to coming to our Website. This information is used in the aggregate and is not linked back to any Personal Information.  Cookies are small text files that are stored on your computer or in your browser. Portal Entryways and our analytics providers may use cookies to collect Usage Information in order to analyze trends, administer our Services, track your movements around our Website, better understand how you interact with our Services, determine interest in particular content and monitor aggregate usage of our Services and online traffic routing. This helps us to identify how users use our Service so that we can continue to develop and improve it. We may also use this information for reporting and analytics purposes. This information is collected anonymously, in a manner that does not personally identify you. Most Web browsers automatically accept cookies, but you may be able to instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. You also have the option to prevent Google from acquiring and processing data generated by cookies by downloading and installing a Google-provided browser plugin at https://tools.google.com/dlpage/gaoptout. However, if you choose to decline or opt out of cookies, you may not be able to use some or all of the features of our Services. By using the Services, you consent to the collection and processing of data about you using cookies in the manner and for the purposes set forth herein.

8. OUR USE OF YOUR INFORMATION. We mainly use Your Information, either alone or in combination with other information, so that we can provide, enhance and personalize our Services. Your Information is used and disclosed for, but is not limited to, the following purposes: to provide you with the best user experience possible;to respond to your questions and comments;to communicate with you regarding updates to our Services;to send you any information that you have agreed to receive or requested from us;to help us develop, customize, deliver, support and improve our Services and content;to protect the rights or property of our users, and prevent fraud and other prohibited or illegal activities;for distribution to third-party service providers that provide services to us;to protect the security of our Services and business;to conduct system administration and system troubleshooting and to diagnose or fix technology problems;for marketing and advertising purposes;for our internal purposes (such as auditing and data analysis);otherwise, as described herein or as disclosed to you at the point of collection; andto monitor and analyze use of the Services and for the technical administration of the Services. We may combine your Personal Information with Non-Personal Information and aggregate it with information collected from other users or sources to attempt to provide you with a better experience, to improve the quality of our Services, and to analyze and understand how our Services are used. We may also use the combined information without aggregating it to serve you specifically. After you terminate your use of the Services, we may continue to use your Non-Personal Information for statistical purposes or other purposes as we see fit. Please note that we cannot guarantee that Non-Personal Information will not identify you as we cannot guarantee that others with access to Non-Personal Information may not have knowledge sufficient to identify you.

9. INFORMATION SHARING. We will not rent or sell your Personal Information to others. Non-Personal Information may be provided to third parties for marketing, advertising, or other uses.

10. OUR SERVICE PROVIDERS. To operate the Services, we may share Your Information with our agents, customers, representatives and contractors so they can provide us with support services and other features and so we can provide support and the Services to our customers. We also may engage third-party companies and individuals to perform services on our behalf or to assist us in analyzing how our Services are used. These third parties may have access to your Personal Information. If they do, this access is provided so that they may perform these tasks on our behalf and we ask these third parties not to otherwise use or disclose your Personal Information in ways that are prohibited by this Privacy Policy, except to the extent required by law. However, Portal Entryways is not responsible for the privacy policies and/or practices of such third parties.

11. THIRD-PARTY PRODUCTS AND OUR SERVICES. Our Services may, from time to time, contain links to and from third-party websites and online services. The fact that we link to a website or display an advertisement or other third-party content or product is not an endorsement, authorization or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices. If you follow a link to any of those websites, please note that such websites have their own privacy policies and that we do not accept any responsibility or liability for those policies. Other websites, products and services may place their own cookies or other files on your computer and/or collect data or solicit Personal Information from you. We encourage you to read the privacy policies and other terms of such third parties before using their services.

12. COMPLIANCE WITH LAWS, LEGAL PROCESS, AND AUTHORITIES. We may disclose any of Your Information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to: (i) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (ii) enforce this Privacy Policy or our End User License Agreement or our Terms of Use; (iii) respond to claims of a violation of the rights of third parties; (iv) respond to user comments or service inquiries; (v) protect our rights, property, or safety and the rights, property and safety of our users or the public; or (vi) prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. However, Portal Entryways will endeavor only to disclose information requested via a valid legal process, and will endeavor to notify any user about whom we have disclosed information if possible.

13. DATA TRANSFER OUTSIDE YOUR JURISDICTION. Portal Entryways processes Personal Information in the United States. We do not offer our Services outside of the United States.

14. BUSINESS TRANSFERS. Circumstances may arise where, whether for strategic or other business reasons, we may sell, transfer or otherwise disclose some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. It’s our practice to seek appropriate protection for Your Information in those types of transactions.

15. OPTING OUT. If you decide at any time that you no longer wish to receive communications from us, please follow any unsubscribe instructions that may be provided on our Website or in our communications to you. Please note that we may use your Personal Information to contact you with important notifications, such as changes to our terms, conditions and policies, and you may not opt out of such notifications. Please also note that we may continue to use Your Information for statistical or other purposes as we see fit after you unsubscribe from any communications and/or terminate your use of the Services.

16. CHANGING OR DELETING YOUR INFORMATION. We keep your data on your behalf and for your benefit. You can correct your Personal Information that we have on file by e-mailing us at support@portalentryways.com, which you may also contact for further assistance and questions regarding this Privacy Policy. You have a right to request access to or deletion of your Personal Information. If you request us to delete your Personal Information, we will delete such Personal Information within thirty (30) business days. All requests to delete, update or access Personal Information will be subject to verification of your identity. We may decline to process change or deletion requests that we deem to be unreasonable, require disproportionate technical effort, jeopardize the privacy of others, or as may be required by law.

17. DO NOT TRACK DISCLOSURES. We currently do not respond to Do Not Track signals.

18. SECURITY. Although we do our best to protect Your Information, we cannot guarantee or warrant the security of Your Information transmitted through the Services and we are not responsible for the theft, destruction or inadvertent disclosure of Your Information. Any transmission of Your Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. The safety and security of Your Information also depends on you. You are responsible for keeping the username and password, if any, used to access the App confidential.

19. COMPROMISE OF PERSONAL INFORMATION. In the event that Personal Information is compromised as a result of a breach of security, Portal Entryways  will promptly notify those persons whose Personal Information has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law. In the event that we or our Website suffers a data security breach that requires us to provide you with notice, such as under applicable law, you consent to allow us to provide you with such notice by sending an e-mail to the e-mail address you have provided to us.

20. NOTIFICATION PROCEDURES. It is our policy to provide notifications, whether such notifications are required by law or are for other business related purposes, to you via e-mail notice, written or hard copy notice, or through conspicuous posting of such notice on our Website, as determined by Portal Entryways in its sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

21. OUR POLICY TOWARD CHILDREN. We do not knowingly collect Personal Information from children under 13 via our Services, and we do not target our Services to children under 13. We encourage parents and guardians to take an active role in their children’s online activities and interests. If we become aware that we have unknowingly collected Personal Information from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our databases. If you are the parent of a child under the age of 13 and have a concern regarding your child’s information on our Website, please contact us at support@portalentryways.com.

22. CHANGES TO THIS PRIVACY POLICY. Our security and this Privacy Policy are periodically reviewed and enhanced as necessary. This Privacy Policy might change as we update and expand the Services. We will notify you of any material changes by posting the new Privacy Policy on our Website. We encourage you to review this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of our policies, you may inquire regarding the same via e-mail at support@portalentryways.com. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.

23. CONTACTING US. If you have any questions about this Privacy Policy, please feel free to contact us via mail at Portal Entryways, Inc., 717 N. 600 W. Provo, UT 84601 or via e-mail at info@portalentryways.com.