JEKASupport

Version 1.16 — in force since October 11, 2026. If you accepted this policy inside a JEKA application, the version you accepted there governs. All policies

MYWATCHTOWER PLATFORM PRIVACY NOTICE

Version 1.16 • Effective Date: October 11, 2026 • For users who accepted an earlier version: November 1, 2026

Effective Date. This version of this Notice takes effect on October 11, 2026. For a person who accepted the MyWatchtower Terms of Service, or an earlier version of this Notice, before October 11, 2026, this version takes effect on November 1, 2026, or on the date that person expressly accepts it, if earlier, and the earlier version continues to apply to that person until then.

This MyWatchtower Platform Privacy Notice (this “Notice”) describes how JEKA Software, Inc., a Delaware corporation with its principal office in Land O’ Lakes, Florida (“JEKA,” “we,” “us” or “our”), collects, uses, discloses and retains personal information in connection with the MyWatchtower platform. In this Notice, “you” means any individual whose personal information JEKA processes through the Platform, including Administrators, Residents, Authorized Users, household members, guests, vendors and visitors. Capitalized terms used but not defined in this Notice have the meanings given to them in the MyWatchtower Terms of Service & End User License Agreement at https://portal.jekasoftware.com/policies/terms-of-service/ (the “Terms of Service”).

Platform. The “Platform” means JEKA’s MyWatchtower software-as-a-service platform, its web and mobile applications, and the MyWatchtower entry kiosks (“Kiosks”) and other cameras with which it operates. “Platform data” means information collected through the Platform.

Communities and Facility Data. MyWatchtower serves homeowners’ associations, community development districts and property operators (each, a “Community”). “Facility Data” means the data generated by or collected from a Community’s use of the Platform. As between JEKA and a Community, the Community owns its Facility Data, and JEKA processes it to provide the Platform. Each Community and its Administrators decide who receives Credentials, which access rules apply, and how entry information is used within the Community.

JEKA’s Role. For Facility Data, JEKA acts as a service provider or processor on behalf of the Community, and the Community is the business or controller that determines the purposes and means of processing. JEKA processes Facility Data to provide the Platform to the Community, for the other purposes the Community’s agreement with JEKA permits (including those described in Section 3), and as applicable law permits a service provider or processor to process it. For account and profile information and for the personal information it processes for its own business operations, JEKA acts for itself as a business or controller. Requests about Facility Data are directed to the Community, as Section 7 provides. JEKA is a technology provider, not a security, guard, or protection service. No product name, service name, or marketing description modifies this Notice.

Relationship to Other Policies. This Notice supplements the JEKA Software Website Privacy Policy at https://portal.jekasoftware.com/policies/site-privacy/, which governs JEKA’s marketing websites. For Platform data, this Notice controls. A Community’s signed agreement with JEKA, including any Data Processing Addendum, governs JEKA’s obligations to that Community.

1. Information We Collect

1.1 Account and Profile Information. Name, email address, telephone number, unit or property, role (Administrator, Resident or staff) and login credentials.

1.2 Sign-In Provider Information. If you sign in through Facebook, Google or Apple, JEKA receives your name, email address and account identifiers from that provider. An email address received from Apple may be a private-relay address.

1.3 Entry and Access Records. Who or what entered or exited; the property; the entrance, gate, lane or door used (the “Access Point”); the entry method; the outcome (approved or denied); timestamps; and related notes.

1.4 Photographs. Entry photographs taken by Kiosks, as Section 10 describes.

1.5 Video Clips and Live Assist Recordings. Kiosk video clips, including Activity Clips (the Kiosk setting “Save clips on movement”), and recordings of Live Assist sessions, as Section 10 describes.

1.6 Vehicle Information. License plate captures from license plate recognition (LPR) cameras, and each vehicle’s make, model, year, color, plate and state of registration.

1.7 Credential Data. Credentials issued through the Platform, including QR codes, PINs, card and fob identifiers with facility codes, and mobile passes, and the history of their use.

1.8 Guest, Vendor and Visitor Records. Names and visit details for persons the Community or its Residents authorize, including standing entries for delivery services and other regular visitors.

1.9 Visitor Identity Data. Where a JEKA-configured handheld scanner or the Platform’s license scan reads a visitor’s driver license or other government-issued identification, the Platform uses the scan to fill in the visitor’s name and address in the visitor’s record for entry processing. The name is shown in the Community’s visitor log to users the Community permits. The Platform stores the identification number in encrypted form, with a one-way code derived from it, so that it can recognize the same identification on a later visit and find that visitor’s earlier entries. JEKA keeps the identification number and that code for up to 3 years. JEKA does not retain the image of the document or the date of birth. The information on the identification is not sold or shared, and is not used for any other purpose.

1.10 Restricted-Entry Records. Records of persons the Community has decided not to admit. The Community creates and controls these records.

1.11 Household-Member Information. Information about members of a Resident’s household, including minors, which the Community or the Resident account holder provides and manages, as Section 9 describes.

1.12 Communications Data. Support tickets and notification history. You opt in to text messages by entering a mobile number for text messages in the Platform or by turning on text notifications. If you opt in, JEKA collects the SMS data described in the JEKA Software SMS / Text Messaging Terms at https://portal.jekasoftware.com/policies/sms-terms/ (the “SMS Terms”), which are incorporated into this Notice.

1.13 MWT Connect Communications. MWT Connect is the Platform’s entry-request communication feature. It is not a telephone service and is not connected to 911. For each entry request sent to you through MWT Connect, JEKA collects the time, duration, number or device reached, and outcome. JEKA also collects the telephone numbers and devices you register for entry requests.

1.14 Community Log Entries. If the Community uses the Community Log module, JEKA collects the entries submitted by users the Community permits, together with their attachments and status history. An entry may include a location the person submitting it places on a map, and a map image of that location. The map service provider listed in the Sub-processor List receives the area the map shows and the location placed on it. These entries are Facility Data. JEKA does not review or act on their content.

1.15 Usage and Device Data. Log data, device and browser information, and analytics about how the Platform is used, collected through cookies and similar technologies.

1.16 Device Location. If you open a door from the MyWatchtower mobile application, the application uses your device’s precise location, on your device, to confirm that you are at the door. If you turn on auto-open for a door, the application also uses your device’s location in the background, including when the application is closed or not in use. Your device’s operating system tells the application when you come near that door. The application then reads your location, on your device, until you reach the door or leave the area. When you are at the door, the application sends JEKA a request to open it. The request names the door and whether it was a tap or auto-open. It does not include your location. While the application reads your location for auto-open, your device shows that the application is using your location. The application may also use your device’s location to center a map it shows you, such as when you place a location on a Community Log entry or an Administrator draws a door’s opening area. JEKA does not store that location.

2. Sources of Information

2.1 Sources. JEKA collects Platform data from the following sources: (a) from you, when you create an account, issue a guest credential or contact support; (b) from the Community and its Administrators, including rosters, property records, access rules and restricted-entry records; (c) automatically, from Kiosks, LPR cameras and other cameras at the Community, and from Live Assist sessions and MWT Connect entry requests; (d) from Facebook, Google or Apple, when you choose to sign in through them; (e) from the Integrator that services the Community’s account (its “Integrator of Record”); and (f) from third-party access-control or video platforms the Community uses with the Platform (“Third-Party Platforms”), such as Brivo, HID and Eagle Eye Networks.

3. How We Use Information

3.1 Purposes. JEKA uses Platform data to: (a) process entries and access decisions, and send entry notifications to the Residents and Administrators concerned; (b) maintain the Community’s entry and audit records; (c) provide Live Assist where the Community has elected it; (d) relay entry requests and their outcomes to Residents and gate staff through MWT Connect; (e) operate the automated assistant for a Community’s MWT Connect number once it is in service, as Section 10 describes; (f) store and display Community Log entries for the Community’s administration; (g) provide support, entry documentation and community administration; (h) safeguard Platform data and address fraud and misuse; (i) maintain and improve the Platform; and (j) comply with applicable law.

3.2 Live Assist. Live Assist is a live person, in a remote capacity, processing visitor-initiated entries under the Community’s configured rules. Entry decisions rest with the Community, the Resident or the Community’s designated decision maker, never with JEKA personnel. With no decision maker reachable, the Community’s standing policy applies, which is denial unless the Community records another.

3.3 AI Model Training. JEKA uses Platform data to develop, train and improve any artificial-intelligence or machine-learning features JEKA offers for entry and visitor processing. Before JEKA uses Platform data to train those features, it removes names, telephone numbers, email addresses, unit addresses, and account identifiers from the records it uses. Entry photographs, video clips, recordings, and license plate images may be used as captured and may show faces and license plates. JEKA does not use Platform data to create biometric identifiers, and does not use it in training those features to identify any individual. A Community may opt out of this use by written notice to legal@jekasoftware.com, as its agreement with JEKA provides. The resulting models and improvements belong to JEKA.

3.4 Device Location. The application uses device location, on your device, only to open the doors you ask it to open or have turned auto-open on for. For this feature, JEKA does not receive, store or share your device’s location. JEKA’s records of an open state the door, the time, and whether it was opened by tap or by auto-open.

4. How We Share Information

4.1 With the Community. The Community’s Administrators can access entry records, recordings and related data for the Community, and Residents can access them as the Community configures. A person who receives an entry notification may use its photographs and recordings only for entry management, entry documentation and community administration, as the Terms of Service provide.

4.2 With the Integrator of Record. JEKA shares Platform data with the Community’s Integrator of Record only as reasonably necessary to service the Community’s account.

4.3 With Service Providers. JEKA shares Platform data with service providers that host the Platform, deliver its messages or otherwise help JEKA operate it, subject to written obligations to safeguard the data. These providers are listed in the MyWatchtower Sub-processor List at https://portal.jekasoftware.com/policies/subprocessors/ (the “Sub-processor List”), which JEKA updates before a new provider begins processing Platform data. Twilio Inc. delivers text messages and MWT Connect calls and video sessions. Apple Inc. (Apple Push Notification service) and Google LLC (Firebase Cloud Messaging) deliver push notifications to the MyWatchtower application. Pushy LLC delivers push notifications to installations of the MyWatchtower application that have not yet moved to Apple or Google push. Radar Labs, Inc. provides the maps the MyWatchtower application shows, and Environmental Systems Research Institute, Inc. (Esri) provides the satellite imagery and address search for its door maps. Mobile opt-in data and consent are not shared with any third party or affiliate for marketing purposes. In this Section 4.3, “mobile opt-in data and consent” means the telephone numbers you register for text messages and your consent to receive them.

4.4 With the Maker of HID Products. Where the Community’s site uses HID products bought from its Integrator of Record, JEKA may provide HID Global Corporation and its subcontractors with the Community’s name, site and contact details, and equipment and troubleshooting information. JEKA provides this information only to place the order and to obtain warranty service and support. HID Global Corporation and its subcontractors may handle the information outside the United States, in countries whose data privacy laws may be less stringent than those of the United States.

4.5 With Third-Party Platforms. JEKA shares Platform data with Third-Party Platforms the Community connects to the Platform, as needed to make the connection work. The terms and privacy policies of each Third-Party Platform govern its services, and JEKA is not responsible for them.

4.6 Legal Process and Rights. JEKA may disclose Platform data when required by law, subpoena, court order or similar legal process; to establish, exercise or defend legal claims; or to protect the rights or safety of JEKA, a Community or any person, or the integrity of the Platform.

4.7 Business Transfers. JEKA may disclose or transfer Platform data in connection with a merger, acquisition, financing, reorganization or sale of all or part of its assets, including during negotiations and due diligence for any of them. The commitments in this Notice continue to apply to the data transferred.

4.8 No Sale or Targeted Advertising. JEKA DOES NOT SELL PERSONAL INFORMATION, SHARE IT FOR CROSS-CONTEXT BEHAVIORAL OR TARGETED ADVERTISING, OR DISCLOSE IT TO THIRD PARTIES FOR THEIR OWN MARKETING PURPOSES.

5. Retention

5.1 Entry Records and Recordings. JEKA keeps entry records, photographs, video clips and Live Assist recordings available to the Community for at least 90 days after capture, or for any longer period the Community’s signed agreement states (the “Retention Period”). JEKA has no obligation to retain any of them after the Retention Period ends, and may delete them at any time after that without notice. JEKA does not commit to delete them on any particular schedule. Where the Community’s signed agreement requires JEKA to keep the records of an entry named in a claim, JEKA keeps them as that agreement provides. While JEKA holds any of them, this Notice continues to apply to them.

5.2 Deletion at the Community’s Direction. The Community may delete Facility Data, or instruct JEKA to delete it, as its agreement with JEKA provides, including in response to a request routed to it under Section 7.

5.3 Public Agencies. A Community that is a public agency remains responsible for meeting the records retention schedules that apply to its own public records, including by exporting those records from the Platform before the Retention Period ends.

5.4 Account Information. JEKA keeps account and profile information while the account is open and for a reasonable period after it closes, as needed for the purposes described in Section 3, to comply with its legal obligations, to resolve disputes and to enforce its agreements.

5.5 Export After Termination. When a Community’s subscription ends, the Community, or another person its agreement entitles, may request in writing an export of the Community’s Facility Data. The request must be made within 30 days after the subscription ends, or within any longer period the Community’s agreement states. JEKA provides the export in commercially reasonable tools and formats. After that period ends, JEKA has no obligation to retain the Facility Data and may delete or de-identify it at any time without notice.

5.6 Legal Requirements. JEKA may retain any Platform data for longer than this Section 5 describes where applicable law or legal process requires it, or to establish, exercise or defend legal claims.

6. Your Choices

6.1 Account Information and Preferences. You can review and update your account information and notification preferences in the Platform.

6.2 Text Messages. Reply STOP to any text message to stop receiving text messages. STOP stops text messages only.

6.3 Entry-Request Calls and Push Notifications. You may withdraw your consent to entry-request calls and push notifications for a number or device at any time. You may do so by changing your notification settings in the MyWatchtower application, by asking the Community’s Administrator, or by telling JEKA by any reasonable means, including by email to legal@jekasoftware.com. If you cannot be reached, or have withdrawn your consent, the Community’s standing policy determines whether your visitor is admitted.

6.4 Telephone Numbers. A person who registers a telephone number in the Platform represents that he or she is the subscriber or customary user of that number, or is authorized by the subscriber or customary user to consent to entry-request calls and messages at that number. The Community is responsible for obtaining and maintaining the consents required for each telephone number it or its Administrators enter in the Platform.

6.5 Device Location. Opening doors from the application and auto-open are optional. The Community decides which doors can be opened from the application and whether auto-open starts on or off for each door. You can turn auto-open off for any door in the application. You can also withdraw the application’s location permission in your device settings at any time. If you withdraw it, the application cannot open doors for you.

7. State Privacy Rights

7.1 Requests About Facility Data. JEKA directs requests about entry records, recordings, restricted-entry records and other Facility Data to the Community, which responds to them. JEKA assists the Community within its deadlines. Send requests about your own account and profile information to JEKA. If the Community controls that information under its agreement with JEKA, JEKA forwards the request to the Community.

7.2 Applicable Laws. Depending on where you reside, state privacy laws may give you rights with respect to your personal information. Those laws include the California Consumer Privacy Act, as amended by the California Privacy Rights Act; the privacy laws of Colorado, Connecticut, Virginia and Texas; and the Florida Digital Bill of Rights, where it applies to JEKA.

7.3 Your Rights. Where such a law applies, and subject to its exceptions, you may have the right to: (a) confirm whether JEKA processes your personal information and obtain a copy of it; (b) request correction of inaccurate personal information; (c) request deletion of personal information, subject to legal and contractual retention requirements; (d) receive the personal information you provided in a portable and, where technically feasible, readily usable format; (e) opt out of the sale or sharing of personal information and of targeted advertising, as Section 4.8 addresses; and (f) exercise these rights without discriminatory treatment.

7.4 Submitting and Verifying Requests. To submit a request, email legal@jekasoftware.com with your name, your account’s email address, your Community and the right you wish to exercise. JEKA verifies each request against its records, usually by confirming that you control the account’s email address. For a request involving sensitive information, JEKA may ask for additional information and will use it only to verify your identity.

7.5 Authorized Agents. Where applicable law permits, an authorized agent may submit a request on your behalf. JEKA requires proof of the agent’s written authorization and may verify your identity with you directly.

7.6 Appeals. If JEKA declines to act on your request, you may appeal by replying to JEKA’s decision or by emailing legal@jekasoftware.com with the subject line “Privacy Appeal.” JEKA will respond within the period applicable law sets. If JEKA denies your appeal, you may contact the Attorney General of your state.

7.7 Global Privacy Control. Where applicable law requires, JEKA treats a Global Privacy Control (GPC) signal as a valid request to opt out of any sale or sharing that the law covers.

8. Safeguards

8.1 Safeguards. JEKA maintains administrative, technical and physical safeguards appropriate to the nature of Platform data, including access controls and audit logging. No safeguard eliminates risk, and no method of transmitting or storing electronic data is free of risk. JEKA does not represent or warrant that unauthorized access to, or acquisition, use or disclosure of, Platform data will not occur.

8.2 Notice to the Community. If JEKA determines, or has reason to believe, that there has been unauthorized access to, or acquisition of, a Community’s Facility Data, JEKA will notify that Community without undue delay and in any event within 72 hours after that time. As the business or controller of its Facility Data, the Community is responsible for any notice to affected individuals or government authorities that applicable law requires of it, and JEKA will assist as the Community’s agreement provides.

8.3 Your Responsibilities. You are responsible for keeping your login credentials confidential. If you believe your account has been accessed without authorization, notify JEKA promptly at support@jekasoftware.com.

9. Children and Minors

9.1 Account Holders. Platform accounts are for adults 18 years of age and older. No one under 18 may hold a Platform account or accept the Terms of Service.

9.2 Household Members Aged 16 or 17. A Resident may enroll a household member who is 16 or 17 years of age to hold Credentials and to use the MyWatchtower mobile application under the Resident’s account. By doing so, the Resident consents to the processing of that minor’s personal information as this Notice describes, supervises the minor’s use of the Platform, and is responsible for it.

9.3 Persons Under 16. No household member under 16 years of age receives a Platform account or Credentials in that member’s own name. A Resident or the Community may issue a guest Credential for a visitor of any age, and is responsible for its use.

9.4 Children Under 13. The Platform is not directed to children under 13 years of age, and JEKA does not knowingly collect personal information directly from children under 13. If JEKA learns that it has collected personal information directly from a child under 13, it will delete that information as applicable law requires.

9.5 Other Information About Minors. Information about minors otherwise comes from the Community or the Resident account holder, as Section 1.11 describes, or from entry cameras that capture minors present at an entry. That information is Facility Data.

9.6 No Sale or Sharing. JEKA does not sell or share the personal information of consumers under 16 years of age.

9.7 Device Location of Household Members Aged 16 or 17. A household member aged 16 or 17 may use the device location features in Section 1.16 only after granting the application location permission on that member’s own device. The application uses that member’s device location only as Section 3.4 describes.

10. Recording Notices

10.1 Kiosk Photographs and Clips. Kiosks are configured to capture a photograph and a video clip of the entries they process. Where the Community turns on Activity Clips, the Kiosk saves a short clip when there is movement at the gate. The clips do not include audio. JEKA configures each Kiosk to display an on-screen notice of recording.

10.2 MWT Connect. An entry-request call or notification that the Kiosk places to a Resident through MWT Connect is not recorded. An automated assistant for a Community’s MWT Connect number is planned and is not yet in service. When it is available, a call it answers may be recorded, and the assistant will say so at the start of the call.

10.3 Live Assist Sessions. Where the Community has elected Live Assist, Live Assist sessions may be recorded for quality assurance, training of Live Assist personnel, and entry documentation. A call a Live Assist representative places to a Resident during a session is part of that session. If JEKA records a Live Assist session, an audible notice that the session may be recorded is played at its start, before any recording begins. The notice is played to the visitor at the Kiosk and to each Resident or Community contact the session reaches. A person who continues after the notice consents to the recording.

10.4 Notifications and Signage. Entry photographs, clips and any Live Assist recordings may be included in entry notifications. The Community is responsible for any additional signage or resident disclosures that applicable law requires for recording at its property.

10.5 No Facial Recognition or Biometrics. JEKA does not use facial recognition, does not identify people biometrically, and does not derive biometric identifiers or biometric information from recordings, photographs or other Facility Data.

11. Location of Processing

11.1 United States. The Platform is intended for use in the United States. JEKA and the service providers listed in the Sub-processor List process and store Platform data in the United States, except as Section 4.4 states for information provided to HID Global Corporation and its subcontractors, and as the Sub-processor List states for Pushy LLC.

12. Changes; Contact

12.1 Changes to this Notice. JEKA may amend this Notice from time to time. For a material change, JEKA will give notice at least 30 days before the change takes effect, through the Platform or by email to the address in JEKA’s records, consistent with Section A.14 of the Terms of Service. Where applicable law requires your consent to a material change in how JEKA uses personal information it collected before the change, JEKA will obtain that consent. The version posted at https://portal.jekasoftware.com/policies/privacy-notice/ governs.

12.2 Contact. Questions and requests about this Notice may be sent to legal@jekasoftware.com, submitted through the support portal at support.jekasoftware.com, or mailed to JEKA Software, Inc., 16703 Early Riser Avenue, Suite 533, Land O’ Lakes, FL 34638. JEKA’s telephone number is (813) 939-7813.