PRIVACY POLICY FOR ACCESS MANAGER
BACKGROUND
This Privacy Policy (this “Privacy Policy”) forms a part of the End User License Agreement (hereinafter referred to as the "Agreement") between you and ASSA ABLOY and relates to the downloading, access and use of the App. Capitalized terms in this Privacy Policy have the meaning given to them in the Agreement.
ASSA ABLOY is committed to protecting your personal data. This Privacy Policy describes how ASSA ABLOY processes the personal data (your "Data") that we receive from you in connection with your downloading, access and use of the App.
You have downloaded and installed the App for use with the lock(s) you have or have had installed. Any processing of your Data in relation to your use of the App is subject to this privacy policy. ASSA ABLOY acts as a provider of the App and processes your Data in its role as controller of your Data.
Any inquiries that you may have about how ASSA ABLOY processes your Data should be directed to ASSA ABLOY using the contact details found below.
1. THE DATA WE MAY COLLECT, STORE AND PROCESS
We will collect, store and process your name, phone number, email address(s) and your user account details such as User Name and Password/PIN, technical data and related information about the Device being used by you for accessing and using the App, including unique push ID, operating system, application software and peripherals.
We will also collect, store and process information related to the use and performance of the App.
2. WHY WE COLLECT THE DATA
We collect your Data to be able to grant you the License to use the App, to administrate the App and to communicate with you about the App.
In addition to the above mentioned use and purposes, we will as Data controller use your Data to improve the App and other products, improve and develop new products, for our internal records, for statistical analysis and as a part of our customer relation procedures.
ASSA ABLOY’s collection of Data is based on the need to carry out the processes stipulated above. To the extent that ASSA ABLOY uses the Data to improve the App and other products, improve and develop new products, for internal records, for statistical analysis and as a part of the customer relation procedures, the legal basis for the processing of your Data is ASSA ABLOY’s legitimate interest to conduct such improvements and analysis. Since only limited information related to the use and performance of the App is used, we have concluded that ASSA ABLOY’s legitimate interest to process your Data overrides your privacy interest.
3. HOW WE OBTAIN DATA
We obtain Data when you download the App, when you fill in the necessary Data to download and access the App, when you use the App or when you contact us directly or from your other transactions or experiences with us or with any other ASSA ABLOY group company.
4. WHO WE MAY DISCLOSE DATA TO
For the stated purposes, Data may be transferred to ASSA ABLOY group companies in countries around the world (which may be located outside the EU/EEA, European Economic Area) which in some cases may have a lower level of protection than that within the EU/EEA. When transferring your Data to countries outside the EU/EEA, ASSA ABLOY uses standard contractual clauses approved by the European Commission to ensure a sufficient level of protection for your Data. The standard contractual clauses can be found via the following link: http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm.
Data collected and stored is exclusively used by companies within the ASSA ABLOY group, except in the following cases where we may submit the data to third parties:
- When required by law or as lawfully ordered by a court or authority of competent jurisdiction;
- To a buyer or a potential future buyer of our business, and/or;
- To third party service providers or suppliers appointed by ASSA ABLOY who provide services or products connected or relating to the App or its functions, but only to the extent it is necessary in order to provide you access to and use all of the functions of the App.
ASSA ABLOY will take measures to protect all Data transferred to such third party, or that has been transferred to other countries, in accordance with applicable data protection laws and as stated above.
5. PERIOD OF RETENTION AND USE
ASSA ABLOY stores the Data as long as it is necessary to fulfil the purposes for which the Data has been collected. This means that ASSA ABLOY deletes your Data when the purposes for which it was collected has been fulfilled.
6. TRACKING OF USAGE STATISTICS
The App make use of Google Analytics, an analysis service provided by Google, to help us track usage statistics about visitors to our App on an aggregated level.
Google Analytics collects information such as how often users visit the App and their geographical location. ASSA ABLOY uses the information to improve the App’s technical performance, to optimize the performance of the App’s features, to improve users’ experience of the App, to better tailor the App to users’ interests and needs and to make the App easier to use.
Google’s possibility to use and share information collected by Google Analytics about your visits to our mobile application is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/intl/en/policies/privacy/. For information about how Google uses your Data when you use the App, visit https://www.google.com/intl/en/policies/privacy/partners/.
By installing the App you consent to Google Analytic’s collection and processing of your Data. For information about how to withdraw your consent, visit http://tools.google.com/dlpage/gaoptout.
7. AMENDMENTS
We may amend this Privacy Policy from time to time. When we update this Privacy Policy you will be notified when you access the App and there you will be required to accept the new and updated privacy policy in order to continue to access and use the App.
8. COMPLAINT
If you have a complaint regarding how ASSA ABLOY processes your Data you are entitled to report such dissatisfaction to the supervisory authority in the country you are located.
9. YOUR RIGHTS TO ACCESS AND CORRECT THE DATA
You may at any time request the rectification or erasure of your Data that ASSA ABLOY processes. You have the right to request a limitation of the use of your Data (for example if you deem Data to be incorrect) or the termination of use of your Data (for example as
regards the use of the Data to improve the App). You are entitled to request a copy of the Data used to process an order, to administrate, access and use the App, in a machine-readable format which you are entitled to transfer to another data controller.
10. CONTACT
Any inquiries that that you may have about how ASSA ABLOY AB (publ)corporate registration number 556059-3575 processes your personal data for which ASSA ABLOY is the controller shall be addressed to ASSA ABLOY AB (publ), P.O. Box 70340, SE-107 23 Stockholm, Sweden with attention to: ASSA ABLOY Group the Data Protection Manager st.privacy@assaabloy.com.
