PRIVACY POLICY FOR CLIQ Connect

BACKGROUND

This Privacy Policy forms a part of the CLIQ Connect License and User Agreement and is part of the agreement (the “Agreement”) between You and ASSA ABLOY AB (“We”, “Us” or “Our”). Capitalized terms in this Privacy Policy have the meaning given to them in the Agreement.

We respect Your right to privacy and are committed to following applicable data protection rules to safeguard Your rights. We want to make sure that You understand the type of information We collect about You, how it is used and how We protect it. You can withdraw Your consent at any time by contacting your local CLIQ reseller or ASSA ABLOY representative.

We need to collect some information about You so that We can provide You with the CLIQ Connect App and Services. This Privacy Policy describes the information We collect about You (the “Data”), why We collect the Data, how that Data is treated, for what purposes We may share the Data and how You can contact Us about Your Data.

1. The Data We may collect

2. Why We collect the Data

3. How We obtain the Data

4. Who We may disclose Data to

5. Period of retention and use

6. Transfer

7. Precautions

8. Children

9. Changes

10. Your rights to access and change the Data

11. Your rights regarding the Data

12. Contacts

1. THE DATA WE MAY COLLECT

We may collect the following Data, which might be considered “personal data” according to applicable rules due to other information about You that We, in a lawful manner, might have collected:

Your ID
Technical data and related information about the Device being used for the Services, including unique push ID, operating system, application software and peripherals; and
Information related to the use and performance of the CLIQ Connect App and Services, including access logs.

2. WHY WE COLLECT THE DATA

We collect Your Data to:

License the CLIQ Connect App or Services to You and to enable Us to provide You with the CLIQ Connect App and Services and any associated products or services;
Provide You with software updates and support, improve and develop new products and services, possibly through profiling, and maintain and manage Our websites and other related services;
Fulfill Our legal and administrative obligations (such as making tax returns/payments);
Enforce this Privacy Policy and the CLIQ Connect License and User Agreement; and
Protect the rights, property or safety of Us, Our customers or others.

We do not sell or trade the Data or collect or use it for advertising purposes.

3. HOW WE OBTAIN THE DATA

We obtain Data in a variety of ways. For example when You contact Us directly by email concerning the use of the App or Services or from Your other transactions or experiences with Us.

4. WHO WE MAY DISCLOSE DATA TO

We may share the Data with other companies in the ASSA ABLOY group, as well as certain trusted business partners and third party service providers to enable them to perform functions of the Services and to process Data on Our behalf, in accordance with the purposes in Section 2 above.

We do not control the privacy and data security practices of these third parties but We will take appropriate and reasonable steps to ensure that the Data will only be used for the purposes described in this Privacy Policy and in accordance with applicable law, even if We do transfer or disclose Data to other companies within Our group of companies (the ASSA ABLOY group) or to Our suppliers or subcontractors.

We may use Google Analytics when obtaining the data for the purposes set out above. Information about how Google collects and processes data can be found at the site “How Google uses data when you use our partners’ sites or apps”, (located at http://www.google.com/policies/privacy/partners/).

If applicable, Data may also be transferred to:

Local or foreign regulators, governments and law enforcement authorities, including tax collection agencies and stock or other exchanges;
Local and foreign courts, tribunals, arbitrators or other judicial committees;
Persons to whom We may assign or transfer Our rights or duties under this Agreement or under any other agreement We may have with or concerning You;
Persons in connection with any sale, merger, acquisition, disposal, reorganization or similar change of Our business (including any potential or actual purchaser of that business and that purchaser's advisors);
Third parties, if so required to comply with mandatory law or requirements; and
Address fraud or technical issues.

5. PERIOD OF RETENTION AND USE

We will retain the Data for as long as is necessary for the relevant activity or services described above or for as long as We are lawfully required to do so.

The Data will be destroyed if:

The purpose of collection and use of Data has been achieved;
The business for the CLIQ Connect App or Services concerned is discontinued; or
You withdraw Your consent to the collection of Data by contacting Us (for contact information please see Section 12 below).

6. TRANSFER

We may share Your information with other companies in Our group or with Our trusted subcontractors in order to provide the Services and for the purposes set out in this Privacy Policy. Processing of Data may therefore take place in countries other than Your home country. Data collected in the European Economic Area (the “EEA”), may be stored, processed or transferred outside of the EEA, as described in this Privacy Policy. The destination country may not offer the same level of protection of the Data as the country where You are located and may only provide You with fewer legal rights in relation to the Data. However, We will only process the Data as described in this Privacy Policy and use Our efforts to handle the Data securely and in accordance with applicable data protection rules. You expressly consent to Your information being used as set out herein.

7. PRECAUTIONS

Unfortunately, transmission via the Internet is not completely secure and We cannot guarantee the security of Data transmitted to Us. You are responsible for protecting the Device against unauthorized access and use, and any transmission of Data will be at Your own risk. Once We have the Data, We will take appropriate precautions to protect it from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Despite the protective measures We put in place, You understand that no data security measure can guarantee complete security at all times.

8. CHILDREN

The CLIQ Connect App or Services are not directed to children under the age of 18, and We do not knowingly collect personal information from children under 18.

9. CHANGES

We may amend this Privacy Policy from time to time. We will notify You through the CLIQ Connect App or the Services before such change applies. Before continuing to use the CLIQ Connect App or Services after such notification, You will be requested to expressly acknowledging and accepting the changes.

10. YOUR RIGHTS TO ACCESS AND CHANGE THE DATA

The accuracy of the information We hold about You is important to Us. You have the right to access the information We hold about You and have any inaccuracies corrected. You further have the right to withdraw Your consent to this Privacy Policy at any time and, to the extent stipulated in any applicable legislation, to erasure, by emailing Us (for contact information please see Section 12 below).

If any of the information We hold about You is inaccurate or out of date, please let Us know by emailing Us. We will respond within a reasonable period of time upon verification of Your identity.

11. YOUR RIGHTS REGARDING THE DATA

Except as described above, We do not sell or trade the Data. We might use or trade the Data for advertising purposes, but You have the right to ask Us not to process Your Data for marketing purposes. We will usually inform You if We intend to use the Data for such purposes or if We intend to disclose it to any third party for such purposes. You can exercise Your right to prevent such processing at any time by contacting Us (for contact information please see Section 12 below).

12. CONTACTS

If You have any questions about how We use the Data, please contact your local CLIQ reseller or ASSA ABLOY representative for service or support.